RNP-RA/18-0015, Application for Technical Specifications Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequently Requirements to a Licensee Controlled Program
| ML18117A006 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 04/16/2018 |
| From: | Kapopoulos E Duke Energy Progress |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RNP-RA/18-0015 | |
| Download: ML18117A006 (320) | |
Text
{{#Wiki_filter:( ~ DUKE Ernest J. Kapopoulos, Jr. H. 8 . Robinson Steam ENERGY. Electric Plant Unit 2 Site Vice President Duke Energy 3581 West Entrance Road Hartsville, SC 29550 0 : 8439511701 F: 843 951 1319 Ernit.Kapopoulos@duke-energy.com Serial: RNP-RA/18-0015 10 CFR 50.90 APR 16 .2018 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 RENEWED LICENSE NO. DPR-23
SUBJECT:
APPLICATION FOR TECHNICAL SPECIFICATIONS CHANGE REGARDING RISK-INFORMED JUSTIFICATION FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAM (ADOPTION OF TSTF-425, REVISION 3) Ladies and Gentlemen: In accordance with the provisions of Title 1O of the Code of Federal Regulations (1 O CFR Part 50.90) , "Application for Amendment of License, Construction Permit, or Early Site Permit," Duke Energy Progress, LLC (Duke Energy) is submitting a request for an amendment to the Technical Specifications (TS) for H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP). The proposed amendment would modify HBRSEP's TS by relocating specific Surveillance Frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specification Initiative 56, Risk-Informed Method for Control of Surveillance Frequencies." Additionally, the change would add a new program, the Surveillance Frequency Control Program, to TS Section 5, Administrative Controls. The changes are consistent with NRG-approved Technical Specification Task Force (TSTF) Improved Standard Technical Specifications (STS) Change Traveler TSTF-425, "Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 5b," Revision 3 (ADAMS Accession No. ML090850642). The Federal Register Notice published on July 6, 2009 (72 FR 31996) announced the availability of this TS improvement. Attachment 1 provides a description of the proposed change, the requested confirmation of applicability and plant-specific verifications. Attachment 2 provides documentation of Probabilistic Risk Assessment (PAA) technical adequacy. Attachment 3 provides the existing TS pages marked up to show the proposed change. Attachment 4 provides the proposed TS
U.S. Nuclear Regulatory Commission RNP-RA/18-0015 Page 2 Bases changes. Attachment 5 provides a TSTF-425 versus HBRSEP TS cross-reference. provides the proposed No Significant Hazards Consideration. There are no regulatory commitments contained in this letter. Duke Energy requests approval of the proposed license amendrT)ent by one year from the :date the application is accepted for NRC review. The amendment will be implemented within 120 days. In accordance with 10 CFR 50.91, "Notice for Public Comment; State Consultation," a copy of this application, with attachments, is being provided to the designated South Carolina Official. If you should have any questions regarding this submittal, please contact Mr. Kevin Ellis, Manager - Regulatory Affairs at 843-951-1329. I decl{ ~un~ ~ ~ty ~?Bry that the foregoing is true and correct. Executed on Ernest J. Kapopoulos, Jr. Site Vice President EJK/jlv Attachments:
- 1. Description and Assessment
- 2. Documentation of PAA Technical Adequacy
- 3. Proposed Technical Specification Page Changes
- 4. Proposed Technical Specification Bases Page Changes
- 5. TSTF-425 (NUREG-1431) vs. HBRSEP Cross-Reference
- 6. Proposed No Significant Hazards Consideration
U.S. Nuclear Regulatory Commission RNP-RA/18-0015 Page 3 cc (with Attachments) : C. Haney, NRC Region II - Regional Administrator J. Rotton, NRC Senior Resident Inspector- RNP D. Galvin , NRR Project Manager - RNP S. E. Jenkins, Chief; Bureau of Radiological Health (SC) A. Wilson , Attorney General (SC)
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RNP-RA/18-0015 Page 1
*I ATTACHMENT 1 License Amenc;lment Requ~st , ..
H.B. Robinson Ste~m l;:lectric Pla~t, Unit No. 2 (HBRSEP)
,
- Dock~t No*. 50-261 Application for Technical Specification.Change Regarding_Risk-lnformed Justification fo r the' Relocation of Specific Surveillance Frequency Requireme'n ts to a Licens~e . ' .
Controlled Program (Adoption of TSTF-425, Revision 3) Description and Assessment *1,
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RNP-RA/18-0015 ') Page2 DESCRIPTION AND ASSESSMENT
1.0 DESCRIPTION
The proposed amendment would modify the H.s ~*Robinson Steam Electric Plant, Unit No. 2 (HBRSEP) Technical Specifications (TS) by r.elocat!ng specific TS Surveillance Frequencies to a licensee-controlled program with the ad.option 9f Technical Specification Task Force (TSTF) - 425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - Risk Informed T~chnical Specjfication Task_Force (RITSTF) Initiative Sb" (Reference 1). Additionally, _the
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change *would add new program , the Surve'illi;ince Frequ~ncy Control Program , to TS Section 5, Administrative Controls. . . ' . . . . . . *
- The changes are consistent with NRG-approved lndu.stry/TSTF Standard Technical Specifications (STS) change TSTP-425, Revision 3 (ADAMS. Accession No. ML090850642).
The Federal Register notice published on July 6, 2009 (74 FR 31996) (Reference 2), announced the availability of this TS improvement. 2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Duke Energy Progress, LLC (Duke Energy) has reviewed the NRC staffs Model Safety Evaluation for TSTF-425, Revision 3, dated July 6, 2009. This review included a review of the NRC staffs Model Safety Evaluation, TSTF-425, Revision 3 and the requirements specified in NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies," (ADAMS Accession No. ML071360456) (Reference 3) . The TSTF-425 Traveler and Model Safety Evaluation discuss the applicable regulatory requirements and guidance, including the existing General Design Criteria (GDC) in 10 CFR 50, Appendix A. HBRSEP was not licensed to the GDC currently in 10 CFR 50, Appendix A. The GDC in existence at the time HBRSEP was licensed for operation (July 1970) were contained in Proposed Appendix A to 10 CFR 50, General Design Criteria for Nuclear Power Plants," published in the Federal Register on July 11, 1967. The HBRSEP Updated Final Safety Analysis Report (UFSAR) provides an assessment against the 1967 GDC. Based on the assessment performed and described in the HBRSEP UFSAR, Duke Energy believes that the plant-specific requirements for HBRSEP represent an adequate technical basis for adopting the proposed change. includes Duke Energy's documentation with regard to Probabilistic Risk Assessment (PRA) technical adequacy consistent with the requirements of Regulatory Guide 1.200, Revision 1, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, " (ADAMS Accession No. ML070240001) (Reference 4) , Section 4.2, and describes any PRA models without NRG-endorsed standards, including documentation of the quality characteristics of those models in accordance with Regulatory Guide 1.200. Duke Energy has concluded that the justifications presented in the TSTF proposal and the Model Safety Evaluation prepared by the NRC staff are applicable to HBRSEP and justify this amendment to incorporate the changes to the HBRSEP TS .
RNP-RA/18-0015 Page 3 2.2 Optional Changes and Variations The proposed amendment is consistent with the*STS changes described in TSTF-425, Revisfon 3; however, Duke Energy proposes variations or deviations from TSTF-425, as identified below and includes differing Surveillance numbers. Revised (clean) TS pages are not included in this amendment request given the number of TS pages affected, the straightforward nature of the requested changes and outstanding HBRSEP amendment reque~ts that will impact some of the same TS pages. Providing only the proposed'
- TS ch~nges in Attachment 3 satisfies the requirements of 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," in that the markups fully describe the desired changes. Not including revised TS pages is an administrative deviation from the NRC staff's model application dated July 6, 2009 (74 FR 31996) with no impact on the NRC staff's *model safety evaluation published in the same Federal Register Notice. As a result of this deviation, the contents and numbering of the attachments for this amendment req uest differ from the attachments specified in the NRC staff's TSTF-425 model application .
Next, recognition of the fact that Surveillance Frequencies that have not been changed under the Surveillance Frequency Control Program (SFCP) may not be based 'on operating experience, equipment reliability or plant risk, came after NRC approval of TSTF-425. Therefore, the TSTF and the NRC agreed that the TSTF-425 Bases insert, "The Surveillance Frequency is based on operating experience, equipment reliability, and plants risk and is controlled under the Syrveillance Frequency, Control Program ," should be revised to state, "The ., Surveillance Frequency *is controlled uhder the Surveillance Frequency Cdntrol Program ." The ' existing r's Bases infor~ation' will be 'relocat~d to the' licensee-controlled SFCP. provides a cross-re'fer'ence betweeh*the TSTF-425 (NUREG.!1431) Surveillances and the HBRSEP Surveillances included in this amendment request. Attachment 5 includes a summary description of the referenced TSTF-425 TS Surveillances, which is provided for information purposes only and is not intended!td be.a .verbatim *description of the TS . Surveillances. The cross-reference in Attachment 5 is intended to highlight the following :
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- The Surv~illances included ln TST P.!425 and the correspor1ding HBRSE P Surveillances * *
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- have differing Surveillance nutnbers.' 1* * * * * - * " -
*' The Surveillances .included ,ri:*Tstp:..42s that are not contained in the HBRS EP TS.
1
- The HBRSEP plant:spedfic S'urveillances 'that are not contained in TSTF-425 '*
Surveillances and , therefore, are not included in the TSTF-425 markups. There are markups for some Surveillances contained in TSTF-425 that are not contained in the HBRSEP TS . This is an admin.istra*t \ve deviation from TSTF-425 with no impact on the NRC staff's model safety evaluation datectJu'ly 6, 2009 (14 .FR 31996) . ' For the plant-specific S1,1rveillances in HBRSEP TS that are not jncluded in the NUREG-1431 markup*s provided in TSTF-425, Duke Energy has determined that relocation of these .*: Surveillances is consistent with TSTF-425, Revision 3, and with the NRC staff's model safety evaluation dated July 6, 2009 (74 FR 31996) , including the scope exclusions identified in Section 1.0, "Introduction," of the model safety evaluation. I *
- Changes to the Frequencies for these plant-specific SurveHlances will be controlled under the SFCP. The SFCP provides the necessary administrative controls to require that Surveillances related to testing , calibration and inspection are conducted at a frequency to assure that the
RNP-RA/18-0015 Page4 necessary quality of systems and components is maintained, that facility operation will be within Safety Limit~:and that.the Limiting Conditions for Operation will be met. J ~hanges to Frequencies, in the SFCP will be evalua.ted using the methodology and probabilistic risk guidelines contained in NEI 04-10, Revision 1, "Risk-lnforme9 Technical $pecificatior;,s Initiative .. Sb, Risk-Informed Method for Control of Surveillance Frequencies," (ADAMS Accession No. ML0.7136045.6) , as approved by ~RC letter :d,ated:September 19, 2007 (AD~MS Accession No .. ML072?7,Q267). The NEI 04-10,'Reyisi9n 1 methodol<:lgy includes qualitative considerations, risk,aAalyses, sensitivit~ tstudies and;_bounding analyses; as necessary, .and recommended *
- monitoring qf the performanc~ of sy~tems1 structures c:JJ)d components (SSCs).for which ..
Frequenci~s. are changed ,to assure that reduced testing does not adversely impa_ct the SSCs. In addiJioJil;. the NEJ 04-10, Revision 1 methodol9.gy satisfies ,he five key safety princ_ipJes specified inJ~egulatory Guide 1.177, "An :Approach for Plant-Specific, Risk-1.nformed . Dec.isionr;naking; Tectmical Specifications," dated August 1998 (ADAMS Accession No. ML003740176) (Reference.!;>), relative,to changes in, ~urveillance Frequenci.e s. Therefore,, the proposed reloc:;a_tion of the HBRSEP .plant-spec,ific Surveiilance_Frequencies is *co.n~istent with TSTF-425 and with the NRC staffs model safety evaluation dated July 6, 2009 (74 FR 31996).
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3.0 REGULATORY 1ANA1:-YS1S
\ ,.1 ; ' t *, , , * "I 3.1 . No Significant-Hazards Consideration* *{
l , .. . , * . . t \ .: . * - . * * . Duke ~nergy has'revie~~~ -the p'roposed no ~ig,~ific~~t tiazards considerati~I) (NSHC) . determination pu,blisheq iry \he Feoeral Register.dated July p, 2009 (74 FR .31996). D~ke Energy has concluded t~at *th~ proposed NSH~, determination presented in the Fede,ral Register Notice is applicable to HBRSEP, and is provided as Attachment 6 to this amendment request, whi9h:-,.s 9ti,$fi1;?sJ he.requirerrents.of- 10 CFR 50.~1 (a,), "Notice for,,pu.blic comm~nt; State con$:LJltatiq,:,;'.. ~: ' , , ., ' */.,_ *<*. r ,,, * . ." ,., * .. * **
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3.2 Applicable-Regulatory Reguirements/Cr~ter:ia ,1 * * , .. I , * '- , _,:ji \flrr;-
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A descripti'on of the proposed change and its relationship to applicable regulatory requirements is P.r~>\1i9-eq,_j~,TST:f:*t.4~*5,~~'.(isio~--.3, ..(,f\0AMS A~ce$~ior;t;Nq. ly1L09q_ ~~0642) and the NRC staff's model safety evaluation published in the Notice of Availability dated July Et 2009. Duke Energy h~s~c;<>ncl.l l9ed.t~~t ~~ .relatiqnshiR (?f the) propose~*.change 'to the applicable regulatory requirements-,Rr~_se,ited .in.J~e fe~eral .Regist~rn_oti~~ is ~pplicable to HBRSEP.
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3.3 Precedent The NR~ ha_;..*pre~jgJ~1/~pprov~d ch~nges*,~i.~i1~r\;* th~ 'pr3~os~d change i~ this License . Amend merit Request for other nucle~r *, ! power ' I
- plants including ', .. , .:. ' : J*
but not limited to the following
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- 1. ponald :C. Cook Nuclear Power Plant 1(CNP), .U nit:Nos. 1 and 2: Application dated .
** N*overn~er 1_9, 201~ (ADAM~ Ac~essiofNo:'. ML t$'~~~f.,450) ; NRC Saf~ty Evalu~tion dated Mar.ch,;31 ,, 201,7 (ADAMS Accession NO. ML17045A150).
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The CNP submittal requested approval ,t? relo_cate penod1c Surve1llan~~ Frequencies to . a licensee-controlled program and add a new program (the Surveillance Frequency qw1tr;9I f,rog~am) ._ to ~h~ A9i:ni.nistratiy.e .Cpntrols. s~ptfon of TS i.n accordance with N~C-appr,o\'.ed T,ST~-425. Th~ .H13,R S~P ~mendment reque~t is ~i~ilar to th~ CNP submittal in both.structure and con~ent.
- RNP-RA/18-0015 Page 5
- 2. R. E. Ginna Nuclear Power Plant (µinna): Application dated June 4, 2015 (ADAMS Accession No. ML15166A075); NRC Safety Evaluation dated June 28, 2016 (ADAMS Accession No. ML16125A485).
The Ginna submittal requested approval to relocate periodic Surveillance Frequencies to a licensee-controiled program and .add a r.ew program (the Surveillance Frequency Control Program) to the Administrative Controls section of TS in accordance with NRG-approved TSTF.-425. The HBRSEP amendment request is similar to the Ginna ~ubmittal in both structure arid, content. * * * * * * , * ,*_ * : 3.4 Conclusions
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1 In conclusion, based on the considerations* discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the 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.
4.0 ENVIRONMENTAL CONSIDERATION
Duke Energy has reviewed the environmental consideration included in the NRC staffs model safety evaluation published in the Federal Register on July 6, 2009 (74 FR 31996) . Duke Energy has concluded that the staffs findings presented therein are applicable to HBRSEP, and the determination is hereby incorporated by reference for this amendment request application.
5.0 REFERENCES
- 1. TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," March 18, 2009 (ADAMS Accession No. ML090850642).
- 2. NRC Notice of Availability of Technical Specification Improvement to Relocate Surveillance Frequencies to Licensee Control - Risk-Informed Technical Specification Task Force (RITSTF) Initiative 5b, Technical Specification Task Force - 425, Revision 3, published on July 6, 2009 (74 FR 31996) .
- 3. NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-I nformed Method for Control of Surveillance Frequencies," April 2007 (ADAMS Accession No. ML071360456).
- 4. Regulatory Guide 1.200, Revision 1, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," January 2007 (ADAMS Accession No. ML070240001).
- 5. Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:
Technical Specifications," dated August 1998 (ADAMS Accession No. ML003740176).
RNP-RA/18-0015 ** ; ** i. Page 1 ATTACHMENT 2 License Amendment Request
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H.B.' Robinson Stea~ Electric Plant, Unit No. 2 (Hl;3RSEP)
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- Docket No. 50-261 **
- Application fcjr Techni.cal Specification Change Regarding Risk-Informed justification for the Relocation of Specific Surveillance Frequency Req.uirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)
Documentation of PRA Technical .Ad~guacy
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RNP-RA/18-0015
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Page 2 1.0 Overview H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP) will follow the methodology provided in NE! 04-10, Revis.ion 1 (Referenc;;e .1), to develop a risk-informed Surveillance Frequency : Control"Progran:, (SF.CP) for controi of Technical Specification surveillance frequencies. ** Guidance for implementation of a generic Technical Specifications improvement that *
- establishes licensee control of surveillance test frequencies for the majority of Technical Specifications surveillances is provided in NEI 04-:10. Existing specific surveillance'frequencies will be removed from Technical Specifications for the affected specifications and placed under licensee control pursuant to the NEI 04-10 methodology.
I' a The NEI 04-10 methodology uses risk-informed , performance-based approach for establishment of surveillance frequencies an9 is consistent with the philosophy of NRC Regulatory Guide 1.174, Revision 2 (Reference 2) . Probabilistic Risk Assessment (PRA) methods will be used to determine the risk impact of the revised surveillance intervals. PRA technical adequacy has been addressed through NRC Regulatory Guide 1.200, Revision 2 (Reference 3) , which endorses the ASME/ANS PRA standard , RA-Sa-2009 (Reference 4) . External events and shutdown risk impact will be considered ~s de?cribed herein. . This attachment demonstrates the technical adequacy of the HBRSEP PRA model to be used " - as the 'basis for the HBRSEP SFCP, consistent with the requirements of Section 3.3 and , .. Section 4 :2 of Reference 3 as follows :
- Section 2.0 of this attachment addresi es the need for the PRA model to represent the as-built, as-operated plant.
- Section 3.0 of this attachment discusses perm anent plant changes that have an impact on those thi ngs modeled in the PRA but. hav~ not been incorporated in the baseline PRA *
~
1 1 model. : * , * , : I . , i * , 1
- Section 4.0 of this attachrnepf ~eniorist;ates that the ~a,rious technical ~leme~t~-of the . ' .
HBRSEP PRA have been perfor~ed :consistently with tne AS ME/ANS PRA Standard as**-. endorsed in the appendices of R~gulatory Guide 1.200. The.peer review~ that have been condt.J.cted and the resolution of fi9ping ~ f rom those reviews are. included in Tables*
- 1 through 3. Those tables demonstra e that the pieces of the PRA have been*performed .
- in a technically correct manner. ** *
- Section 5.0 of this attachment includes a summary of the methodology that will. be used *.-
to assess the risk under the SFCP.
*
- Section 6.0 of this attachment identifies the key assumptions and approximations *
,;*h ~levant to the. results used in the decision-making process. This section provides asswance that the assumptions and approximations used in t.he development of the P~A are* appropriate.
2.0 Basis to Conclude that the PRA Model Represents the As-Built, As-Operated Plant
' -~ *t * ,. I The HBRSEP PRA Model of Record (MOR) is maintained as a controlled docume t and is updated on*a perjodic basis to represent the as-built, as-operated plant. Duke Energy
RNP-RA/18-0015 Page 3 procedures provide the guidance, requirements and processes for the maintenai1ce, update and upgrade of the PRA: a . . The process includes a review of plant ch'anges, relevant pla'nt proced~res an.d pJarit opefating data as required , through a choseri' freeze date to assess the effe.ct on the PRA model. ,
- b. The .PRA model and controlling documents are revised as necessary tb incorporate ,
those changes determined to impact the model.
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- c. The determination of the extent of model changes includes the following : .,
- Acc~pt~~'~ in'.~~~try -~R*A pra:tices, '. gr~Lind 'rules and ass'umptioris coris1stent 'with 1
those empJoyed in the:ASME/ANS PRA Standard .(Reference 4), * \ "' .1 (, J , I w * ,l : 1
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- Current. industry*.practices, * * .* ** * ' * * - * -
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* ( NRG' guidarlce (e.g.,'*Refererfces '2 ~*~d-'3j'; *. ;, .. '- , - ' '
- Advances in,PRAtecti'nology and _m~f~odoiogy, and... , ;,*,
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- Changes in externarhaz'ard'tonditions.' : * '* * . .
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For plarit change*s*of*sm?II 6r*neg'Hgibl~ ir'np~ci..*t~~ _rpqd.~l .~hang_es_.ca11 ~ a,qc,1:1mulated and a single revision is pe'rfo'rmed at ~n i'riterval consisfenfwith* major PRA. reyl~iQns. -\ The-results of each evaluation determine the necessity and timing of incorporation'of a partfoular change into the PRA model. An electronic.tracking .databas~ i~ 1,c1tilizepJo dqcl!meot p.Wi)dinfJ fl1o<jel changes and undates:0 : ' .. , .. , . * . . :' * ' -, , ., .: '-* C' * .*, \.,,I, . .. _*. . * *.: . . - ** .- : . ,.. f'"" ' ,, ., ** .'* .' ( ! ;_. ._ .. I
- 2.1 HBRSEP PRA Model History .. ,.
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In ~Spense,to>the ,otigiiiar Generic t.ett'er *as-2eW fhe ~992 t ntfi~iduar'PY~'.n't' *E~~rJi~ation.(I PE) 1 was developed to address the risk from internal initiating events including internal flooding. In 1995, the scope was expanded and the Individual Plant Exa~ination 9.f Ext~rnal Events (I PEEE) *wasr?ireatedto ad~re~s,t~e. ris~ *_ of-~~!~~r~ :~J~r.!ftr:n!~rh'ci( firrs \.~i~h.W-inds and tornadosr externat floods' a111d transp9rfat1on ah_g:ne~rbY:fata~t_y"ac~1~e_r,~s. T,he HBRSEP PRA model hasrutldergo1:1e*numerbus upttafes an'd-'revie~ 'since tne 6rig_ ina'l_dev~lopment to maintairfa r;epresentati"Oi"t'-Of ,t he as..:buift, 'a s:.o,per~\~t1 :p1ahti l~ hisi:io~!;~'. to improvementS; in PRA technology *cll'ld,state:..of...the!-art mettiod6logies.; ttielfdlldwing J~t~sen.fs surnmarie,s of the HBRSEP PRA MOR updates. * ' '" * * * *
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t*- . ** I MOR 2010 addressed Findings and Observations (F&Os) from the 2010 RG 1.200 Peer Revi~w and the changes ,madeldurJng that mddel lipdale' have bee~*.-carried through the current model of record.~.The 201CH~G 1-.200 Peer Revi.e w*is the pee(re'view ofrecord*for internal events* (excludt11g ioter.oal floadin*g,*.which was asses'sed at*a*later date):***MOR '2.010 'also 'in~luded updated modeling of the Human Reliability Analysis (HRA) , updated data *and updated success criteria documentation. t
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MOR 2012 again updated modeling of the HRA, added d?\~ and updated success criteria. An additional change-as part of this'PRA; model'tJpdale *was tb 'tfie Le_ vet ?/LE.Rf' .?n?lysis, which in conjunction with the; b:evel 1 updates.r resultea in1updated 'LERF values and i'n'sights.
RNP-RA/18-00 15 Page4 MOR 2015 included the "C" motor driven Auxiliary Feedwater pump and its diesel.generator, added new shutdown seals to the model and incorporated other PRA model improvements consistent with plant 'design and operation . A new post-initiator HRA was also performed as part of MOR 2015. ' . Several open findings associated with the HBRSEP internal events PRA model were reviewed and closed in August 2017 using the process documented in Appendix X to NEI 05-04, NEI 07-12 and NEI 12-13, "Close-out of-Facts and Observations" (F&Os) as *acc-epted by NRC in the ,
- letter dated May .3, 2017 (ADAMS Accession No. ML17079A427). The results of this review have been documented and are available for NRC audit. The remaining open.finding s that have not been resolved are listed in Table 1. , ** ..
Internal Flooding Model History The initial HBRSEP internal flooding PRA model was released in June 2015 ahd was*based on*' the MOR 2015 internal events model update highlighted above. ~hortly ~fter th~ internal flooding model was released , a full 7scope internal flooding peer review on the HBRSEP model was held and the final peer review report was released in August 2015. The internal. flood ing
. I model was subsequently revised to incorporate the F&O resolutions and shortly following the
- I final peer review report, Revision 1 of the HBRSEP internal flooding PRA model *was released .
Several open findings from the HBRSEP internal flooding PRA model were reviewed and closed , in August 2017 using the process documented in Appendix X to NEI 05-04, NEI 07-12 and NEI 12-13, "Close-out of Facts and Observations" (F&Os) as accepted by NRC in the l_etter dated May 3, 20*1i (ADAMS Accession No. ML17079A427) . The results of this review have been , -* documented and are available for NRC audit. The remaining open find ings that have not' been resolved are listed in Table 2. * * : ;. ' *., "*
. : I**: ** .,:*
Fire PRA Model History ; .** *:. ; ,, ,. I .,. ,,,*,
- A full scope fire peer review of the HBRSEP Fire PRA mo-defl 'w as *performed in 201'3th~t is .
considered the peer review of record f6r 'all technical .elements except for the F ire Scenario Selection (FSS) technical element. Following the fu !'scope peer.review, ch~;1nges *and updates were made to the Fire PRA model that were ,su~~tantial enou9,h to.. warrant a_follow~up _peer * *. review. A partial scope' fire peerreview was performed (also in 201 3) and the scope *of this peer review was limited to the FSS technical element. ' * * * *
- i Several open findings from the HBRSEP Fire PRA.niodel were reviewed and dosed in 'August 2017 using the process documented in Appendix X to NEI 05-04,.NEI 07-12 and NEI 12-13, *
"Close-out of Facts and Observations" {F&Os) as accepted by NRC*in the letter d ated May 3, 2017 (ADAMS Accession No. ML17079A427). The results of this review have been documented and are available for NRC audit. The remaining open fi ndings that have not been resolved are listed in Table 3. *
- J.
3.0* Identification of Permanent Plant Changes Not Incorporated in the PRA Model
; .., ' * " ~ I .*1,* ,,J ** s The current HBRSEP Model of Record (MOR 2015) is being used for current applications. All ,.
permanent plant modifications and Engineering Changes (ECs) that have been implemented since MOR 2015 have been reviewed as part of Duke Energy PRA model maintenance procedures. There are currently no identified permanent plant modifications that have a significant impact on the PRA that have not been incorporated into the MOR.
RNP-RA/18-0015 Page 5 4.0 Conformance with ASME/ANS PRA Standard The following sections describe the conformance and capability of the HBRSEP PRA against the ASME/ANS PRA Standard. 4.1 Internal Events and Internal Flooding PRA In 2010, an industry peer review of ttie HBRSEP internal events PRA model (excluding internal flooding , which was assessed at atlater date) was performed in accord'ance with NEI 05-04. The model was evaluated. qgainst ASME PRA Standard ASME/ANS RA-S-a-2009 and Regulatory Guide 1.200, Revision 1. All findings from the 2010 peer review have ,been resolved . Several of the findings have been closed using the process d9cum~n,~-ed.in ,Appendix , X to NEI 05-04, NEI 07-12 and NEI 12-13, "Close-out of Facts and Observations" (F&Os) . The six findings from the 2010 peer . review that still h.*..ave. not. peen closed qfe. listed .... .in Table ... 1. In 20 ~5., ~n industry p~ef reVi!3~ of ,th.~ .-H BRSEP'_ int~rn~J floodin"g ~RA rri'g~e,i wa~} ~1qrrne9 in accord ante. with _t,U; I 05-04. T.h~ .mqde1*,w~s .~v~lua\e9 against .(1.SM,E PRh Standar d *. . ASME(A_r;JS RA-Sa-2009 ar;id_Regul~t?ry Guide 1.2p9J =~-~~isio_r:i ,2- ;J\11 fi~~l~~~_frprf). the 2015 peer re~1e_w.,hav~vbe~n .resol~~d . ~~v~r~I o( the find_1n9f h~ve been:cfo~eg ys)ng the:process documented .in Appendix X to NEI 05-04, NEI 07-12 and NEI 12-13, "Close-out of Facts and Ob~~rv_atjo~~,, (F~Os) . .Th~. fo~r f_jndings.from t)1e 201.? p~er_,r;ev.i~V.: ~ha,t s til\ hA_::e,not been closed ..~~e .hsted 1n Ta~le~2, *,:) ,:_ . ; ,* . .,-, 1
- r**<'--:* * ., ....-:~ .* "'* *:. *1 '. . .-.*.. . ,
Tables *1.'a~d 2 pro~i.?,e;,a c~_ ~ pi~ti _li~fRf~{the _. Q~~~~fi~~iing~ tr~~:*th~)nt~~,n~! ~~in~.s a~d- . internal flo?din__g p~~c r7¥Je.~~ ari~ cJ d1sp9sitiop f9r ;~ ch. fi~d1 _ ng to pet~rmi_ n e ,Y1f.h et~r J~e find ing has any sig*nificant impacf on the Risk Informed Technical Specification Task Fqrc! (RITSTF) Initiative Sb application . * " ** -- *
*i~
- 1
.i ** _; , '"*.~I ,
- In reviewing the HBRSEP risk informed License Amendment Request (LAR) for implementation of NFPA_~Q§ 1it~1¥ J~Rc; ,~ia.ff..e\{~l_uate.9 _ t q~ q.y 9Hty 10!~~:ia_t~rMt:ev.e nts f.?.~/.t.0-m9d_el u~eq to support d~~$rlC?eP.1e.n_t ,oJ1t~~.fir..e_gff\ T,he,_<;>~je~tiv~.~ f1t~ q~ 9J\ty re,vi~w ~;;is. "to. d_eterflJ_ine whet"h~r,tl;)_r.;R!~~t"J.~U?~cj,fic.P_R.f. \~~~d ~j~ e.'l(.~lua,il')g .!tl~ ;P.U~R9,~~ Lf.\~ .i.s.of .sufficierit scope, level of detail,.~ ~Gh,,fclj¢.~.I ~qequ}~9Y f9 f1th_~1~PPlig~ti<?P.:/L J ha,r.f!SY.lts, o_f tl:le t;.JRC _-s taff quality 1* .
- review_ar:~1dQ9y,~.~~~ 1in t~~ H~R,SEFf\NFP,f\~.0§, §af~_ty..pv~l14c1tion f.qr-tran$ition to .a risk- ..
informed, performance-based fire protection program1~D1 .M..RiAPq~ssi~n No: ri,11 1..1.633?'A264). The staff concluded that the licensee has demonstrated that the HBRSEP internal events PRA model is._tec~11ical,.ly-~deq~~te.J?,s~pport.th~ Ni::~~ 89~ (isk ,c,~lc;:4latiqn necessary.for, the
- license amend men( ,) Nhile,tll~ partic~ar, ewf!J.u.atio_n.was ;not 1~p~citic to -~h~ R ITSTF lp itiative Sb
- application ,. it fu~n.er.A~i:nonstrate~ th~.te<;:_hni_p~l .9 geq~acy-qf"the inJer.nal events PRA model. , ..
.. ~* - . .. .* f , ' * . . : . ;' ~ *, ..J * ~' ' .._ t:* ~ : C ;:;_ ,.:* .f. ,: \*.,. , - . "
Based _on th~ ,resylts, (?f tt;i~ peer r~view!p an.d r~5?lu!i.o rs1. .t l;l~ . ~BRSEP internal events and internal flooding PRA models meet the requirements of the ASME/ANS PRA Standar d as clarified by Regulatory Guide 1.200, at an appropriate capability category to support the HBRSEP_~ fCP ~,I he J:-l~RSE~ internal events.al)q ,inter11alj lo~dir,g PRA models '!Viii be 1:tsed in accordance with NEI 04-10 to assess proposed surveillance frequency changes under the SFCP::.. . *,1. ....
* ,r RNP-RA/18-0015 Page6 4.2 Fire PRA The HBRSEP fire PRA was developed using the guidance *1n NUREG/CR-$850 in suppo~ of the NFPA 805 fire protection program . The fire PRA is built upon the internal events PRA which was modified to capture the effects of fire . In 2013, a full scope industry peer review was performed on the fire PRA using NEI 07-12, Fire Probabilistic Risk Assessment (FPRA) Peer Review Guidelines. The model was evaluated against the ASME/ANS RA-Sa-2009 PRA .
Standard, as clarified by Regulatory Guide 1.200, Revi_sion 2 . Also in 2013, a partial scope,peer review was performed on the* Fire Scenario Selection (FSS) technical element. Several findi,ngs from the peer reviews have been closed . using* lhe process documented in Appendix X .. to NEIl '. ',: 05-04, NEI 07-12 and NEI 12-13, "Close-out of Facts and Observation.s" .(F&Os) . HolJl.'.ever, a total of six findings from the two 2013 peer reviews have not been dosed to~date.
- Table 3 provides a complete list of all the open findings from the fire peer reviews and a *"
disposition for each finding to determine whether the finding has any significant impact on the Risk Informed Technic?tl Specification Task F:orce (RITSTF) lnitiati')(e Sb application . The six findings*that are still ope_ rY and their.assoclate,d resolutions were* includ~d i*~ the HBRSEP NFPA 80.5 t:AR. The* results of the NRC staff quality review.' of the Fire PRA are a documented *in 'ttie HBRSEP N.FPA 805 Safety Evaluation for transitiofl to ri~k-informed , performanc*e-based *fire protection program\ The_qu~lity review concl~l°ded that th.e techni~a,I " adequacy and quality of the HBBSEP 'P'.R A i~ *suffici~nt to sup'p~rt risk-info[med changes t9 .the
' " *
- J ' " I~
- NFPA 805 fire protection program . *~
Based on the results of the aforementioned peer reviews and the [esolution the HBRSEP fire . PRA meets the requirements*ot°the.ASME/ANS PRA Stahdard as clarified .by Regiiatory Guide ' 1.200, Revision 2, at an appropriate capability category to support.th~ H6RSEf:. SFCP: Th~.fir~ .: PRA will be used in 'accordance _with_NEI 04-10 to assess proposed surveillance frecfuency .. ." , changes under'th'e SFCP. . ' . . *. . 4.3 External Events The NEI 04-10, Revision *1 methodolo-gy allows fdr surveillance frequency change ,evaluations to be performed in the absence of quantifiable PRA models tor *a11 exter_nal hazards, ' For those cases where the surveiilance frequency cannot be modeled in the plant PRA (or where a_ particular PRA model does not exist for a given hazard group), a qualitatiye or bounding analysis* is performed to provide justification for the acceptability of the proposed-test interyal change. Currently, HBRSEP does ilot have high winds, external flooding or seismic PRA models that have been evaluate~ agc!inst the ASME/ANS Standard, as clarified by Re~ulatory Guide 1.200, Revision 2. The followi ng discusses the overall external hazards analysis methodology at HBRSEP. *
- The general ;
approach used to *develop the
- external* r events PRA *at HBRSEP is a$ follo~s:
I , ~ * , , ,
- 1.
- Identify all natural and man-made credible external events that may aff~ct } he site' .using many reference sources. * * * ' *
- 2. A screening analysis was conducted using *defined bounding criteria in order to select those events that may require further review.
RNP-RN18-0015 Page 7
- 3. A scoping analysis was performed on the remaining non-screened events to determine those that warranted a detailed site and plant-specific analysis.
This approach is consistent with that previously submitted to the NRC in the Individual Pla,-,t Exarri-iri~tiori of Ext~rn'al Events (IPEEE). . 4.4 Shutdown Risk HBRSEP *operates under a sh_utdown risk manag.ement program to support implementation pf *
- NUMARC 91-06. The shutdown ris.k mi?nc!gement,implementing procec;lure provides guidelines ,
for outa'ge risk management which focuses on proper planning, conservative de.cisioi')-making, . maintaining defense-in-depth _and c6r,itr9lling key safety functions. HBRSEP will use .the shutdown risf manage.rnent prograrr proc;:edures to assess shutdown risk ,for proposed *. surveillance frequency changes. 4.5 Conclusions on External Events and Shutdown Risk I * ~ r* <. External hazards screenings have been performed for HBRSEP to support requirements of the IPEEE. NEI 04-10 allows for proposed surveillance frequency change .ev~luations to use .. hazard screening in the absence of .external hazards P.RA models. In *cases where these , methodolo~ies are not apprOp(iat_e for:~ surveilla'nce fr_equency ch~nge eVfll.Uation , 9ther qualitative o~ bo.unding analysis will be .utilized to provide justification for the .accept,abiljty of the proposed surveillanc_e frequen.cy c~ange. HB~$~P w(II ~Qllow Jhe NEI 04-1 O gu,idance to. . assess external events *and shutdown risk associated with potential..surv~illar;1ce frequency changes. * * " * ** ' *
~~ u_
1 5.0 . M~l.thodo~*OQ~JQ sed to Af~~ss_~Y"¥~,,l~nc~ Fr_ ~~~enc>'*Ch,ang~s Existfn~l R~~.~' ~ n-~_rgy P.E.O~~dures ,~eHve4 fr,9,~ \~~ Ng,i' q1)0:*~~i~a,~F:~ iili.b~ the SFCP *anti-the surveitlarfce test *interval {~hi) evaluation process. The tc;>.llo"Ying steps .will be use.cl,to govern used to assess proposed changes within the HBRSEP program. * *
- Each STI revision will be reviewed to determine whether there are any commitments mfd-~ to.me. ~.RC ~~at1,r:n,~y,p_r10,~.i.~~t.. c.~ar;i~.ir;ig t ~~ in,~yr.y..c;i.1,.. lf.~~~r~ are no rela~ed cornrq ~m~pt~\ 9-r.~e. p~rti~u!a( .qomm1fPl~~f~f:J:~Y} j~,c~~0ge~. us~r:,g a comm1tmen! .
- c~~XJ_S,~pt~~e~~ b~~~d .. ~.n...r'J~~"~~dersE!f;l,~.~}~Pce:J~tn.}~~aJ~pt1on of th~ STI rev1s1on w1l\))f0.C~~~ :,. ,If_~.~?l:Q[lltJJJem e~1~t~ ~Qf;1i-t~!3.,,C ~m.~tll]ept_~bang~ p,ro,qes~ c;jqes ~O!
permit t~~ q~~P,~r,-*, \~e~ :!~~' S~! rev_1~.1~0.,.w~11... ~~~- P~. 'ITTR~~r11.ente? *. Only, afteu~ce1v1ag , for,~al NRE:'3P8r.~y~l,tq ;e~a.n.Q~ .the ;C(?,OJITl)trn~r:il ~1lt ~r,..§J..I, revJ~1qn pr~ceed. , .
,-* i . -..;.i,!~,.-* ..., I"' ... ~ 4 .... *,,I . . **:;"., ,~** :' :** * '. 1: *(1 *\~,1: t':"Rt.. *) ."1 :**' - .-:* ' ' *
- Sy~tems en9.i9e¢r!~S,ey~I\J?~19ns_~n~ gl!qntitati_v~ ~~sess1;11en~s from available PRA models will be developed for each proposed STI revision. The HBRSEP internal e.vents;
- internal flooding and fire PRA models will be used to assess whether an SSC is affected by tt,e propq~ed~S"'[I change'. In c;;alculq~ing $.$C,fai lure .r~te_s, .if. ~e breakdown between the standby"time-dependent failure rate.and the demand-related failure rate probability for affected SSCs is uaknown, then the .totaJ tailure,prqbability will be assumed to be
. time-related to bbtain the maximum test-limited risk condition. The total and cumulative effects on Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) will be ass:ssed and ~umulative risk wi,11 b~ tr~c.k,ed :
RNP-RA/18-0015 Page 8
- If an SSC being assessed is not modeled in the PRA, th~n an appropriate*qualitative or bounding risk analysis will be performed for the SSC. Duke Energy procedures derived from NEI guidelines will be used to determine i.f the qualitative analysis is sufficient
- Hazard screening performed for the IPEEE will be used to assess external events considerations for potential STf revisions. The HBRSEP shutdown risk management program for *implementation of NUMARC 91-06 will be used to assess the shutdown risk.
- The results of each STI assessment will be documented and presented to an Expert Panel, referred to as the ~ntegrated Decision~making Panel (IDP) '. The IDP will normally be the same panel used for Maintenance Rule implementation but with the addition *of specialists with experience in surveillance testing and system or component reliability If the IDP approves the STI revision, the change will be documented and implemented, ahd will be available for audit by the NRC. If the IDP does not approve the STI revision, the surveillance frequency is left unchanged. *
- Performance monitoring will be conducted as recommended by th~ IDP. In some cases,
*~o additional monitoring may be necessary beyond that *already .cqnducted under the Maintenance Rule. Performance monitoring helps to _c9'nfirm th-flt no failure mechanisms ,
related to the revised STI become important enoug:i, to:al,t~r tt,e inform~tion provided for the justification of the interval change. Second, performance monitoring ensures, to the extent practicable, that adequate component capability (i.e., margin) exists relative to the design basis conditions so component operating characteristics, over time, do not result . in reaching a point of insufficient margin before the next scheduled test.
* ,The IDP is responsible for periodic review. of performance monitoring results. If it is determined that the time interval between successive performances of a surveillance t~st is. a factor in the unsatisfactory performances of the surveillance, the IDP will reset th~ STI to the previously acceptable test interval. . .
6.0 Key Assumptions and A"pproxirnations 1.1:-- A list of potential contributors to the uncertainty in the PRA were compiled . Tf1e list below in represents the modeling assumption'~ and uncertainties that are considered to have the greatest impact on the HBRSEP PRA results if different reasonable alternativ.e ,assumptions are utilized. 1 * * * *:-; i Key ' . Assumptions and,Sources of Ur:,certainty in the HBRSEP . l?RA I
- Uncertainty Evaluation RITSTF Initiative 5b LAR Impact 1 Reactor The HBRSEP PRA model uses the The approach utilized-for modeling Coolant Pump WOG 2000 RCP seal failure model, RGP. seal LOCA frequencies is (RCP) Seal and it assumes RCP seal leakage consistent with industry practice Failure every time both Seal Injection and based on the current-state of .
Thermal Barrier cooling are lost. knowledge: Sensitivity studies will be This is an Industry consensus conducted in accordance with NEI model. For risk applications this is 04-10 guidance to determine if other one of the most important areas of considerations might lead to impacts uncertainty. on surveillance extensions. The
RNP-RA/18-0015 Page 9 1 Key Assumptions ~nd Sources of lJncert~inty in the HBRSEP PRA *
- Uncertainty Evaluation RITSTF Initiative Sb LAR Impact assess,ment of the uncertainties, therefore, is appropriately included in
-' this risk.:informed application.
2 Loss of Off-* LOOP initiati~g events have been The approath utilized for modeling Site Power shown to be important contributors the LOOP frequencies ijnd the (LOOP) to CDF due to the potential for_ * .~- recovery proqabilities is' consistent
* ' . I ' .Frequencies station blackout and the reliance of; with *industry practice.,Sensitivity L
- 11 many frontlin'e s*ystems on 'Ac _. , studies will be conducted in .
power. The LOOP initiator was accordance with NEI b4-1 O guidance separated into plant, grid, to determine if other consider.ations switchyard ,. and weqther in<;luced, , . might lead.l o im~-~_ cts on ~µ,~ eillance LOOPs, which allowed the. mode.I to :extensions. The*as~essmeht of the apply recove~ c;tctiqns to the ,higJ;ler.1
- uncertainties', thereto~~. is ,* , .
*~ : t *, I 'trequer'l'cy events (i.e., plant anc!. . *' appropriately-induaed ir:, this.risk-
*switchyard). HB~SEP used. generic 1. informed* applicat.ion. . '. ..
industry' data'to calcu'late LOOP '" .,, -* \ . ' . ,, . .~
,, ,'. 'I I ' *, j ' I ' l ,~ \ ') ( '1 f requenc,_es.-.. . ,, ' . *J'. / ' ,* ,, ' ., ... ' ,, **r,':* . .
3 Fire Modeling The HBRS~P' Fire 'P RA (~PRA) .** !;,'. **updat~d , .NRC-approved FPRA model complies with the . ,, - . : ~~c~rologies tWm be *incorporated in _, NU~EiG/GR.:6~50 meth()dolo,~y_,tt(~t,, tp~Hi?F,S6P FPRA model as they
, .. , )nCll!ldes *unceftainti.~s fro_m _t~~ ~' .*. ,;. J:>ec9111e;a~ailable in accorda'fice with
, ,., ' iQherent*randoniri'ess :in 'eler,ri_$,r,W r.:;* : th~..Ji1,9.r.m at*P.RA* majnten~hce and
... that comprise the FPRA r'tiode(' ahd' "' Lipdate (MU) procedures. Sensitivity from the state of knowledge in ._ .. * ;i .~lHAifi~ t~1i!libe..:eonducted*ih' *'
these elements as the FPRA ~ .. accordance with NEI 04-10 guidance technol_ogy cont.inu~s. tp .T.v;..~Jye._ . *u .;~: *;-t,9:fi~Je..rmioe j ~ 0ther consicl'era~ions
.. . _..- *::; ._These *1n?lud'e the tre'.. ,~~!t'?~ (" i, :,: r. .1g,19~1t ),~ 9_<;i tw1 mpacts on ~urve1llance
..* ! . fr.~uenc1es,, h~atTele.a~e_r~teG, ~rf:;!t\t ,~e~xt~(l,~l~n~,: J.:he assess~ent of the .
, . *:,' ., ,-gr0.wth. turves,: fire* sl:lppresslon uncerta1nt1es, therefore, 1s
- failure probabilities, severity appropriately addressed by the factor~. ~.nd po~t-.initia\or hUIT!~n: .. .,: *::,§en$iti~ity;studies required by this failure* event' probabilities. While the risk-i~torrned application.
appr.o~~~~s ys~~ \i;t the HBRSEP ,, ., .-- ,,~-. :; FPRA *are NRC-approved * ,, , ... ,..... methodologies;: they are still ., ? *: *. ..
' *- constraine<;i by the relatively 'limited***: . :*, . " .
.. ' dat~ on fire .events- at Nuclear ** , ,,
~ow.er Plants. , , 1 ':
; :, * * *
- J ,-
RNP-RA/18-0015 Page 10 7.0 Conclusions on PRA Technical Adequacy ' The HBRSEP PRA is sufficiently robust and suitable for use.in risk-informed applications such as the SFCP. The peer reviews that have been conducted *and the resolution of findings from those reviews demonstrate that the pieces of the PRA have been performed in a technically correct manner. The assumptions and approximations used in development of the PRfi.; haye also been reviewed* and are appropriate for their application . Duke Energy procedures are in place for controlling and updating the models, when appropriate, .and for ensuring that the , model represents the as-built, as-operated plant. Therefore, the conclusion is that the fiBRSEP PRA model is acceptable to be used as the basis for risk-informed applications including RITSTF Initiative Sb. . 8.0 References
- 1. NEI 04-10, Risk-lnfonned Technical Specifications Initiative 5b, Risk-Informed Method i for Control of SuNeillance Frequencies ," Revision 1, April 2007. '
- 2. Regulatory Guide 1.174, An Approach for Using ProbaQilistic Risk Assessment in Risk.:,'
lnfonned Decisions on Plant-Specific Changes to the Licensing *aasis," Revision 2, u.s.** Nuclear Regulatory Commission , March 2011 . . :
- 3. Regulatory Guide 1.200, An Approach for Detennining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Ac(ivities, Revision 2, U.S. '
Nuclear Regulatory Commission, March 2009. _.; I
- 4. AS ME/ANS RA-Sa-2009, Standard for Level 1/Lar_ge.Early Reloase Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications-, Addendum A to .
RA-S-2008, ASME, New York, NY, American Nuc)ear Socie.ty,1..a Grange Park, Illinois, February 2009. " ~* .. ' , . .
*;. i ...
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RNP-RA/18-001S Page 11 Table 1: Disposition and Resolution oJ Open Internal Events_Peer Review Findings
) -
Finding Supporting Capability . - - ._., *> ~ _- Qescriptioh Disposition for RITSTF lnjtiatiye Sb Number Requirement(s) Category (CC) *-- AS-AS-3 AS-AS 1/11/111 HBRSEP,2-F/PSA-0043, Section 4.8, An Induced SGTR model, bas.e<:i on AS-83 ConsequeniJal , Pressure-fnduced .,- the guidance in NU~EG~:1570, "Risk Internal SGTR not coosidered . "Conseq*uential Assessment of Severe Accident-Events tube ruptures due to high primary-tq- Induced Steam Generator Tube secondc:fry differential pressures (e:g., - Rupture," USNRC, March 1998, has due to secon9ary line breaks or A TWS been developed and js included in the events) are**not explicitly considered in .. PRA. Therefore; the impact of the model. :Secondary line breaks can *induced SGTR is c;:onsidered for the result in' a primary-to-secondary* RITSTF Initiative Sb ~pplie:ati'on. different1i3l:pressure equivalent to ~CS * .. pressure." * -
- '. ' C\
- ."', (
RNP-RA/18-0015 Page 12 Finding Supporting Capability Description Disposition for RITSTF Initiative 5b Number Requirement(s) Category (CC) DA-E2-1 DA-E2 1/11/111 The PRA documentation does not Development and discussion of the show the probabilities or basis for the occurrences represented by the basic Internal probabilities for the following basic events cited in the F&O may be found Events events (note that the basic events are in the Westinghouse Owner's Group assigned probabilities in the fault tree): document "WOG Risk-Informed ATWS
#ACRDMF (control rod fails due to Assessment and Licensing
. mechanical binding), #CRDMF (insufficient rod insertion), #RPS Implementation Process":(VVCAP-15831-P) which is cited in the (failure of reactor trip) , EAMSAC HBRSEP2 Success Criteria calculation I ' (AMSAC failure), ESFAS (ESFAS (RNP-F/PSA-0075). Two of the events fails) , CCVENT (performing CV purge), cited in this F&O are included as part of and GINRDOORSL (personnel hatch the Level 2 analysis (RNP-F/PSA-0046,
' door gasket). No evidence was found RNP-F/PSA-0047). This is a
. that these basic event values are not documentation issue only and is not a appropriate. technical issue. Therefore, it has no
.. impaclon the RITSTF. ~nitiative Sb i ' .
I * .. application . . ,, . .
~. ,
*; I *. ~
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- j. -*
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RNP-RA/18-0015 Page 13 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) LE-E1-1 LE-E1 1/11/111 The system level data are documented The latest revision of RNP-F/PSA-0047 in the Level 1 analysis and some Level (Revision 2) uses Section 8.3 to Internal 2-specific parameters are documented discuss at length the analysis used to Events in Attachment 2 of RNP-F/PSA-0047. produce the Level 2 values that are The basis for some of the values was summarized in Table 8-36. Literature subjective (e.g. , see Table 8-10) and references, MAAP runs, human others are based primarily on the IPE reliability analysis, and the use of submittal and supporting MAAP runs engineering judgement were applied to for the Level 2 analysis (e.g., Table 8- build the Level 2 values. This finding 35). Although it is understood that the determined that the SR LE-E1 is met, approach for estimating probabilities for but is left open asking to improve the some Level 2 parameters is soft, using documentation of sources and IPE results without additional traceability, as well as add to the
- --* --- jl.fstiflcaliori may not be as realistic as summary table a column briefly stating req ~ired for a CC 11 classification . the val.uas source or method of
,,c.::: :,>,*.1, .. ; determinat.ion . However, with the
- ; :. 'L , :.* '. .., r J :., ... _ calculatiort.disCJ.1ssin9 ,how each value,.
v ..:'< f' .,;*.:;<.:: ; ,,, . *, * ,:* .. . f .. '..has been r~aljs,tic-aUy qetermined and
! s::q ~ i ,i,., , ,,...,,_-,0 *. - 1* ,": ,.-, ,, :*,,. 1 :* . ,documented in Section 8.3,-th_e , 'i.., *' - ...
. *~* ;;:- ** -_-: ;.': . ! .: -:1 u:t.," , ; .. .. :.resulting PfantE:>amageStates -are
; ,**,-:ii, ?::,:* (Y' " - , c. __ credible find accurately support the lj_'.3 .P,,J:: , -.* : , , ! , *1 .. PRAmoqel'5,results.Therefore, this l , k *C::fi ;~ _e< '.<, , *\ .. , .. , , s .. documentation concern *has no effect
- ***' " : :, ,: Ji* , . ,. ,, on the RITSTF Initiative 5b application.
- \* / --: *:: .* *r,lr , _,;~~ -:, *. *,;. * *:
* (~:-:::* 1~ * :.1.. \. :.., , { , * * ,: I. i: ;, I ; '!i i
., I.
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.' ' -~
RNP-RA/18-0015 Page 14 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) LE-DS-1 LE-05 Not Met Based on a review of a number of
- 1) In response to this finding, the calculation files, SGTR event tree, and assumed number of SG PORV/SRV Internal fault tree for #RW, it appears that a cycles on the ruptured S/G ~as .
Events realistic secondary side isolation increased from 10 to 40. This value 1s capability analysis is performed. considered reasonable and is within the However, there are a number of range of cycles described in section important issues that their resolutions 2.3.3 of NUREG-1570. As such, this may impact this conclusion . These portion of the F&O is considered issues include addressed and has no impact the RITSTF Initiative Sb application . a) A justification for the assumed number of cycles for the PO RVs on the
- 2) A sensitivity study has been faulted SG (which is 10) is not performed to assess the impact of provided . Also , it seems t~at onl~ 'fail to adding a Human Failure Event (HFE) to close' of one SRV is considered in the the model for isolating the ruptured SG.
fault tree. The HFE was developed and dependency between it and the other b) Additionally, it appears that C?perator HFEs in the model has been assessed. action to isolate the faulted SG 1s not The s-ensitivity study revealed a included as a potential contributor to reduction in the*system importances the secondary side isolation failure (Fussell-Vesely (F-V) and Risk probability. Given that in the current Achievement Worth _(RAW)) for the model modeled systems of 1% to 4% for CDF. The majority of the systems saw a less
- 1) fail to isolate probability is d~mi_nated than 0.5% reduction in importance for by the probability of a PORV sticking speti; and * *- *..,.,
- LERF. The exceptions to this being the "1. : f ~ ;.,. !
- Engineered $ afeguards Actuation
RNP-RA/18-0015 Attachment 2 Page 15 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) LE-05-1 2) the SGTR IE is one of the highest System , which saw a slight increase in (Con~in_u~d) G9n!ri_ p_uJQr§ toJhe LERF figure of merit, importanca.(4% Jor E-V and 1% for it is important to ensure that the above RAW), a,:id the*C-Qntainment {~elation app~rent-issues are fully resolved. system, which ~aw a slight incre.ase in
- . *. ~,J~ t z: "1 *: .:':I!'.:~ : t *~ -*, ....- ... ' - ~ 1\
impoftanee (3% for .both F-V and
, ) * ' ,;!'. ,,-... , .( ( 1: 1f * ;' 1C' ,* ;,_.1 1_. .* ,::,_,
R/\W) .. $in~~ -the .ed.dition of the HFE t,as ~ rn inimalimpa~
! . _* , .~
, i . " ; * * ~ .. - .,
or:, . n,e .PRA ,moqel .results, the impact
! *~ ' ); on the RITSTf= Initiative Sb application J*
. ., - ,,,. ..:~ , 1.; .-.. . ,, 1, (__* :~*.) ** . . . . . ._ ... ;i*: i$ .miAirnal 9s well , and the differences i ~ ::* ., . i :,,, ...
,j _; : ~: .... . ..... ... 1..
ar~ .cQns.ic:t.ered .to be acceptable.
- V l . r
- _\ * "i - ;*'-.;. . .. - f j
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i t,~:! ! p~H (" Cf ::,tJ ~ ~t *,- , *-* -,(~. .I._ **
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RNP-RA/18-0015 Page 16 Finding Supporting Capability Description Disposition for RITSTF Initiative 5b Number Requirement(s) Category (CC) LE-C4-1 LE-C4 I The accident sequences are based on A sensitivity study has been performed generic references and on plant to assess the impact of adding a Internal specific MAAP analysis. Important Human Failure Event (HFE) to the Events mitigation actions in significant accident model for isolating the ruptured SG . progression sequences, such as SG The HFE was developed and isolation for SGTR are not modeled . dependency between it and the other Evidence of technical justification for HFEs in the model has been assessed . demonstrating the feasibility of The sensitivity study revealed a mitigating actions was not provided. reduction in the system importances Scrubbing is discussed for release (Fussell-Vesely (F-V) and Risk categories in RNP2-F/PSA-0048 and Achievement Worth (RAW)) for the brTef -ratforiale is provided-wtien it is . *modeled systems of 1% to 4% for CDF . credited. Inclusion of beneficial failures ..The majority of the systems saw a less was not observed . -than 0.5% reduction in importance for LERF. The exceptions to this being the Engineered Safeguards Actuati on System (ESFAS) , which saw a slight increase in importance (4% for F-V and 1% for RAW) , and the Containment
*Isolation system , which saw a slight
' increase in importance (3% for both F-V and RAW) . Since the addition of the HfE has a minimal impact on the PRA model results, the impact on the
- ' RIJSTF Initiative Sb application is
' minimal as well, and the differences are considered to be acceptable.
RNP-RA/18-0015 Attachment 2 Page 17 Finding Supporting Capabil ity Description Disposition for RITSTF Initiative 5b Number Requirement(s) Category (CC) LE-C4-1 Level 2 operator actions were (Continued) assessed in more detail using industry-standard methodologies via the EPRI HRA calculator,-ir,icluding assessment i of feasibil ity due to post-accident .. env*ronmental conditions. The SI I System Engineer and the HBRSEP2 MOV Program engineer were consulted I to determine .the *maxjmum differential pressure against which the RWST OutletM0Vs-.(SJ-864A and .B) could be manually,clc::>sed during an ISLOCA . event and it was-determined that their I closure is feas~.bl~. Based on the more d~tailed .assessment of these Level 2 HFEs, th[s portion of the F&O has been
; ;**1:_; 'L: r . *: ,.. ,,. r,. - addressed in the RRA ar:id .does not
" ,**}**'! .-.... ,, .. ... ,*
' . ' " impact.the RITSTF:..l nitiative Sb ..
I I ; ... ; : ,*;~ ;_ ':'. '; * ') .;I
! .. - ..," T"*.._ .aoolication .
"i '--, > 1 i.
'. "* 'f,f*J '1.)* *_ ... ! ',, ***:* *,.' *.. , *'-*.**
- l( ' ~~ \ * ' ,
_: ~* '. : -.,
RNP-RA/18-0015 Page 18 Finding Supporting Capability Description Disposition for RITSTF Initiative 5b Number Requirement(s) Category (CC) QU-D4-1 QU-D4 11/!I I RNP-F/PSA-0077 Section 3.4, Similar With Capability Category II - Ill for QU-Plant Review, Table 7 shows a D4 not met, the results from the Model Internal *comparison of Robinson CDF and of Record are still valid and Events LERF values to Turkey Point and have been compared to two similar Beaver Valley. Plant systems plants with their final results being differences. are compared . However, within an order of magnitude of each the comparison is inadequate and , other. Robinson PRA alsQ contains
. sources of specific differences (e.g ., documentation that compares the LOCA contribution) are not identified.
plants in terms of system and plant capability differences. As i 'I l._; -:, * .. .. J ,I ~* recommended by the finding , Beaver
' .... ._ . ~-*
-:_ \. .*- \ . ' } .-
Valley's CDF contributions we.re .
- .. . .'~ . . ,, .,
compared to that of Robinson's. LOCA,
'I I I SGTR, and Loss of Service Water contributions to CDF are nea*rly the same between the two plants, noting that the overall CDF values are_within 1E-6 of. each other. Steam Generator
' ' Tube Rupture, Internal Flood , and Loss of Offsite Power cqntributions to LERF have similar ratios for both plants.
Other contributions, such as a reactor trip and loss of f~edwater, were more different between the two plants, but not enough to warrant any concern of
. the validity of Robinson's model.
Therefore, this documentation concern
- ,. I "' -, **
of comparing models has no effect on
. the RITSTF lnit:e!ive Sb aoo:ication .
. . -*} . i: .*
RNP-RA/18-0015 Page 19 Table 2: Disposition and Resolution of Open Internal Flood Peer Review Findings Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Require_ment(~) (?~teg~_ry_(C~) . _ _ ___ ___ ____ _ ___ .. __ ___ **-** ,* .. _ .. _ _-;- . . . . __
- ~-
IFEV-A7-1 IFEV-A7 1/11 *Human-induced flood events are
- considered as potential flood sources The,sen$itiv1ty study perf~rrned Was *;:,
Internal .but all such events are screened with ove-rly qor,seryativ.e and a.ttemp_ te"cf to - Flood potentially non-conservative screening . ap' p ly.:ai\..iridu~try );iuL man indUC~. d, failurEr _e~e~i s .Q~_~ per pipir.1g . .. . *
- r he following issues were identified: f r~uen.cy. This led to a largE!ly ov~r (a) Of the 160 generic human-induced .conservative..value. H*un;ian induced event identified as significant flqo~liiig ev~rit.s. a*r~ not ri~k "sigr,i~cant operational events involving foYfhi.s appli~~tion .as. ori the whole inadvertent or accidental release of h~'maci induc~~ flo_odir,g ev~nts i_n ,the
~ignificant quantities of process lndusJry h~ve larg~ly bt:eri occLfrrinQ .
medium outside the plant containment !ess often . This. evi.dent. by analyzir:,g structure can be defined for the the industry_q,ata 6n maintenance-industry, only 50 were included as inauce.d floc;>dJng, events which spans related to human errors in maintenance a tirneffame from 1971 to 2011. The resulting in flooding. It is not clear that Va. s t rrtajority
* ,\ * ** * ., ,, I..
of.the event$. occurred in the other 110 events were properly th~__197,0p aqd 1980s _with !?ig_nificantly"
~creened out (e.g. , is spurious fire fewer ev~nt~.occur'ring in ~he 1990s suppression operation considered and 2000,s. This tr~nd can be I * +, ?, attrµJuted.to fewer infant mortality
\11.ai~.!.e~ ~~t t I ,.__ , _ . .
~<"A*n , .-. ...
* -'* t .: * *.-' '
* : . '* .- ,. i
- i )( .... * ....... ,.,, .;.. . . 1* **- * : * ** ;* issues as .the _plants age and ..
(b~'J~~:~r;,~ntt ~ _ ~(e 11e~~LTlr-~- only__oy im~roved 'maintenance practices.
?~r~,~~i~~~ -~Y$t~-~ *-w,tr/i~~ . _ ;, .- ThW~f9re, riot i_nclOqil:lg) fi~m - . .
1d~nJ1!feaf1o_n Qf,s ize,* dU!pt1on 1 _cause, ~l?e~!ri9~II)'. _in ,t_t,e l,f P~A model would etd: 'ttfaifwould allo'w'these 'events to be not qffect results in a manner that us~o tb re"pr~~~nt-~-p~cific,flood - y.,ouicf'i mpact the . ' ~- . . '
'. sc~~aHas-*'
- l * .. .. ,- * *-* .. *.
0 RIT.STF Initiative 5. b application . t I '. 1
't-L ~,'\j .._-* *a* ~- ' i ,~1 ~** :..,. ,.'* \'- ;, *- '
-- .. * ... ~ .... ~ ,. ... "' * **..:. - ~ -< * - -
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- J *v
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RNP-RA/18-0015 Page 20 Finding Supporting Capability Description Disposition for RITSTF Initiative 5b Number Requirement(s) Category (CC) IFEV-A7-1 (c) The frequencies were apportioned (continued) by linear pipe length per flood area, but it is not clear that human induced flood frequency is proportional to pipe length. Sp~cific~lly, ~u_cb. flg_qds in fire -* *- Protection systems is likely to be
- inadvertent actuation of fi re* systems, which can only occur in areas-with * -
- sprinkler systems .
(d) -Human-induced flood frequencies are sereened out if they are considered I small contributors, i.e., less that the total system* flood frequency based*on random p1pe b reak frequencies. Since
.' 'this could double the freq uencies, it*is not clear that screening is appropriate.
Subsuming (adding t he frequencies *
- and modeling with bounding impacts)
, would be more appropriate. "
,I *
... # ,I I **I; i.. ,. t -, ....: : "":.. ! **
._ r \), . r,.,...'
. -' ... . .~ )'.
** *,Ji .....
-- ' . .. *.i
RNP-RA/18-0015 Page 21 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) IFEV-A7-1 (e) For Human-induced floods with (continued) frequencies larger than the corresponding system's random pipe break frequency, all the floods were screened out qualitatively, with justification such as "at-power maintenance is not expected in this internal flood zone, and consequentially, human errors in _ . rnaLIJ~~_n§JlC:~.r~~J,J lting in flooding in this ..*
~nternal flood zone are not postulated".
H*owe\ter; these e'Vents;apparently
.occurreel -iri ;t~ generfc database. **
- U-nless-Robrn's6n*t3ah identify' ttesign or operafional,diffefences*that make"-the generiorctata n*o t,applicable, ,the.generic tlattfshourcl-t,e)use: At ,1east, for the h,ost:impGriarii!ti"Ufnal'l-inaubed *flood '
events {-h~flle'stff.reqtiencie§.-* systems wiU'i-ttle-'gfeatesfr1sk~impact), such events:sf'10Uld 1oe*:ex-plic:itty m:odeted .. lvith the corresponding flood mitigation 13ttioh!{ cfi-solateHhe flood (expected to be,more-reliable than 'for random*pipe breaR'events}! {Tt-iis F&O or4ginated * - from.SRIFEV1.AY~ * , :. *
. :..-- ,; ) t\ l ... -. ., ,..
**.* ; . , ) . ' ; ~ ..
... . *. .. . }
*, ,,..; . . - -~ - l
RNP-RA/18-0015 Page 22 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) IFSN-A12-1 IFSN-A12 1/11/111 Flood area screening is performed in It is acknowledged that the HBRSEP2 Section 5.0. The qualitative screening documented process for internal Internal process is described in Figure 11. The flooding area screening is lacking in Flood flood events are potentially modeled detail. Based on the description of the with an assumed reactor trip (manual finding and the recommended or automatic) where this may be overly resolution this is a documentation conservative. Also, it is not clear how issue that may be addressed by the screening criteria define a flood calculation revision to better detail event that would not require an and clarify the process of screening.
- - .. ... .. _ immediate plant shutdown. This may This supporting requi~ement ~a~
' be especially true for spray events assessed as being MET. Although a where the flood can be managed better presentation for the screening without tripping the plant. process of internal flooding areas at I
HBRSEP2 would more clearly satisfy the requirements of IFSN-A12 there jis , negligible impact on the quantified
- values for CDF or LERF and therefore .
, no impact on the RITSTF Initiative Sb application .* -
~ '"' ..
* .:,:*'
- I
' '.; Ii 1, * *"": (* -*. ::_. :;.
*~ . -
. , 1
-1=:*.:. ,*
RNP-RA/18-0015 Page 23 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) IFSN-A8-1 IFSN-A8 Use of EPRI door failure criteria of 1ft / Door failure height was evaluated and 3ft may not be appropriate depending found to be acceptable for the current Internal on the actual door attributes and IFPRA. The current IFPRA Flood flooding scenario. assumes that the majority of the components would fail at or around 1 ft to 3 ft, which are the current door failure heights used. As this was the failure height used varying the minimum door failure height to something greater than 1 foot or 3 feet would not impact the IFPRA in a meaningful manner. Therefore this .
- open F&O *is not expected to impact the risK results. *,. - "*' .
. The*,flood propagation-and estimated i door heig ht'failure**effects of this- open
' , F&Q.are min1mal' onmodelihg' results
,an8'lh'erefore will have no' impatt-or:i the* ~ua'ntifi~d*values with regard to
. -* .*, ' .. tlie RITSTF Initiative 5b appiication :
** L
. ,. ..: -~ ~ **. . . -:,.
I * , -::::" , * * : ...:: ,~I \ * ~ * ' : .~ ..... I ' l , * '; 1
- j
* ~ ** I ; , *
- t:: . ./! *~ * . I ' ,*. } 1 : .i **~-: ~ . .. --:j~ .: : !~; :. . ~ -~; i
,. ,,, **- ,.. .., ?111'( ._ * ***.,_ , _ _oc * , , , . _ _ , . . . , . . , .. _ . . , . . 'J * - - "' * -* .,. - . . . . ... "'"
*' * ~ t
- J * ...__ :. * * '
~ I'
RNP-RA/18-0015 Page 24 Finding Supporting Capability Description Disposition for RITSTF Initiative 5b Number Requirement(s) Category (CC) IFSN-AB-2 IFSN-A8 I Flood propagation via door gaps is Flow under door gaps was evaluated assumed to be minimal and handled by for applicable flood areas. Door gaps Internal the floor drain system. The potential for exist in a select number of flood areas Flood propagation via door gap flows should b!,Jt theseflqod area~ are not risk be addressed -in ttie flooding scenarios. significant with the exception of one flood area. This flood area is adjacent to other areas that are of limited floor area and the scenario fails equipment a low critical height. Therefore flow underneath door gaps would be limited due to the limiting ability for the flood to develop any sort of significant hydrostatic head. Crediting flow underneath door gaps would increase
, the time that operators would be able to potentially isolate the scenario.
Therefore as it is currently modeled, scenarios for this flood area are conservative but modeled in manner
; .. (. '. .~ .. consistent with CC II IFPRA modeling.
- The timing effects of this open F&O is
. . minima*1on modeling results and
. ~* . therefore will have no impact on the
..' quantified values with regard to the
. RITSTF Initiative Sb application .
'l
*~ ..,
.. . ~
. *~
RNP-RA/18-0015 Page 25 Table 3: Disposition and Resolution of Open Fire Peer Review Findings Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) CS-C1-01 CS-C1 Not Met There is no notebook encompassing This is a documentation only issue. Task 3 (Cable Selection) making Fire review and update difficult. There are Cable selection and circuit analysis numerous change packages, and a data ~rEE d~yeloped_Jmd maintairi~d .
- dafabas-e {FSSPMD) which is *a :by the Fire Protection/NSCA team at repository for the cable routing ,Hf3RSEP2, Th*s data isthen
- information; however, there is not a , -r.eferenced:.as ~nputs to -the
- single document which compiles the *Component; Se1eotion*and -
tasks performed, procedures followed : Quantification FPRAcalculatibr:is.
- or guidelines employed. 1-his*proGess *an.d ~associated results are easity reviewable, *has'been peer reviewed multiple times for-our other siteS-and*foundio be acceptable.
There is no requitemeRt to have a separ-ate 'PRA notebook. However, adding references -to current '*- -- documentation* regarding circuit an'alysis-peffbrmance (ex. prd'cedure) would *provide.the*necessary documentation linkage between the proces's and ttie end .results (FSSPMD) : - ' There,1s no impact on the.RITSTF *
,. .. }
.. -
- J *- ~ .,r l~*** . ' lnftiative Sb*application .
~. ~.. .
~.. {* h, ** J' ..
- I.:: : o
- t I * ': '* * * ;, ~ ~' .. .. , ..,
~ .. . .*, **
RNP-RA/18-001S Page 26 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) FQ-F1-01 FQ-F1 1/11/111 The contents of the elements of This is a documentation only issue. applicable SRs of Part 2 were Fire addressed in the FQ and associated The HBRSEP2 Fire PRA was documents; however, no explicit developed using the Internal Events connections were established in the PRA as an input. Therefore, the
. *------ d_ ocuments to associate with the "back- "back-references" associated with -
.references" requirements LE-G2, LE- requ irements LE-G2, LEG4 ~nd LE~
G4 and LE-GS GS are considered to be met. j I ~_. There is no impact on .the RI.T STF i .' ~ - ' Initiative* Sb application . *
*I
.. I
*... f * : ~
I * ,r" " ,q
- I -* *-'
~_. . ... . ..
i! ~-- l * ._! j _;!; , *1* !* i*,.~
!,\\!~. :.:(... '.:...:. ... :*-* .. .:
- .1.-.' t *....,
\.,." ' .. ' - : ~-. *;, .;*
* -*' I
.. *, , ~> . "' *' '
RNP-RA/18-0015 Page 27 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) FSS-D7-01 FSS-D7 Not Met There is a failure to meet the Category Recent review of calculations and I requirement of having systems data support the following: Fire installed and maintained in accordance with applicable codes and standards.
- As shown in the NFPA 805 code The Main Turbine Lube Oil Deluge compliance evaluations, the credited system must be replaced to account for suppression and detection systems system deficiencies identified in NCR- are installed and maintained in 425437 where a simultaneous accordance with applicable codes and actuation of the Turbine Lube Oil standards.
suppression system , along with the mezzanine and ground level sprinkler
- Based on preliminary NFPA systems, could place a higher system monitoring and maintenance rule data demand on the water supply than can unavailability and unreliability of be provided by a single fire pump. This significant suppression and detection was not identified, nor is a comparison systems are green, indicating no provided in the Fire PRA of all installed operational issues of concern or detection and suppression systems vs. outlier behavior on those systems.
the corresponding Code Compliance This insight is further supported by a calculation . Review plant-specific separate study of suppression and
-*-, lnforrnation,_and ens.u re thatthe use.oL detection -systems which show 1
generic data from NUREG/CR-6850 is minfrrial failures for these systems reasonable for use in the HBRSEP2 ov~r the past few years. . '
. Fire PRA. :
- "? - ')!.;~* 1- ;-- *~~ ;_.
- Therefore, there is no impact on the RITSTF Initiative Sb application.
~
1
- RNP-RA/18-0015 Page 28 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC)
FSS-D7-03 FSS-D7 Not Met Evidence needs to be provided to Recent review of calculations and support that credited data support the following : Fire detection/suppressions systems are installed and maintained in accordance
- As shown in the NFPA 805 code with applicable codes and standards. compliance evaluations, the credited System health report for period 02- suppression and detection systems 2013 for systems are installed and maintained in 6185/6181/6175/6195/6205/6180 notes accordance with applicable codes and that age, obsolescence and standards.
replacement part procurement is an issue for multiple fire protection
- Based on preliminary NFPA systems. This system health report also monitoring and maintenance rule data notes that "There are LTA Ms budgeted unavailability and unreliability of for 2014 and 2015 which study and significant suppression and detection replace the detection, CO2, and Halon systems are green, indicating no Systems." This report suggests that operational issues of concern or sp me of theJire protection syst~.rns at outlier betiavior on those systems.
HBRSEP2 may be experiencing outlier This insight is further supported by a
*behavior relative to system , separate study of suppression and unava*ilabiHty and may not be in a fully detection systems which show opera b1e 'state during plant operation minimal failures for these systems over the past few years.
- . Therefore, there is no impact on the RITSTF Initiative Sb application .
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RNP-RA/18-0015 Page 29 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) FS5-E1-01 FSS-E1 1/11/111 Section 4.3 of Calculation No. P2217- This is a documentation only issue. 2100-00, Fire Scenario Data, RNP- No issues are identified with the Fire F/PSA-0079, Revision 0, dated modeling parameters that were used. January 2013 contains information Therefore there is no impact on the about fire modeling parameters that RITSTF lnitiafive Sb application. __ _ ----*-* --~~r~ !:!_~e_d_.JjoweyerJ S~ctiqn 4.4 through 4.7 should be completed because they are missing information about other relevant fire modeling parameters. Sections 4.3 through 4.7 stilt:make reference-to databases for-the'..paramet~rs used 'in the ,fire * ,i modeling... i:hese parameters should be added to_t-Ae repmt * *,~., ' *,. I ';l *J.; J : *,* ~; ** , : *; * ,1 ,.,
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RNP-RA/18-0015 Page 30 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) FS5-E3-01 FSS-E3 I No statistical representation of HBRSEP2 used the HRRs and uncertainty intervals (e.g., NUREG/CR- applied them using the guidance Fire 6850 Table E-1 or G-1 for HRR, Tables found in NUREG/CR- 6850. As E-2 through E-9 for severity factor) is NUREG/CR-6850 is the consensus documented for the mean values of methodology, a detailed uncertainty parameter estimates used for fire analysis on these parameters is not modeling the significant fire scenarios. needed and does not add to the credibility of the results. The majority of applied values are based on the 98th and 75th percentile fir~s from NUREG/CR- 6850, and the ZOls are applied conservatively. It is not believed that reducing these values would allow the use of reduced impacts for the applications being pursued. Although no change has yet been made that would improve the Capability Category assessments; HBRSEP2 considers the risk res ults from the Fire PRA to be creditable for this application because documenting the statistical representation of uncertainty intervals will not change the quantified risk metrics. There is no impact on the RITSTF Initiative 5b aoolication . to RNP-RA/18-0015 ATIApHMENT3
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~li~ense Ariiendmeh_t Request, H.B, Robin~on Ste~nj' Electric Pla1(' Unit No. "2 (HBRSE,P) _.
.Docket No. 50:261
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Application for Technicaf Spe~ifjcation 'Ctiange Regarding Risk-lnfonned Justification for the Relocation .~f Spe~_ifi~ Suryeill~nce Frequ~n~y Requirements to a Lic~nsee Controlted Pr_ ogram,{Adopti-on, Q, TSTF-:425, Re'vi$,i on 3) '* . *
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Proposed Technical s*pecification- )
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Robinson Technical Specification Inserts for TSTF-425, Revision 3 Insert 1 In accordance with the Surveillance Frequency Control Program Insert 2 5.5.18 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.
- a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.
- b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.
- c. The provisions of Surveillance Requirements 3.0.2 and 3.0. 3 are applicable to the Frequencies established in the Surveillance Frequency Control Program .
Definitions 1.1 1.1 Definitions SHUTDOWN MARGIN a. All rod cluster control assemblies (RCCAs) are (continued) * ':
- fully ins'erted except for the single RCCA of highest reactivity worth , which is assumed to be fully withdrawn .
W ith any RCCA not capable of being fully inserted , the reactivitY, worth of the RCCA must be accounted for in the determination of SOM ; and - *
- b. , In MODES 1 and 2, tt,ie fuel arid moderator
_., te~peratur7? are changed .to the 547°F . . SLAVE RELAY TEST A SLAVE RELAY TEST shall con.sist of e*nergizlng each sla.v~ r.elay and verifyin~ the OPER_A BILITY of each slave relay. The SLAVE RELAY TEST shall include, as a t.' minimum , a continuity ch'eick' of' associated .testable actuation devices. * ; :: ,-. -
- STAGGERED ,lEST BASIS *..:* ,A S:PAGGERfiDTEST 8.A.SIS 1shall'c0nsist of the testing of
* , 11: . *, , ; , . . .one. of:the sys.tems, s.uesystems, chann~ls, or other
*, .. c;lesjgnated. po_ mpononts.~d.ur.ing t_hQ int.orval specified by the Surveillance rrequency, so that all systems, subsystems,
*
- _, ,. . , ... ;
- 1, , .J ~- .~cl~fil~,l.s ~o_r,othE\)f, ~es_ ig2atf?p_.c.9 ~p9r9nts are .tested during
, .* . .*, .. , .. . .. -_ . .() _Surv,eil[,Hipe Frqql,lqncy jot9rv~ls, where fl is the total
' -1 , .,.,, .: .. t. .: .. - tiu'fr1b6r..of syst~ms,' s*uiJ'syslei°fnE( 16 ti1nnels, or other designated components in the assodrateid' function .
THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant. TRIP ACTUATING DEVICE A T ADOT shall consist of operating the trip OPERATIONAL TEST actuating device and verifying the OPERABILITY of (TADOT) required alarm , interlock, display, and trip functions . The T ADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the required accuracy. HBRSEP Unit No. 2 1.1-5 Amendment No. ~
SOM 3.1.1 3.1 REACTIVITY CONTROL SYSTEMS 3.1 .1 SHUTDOWN MARGIN (SOM) LCO 3.1.1 SOM shall be within the limits provided in the COLR. APPLICABILITY: MODE 2 with kett < 1.0, MODES 3, 4 , and 5. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. SOM not within limit. A.1 Initiate boration to 15 minutes restore SOM to within limit. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify SOM is within the limits provided in the COLR INSERT 1 HBRSEP Unit No. 2 3.1-1 Amendment No. 47e
Core Reactivity 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 -----------------------------N OT E----------------------------- T he predicted reactivity values may be adjusted (normalized) to correspond to the measured core reactivity prior to exceeding a fuel burnup of 60 effective full power days (EFPD) after each fuel loading . Verify measured core reactivity is within +/- 1% .llk/k of Once prior to predicted values. entering MODE 1 after each refueling
--------NOTE--------
0 n ly required after 60 EFPD i" INSERT 1 HBRSEP Unit No. 2 3.1-3 Amendment No. 47e
Rod Group Alignment Limits 3.1.4 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time of Condition B not met. D. More than one rod not D.1.1 Verify SOM is within 1 hour within alignment limit. the limits provided in the COLR. OR D.1.2 Initiate boration to 1 hour restore required SOM to within limit. AND D.2 Be in MODE 3. 6 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify individual rod positions within 12 hours alignment limit. ~.-IN_S_E_R_T_1_, AND Once withi hours and every 4 hours thereafter when the rod position deviation monitor is inoperable (continued) HBRSEP Unit No. 2 3.1-8 Amendment No. 47e
Rod Group Alignment Lim its 3.1.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.2 Verify rod freedom of movement (trippability) Q2 days by moving each rod not fully inserted in the
~
core 2: 10 steps in either direction.
!INSERT 1 I SR 3.1.4.3 Verify rod drop time of each rod , from the Prior to reactor criticality after fully withdrawn position , is ~ 1.8 seconds each removal of the reactor from the beginning of decay of stationary head gripper coil voltage to dashpot entry, with :
- a. T avg 2: 540°F ; and
- b. All reactor coolant pumps operating .
HBRSEP Unit No. 2 3.1-9 Amendment No. 4-+e
Shutdown Bank Insertion Limits 3.1.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify each shutdown bank is within the limits specified in the COLR. INSERT 1 HBRSEP Unit No. 2 3.1-11 Amendment No. 4+e
Control Bank Insertion Limits 3.1.6 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE . .. . FEQUENCY SR 3.1 .6.2 Verify each control bank insertion is within the limits specified in the COLR. Once wit and --4...JC.l~~ thereafter when the rod insertion limit monitor is inoperable SR 3.1.6.3 Verify sequence and overlap limits specified in the 12 hours COLR are met for control banks not fully withdrawn from the core. pri;'ERT 1 I HBRSEP Unit No. 2 3.1-14 Amendment No. 4+e
PHYSICS TESTS Exceptions - MODE 2
- 3. 1.8 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME C. RCS lowest loop average C. 1 Restore RCS lowest 15 minutes temperature not within loop average limit. temperature to within limit.
D. Required Action and D.1 Be in MODE 3. 15 minutes associated Completion Time of Condition C not met. SURVEILLANCE REQUIREMENTS
,SURVEILLANCE FREQUENCY SR 3.1.8.1 Perform a CHANNEL OPERATIONAL TEST on Within 7 days prior power range and intermediate range channels per to initiation of SR 3.3.1.7, SR 3.3.1.8, and Table 3.3.1-1. PHYSICS TESTS SR 3.1.8.2 Verify the RCS lowest loop average temperature is 2!53.0°F.
SR 3.1.8.3 Verify THERMAL POWER is~ 5% RTP . SR 3.1.8.4 Verify SOM is within the limits provided in the COLR. 24 hours HBRSEP Unit No. 2 3.1-21 Amendment No. 47e
F0 (Z) 3.2 .1 SURVEILLANCE REQUIREMENTS
.---------------------------------------------N OT E-----------------------------------------------------------
0 u ring power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved , at which a power distribution map is obtained . SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify F~(Z) is within limit. Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 12 hours after achieving equilibrium conditions after exceeding , by
~ 10% RTP, the THERMAL POWER at which F~(Z) was last verified
!INSERT 1 HBRSEP Unit No. 2 3.2-3 Amendment No. 476
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 -----------------------------N OT E-------------------------------- 1f F~ H is within limits and measurements indicate that F~H is increasing with exposure then :
- a. Increase F6 (Z) by a factor of 1.02 and reverify F6 (Z) is within limits; or
- b. Perform SR 3.2 .1.1 and SR 3.2 .3.3 once per 7 EFPD until two successive measurements indicate F~H is not increasing.
Verify F~H is within limits specified in the COLR. Once after each refueling prior to THERMAL POWER exceeding 75% RTP 31 EF"PD +-(--IINSERT 1 thereafter HBRSEP Unit No. 2 3.2-6 Amendment No. 4+e
AFD 3.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify AFD is within limits for each OPERABLE ?days ~ excore channel. SR 3.2 .3.2 --------------------------NOTE------------------------------- Ass um e logged values of AFD exist during the preceding time interval.
-----NOTE------
Verify AFD is within limits and log AFD for each Only required to be OPERABLE excore channel. performed if AFD monitor alarm is inoperable Once within 15 minutes and every 15 minutes thereafter when THERMAL POWER
~ 90% RTP or 0.9 APL, whichever is less AND Once within 1 hour and every 1 hour thereafter when THERMAL POWER
< 90% RTP or 0.9 APL, whichever is less (continued)
HBRSEP Unit No. 2 3.2-10 Amendment No. 4+e
AFD 3.2.3 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.2.3.3 --------------------------------NOTE------------------------------
- 1. The initial target flux difference after each refueling may be determined from design predictions.
- 2. The target flux difference shall be determined in conjunction with the measurement of F 0 (Z) in accordance with SR 3.2.1.1.
Determine, by measurement, the target flux Once within difference of each OPERABLE excore channel. 31 EFPD after each refueling 31 ErPD thereafter INSERT 1 HBRSEP Unit No. 2 3.2-11 Amendment No. 47e
QPTR 3.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.4.1 ---------------------------N()TES--------------------------------
- 1. With input from one Power Range Neutron Flux channel inoperable and THERMAL P()WER < 75% RTP, the remaining three power range channels can be used for calculating QPTR.
- 2. SR 3.2.4.2 may be performed in lieu of this Surveillance.
Verify QPTR is within limit by calculation . 7 days INSERT 1 hours an 'eveflf 12 hours thereafter with the QPTR alarm inoperable. SR 3.2.4.2 ----------------------------N ()TE-------------------------------- Not required to be performed until 12 hours after input from one or more Power Range Neutron Flux channels are inoperable with THERMAL P()WER
;:;: 75% RTP .
Verify QPTR is within limit using the movable incore ()nee within detectors. 12 hours fil:!Q 12 hours~pNSERT 1 thereafter
- HBRSEP Unit No. 2 3.2-14 Amendment No. 47e
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS
N OT E-----------------------------------------------------------
Refer to Table 3.3.1-1 to determine which SRs apply for each RPS Function . SURVEILLANCE FREQUENCY SR 3.3.1.1 Perform CHANNEL CHECK. SR 3.3.1 .2 -----------------------------NOTES------------------------------
- 1. Adjust NIS channel if absolute difference is
> 2% .
- 2. Not required te be performed until 12 hours after THERMAL POWER is~ 15% RTP.
Compare results of calorimetric heat balance 24 hours calculation to Nuclear Instrumentation System (NIS) channel output. im:sERT 1 SR 3.3.1.3 -------------------NOTES-------------------
- 1. Adjust NIS channel if absolute difference is
~3%.
- 2. ' Not required to be performed until 36 hours after THERMAL POWER is~ 15% RTP.
Compare results of the incore detector 31 effective full measurements to NIS AFD . po1.+.<er days (EFPD) < !INSERT 1 (continued) HBRSEP Unit No. 2 3.3-8 Amendment No. 47e
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.1.4 ---------------------------NOTE---------------------------------- T his Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service. Perform TADOT. 31 days on a STAGGERED~ TEST BASIS SR 3.3.1.5 ----------------------------NOTE--------------------------------- Not required to be performed for the logic inputs from Source Range Neutron Flux detector prior to entering MODE 3 from MODE 2 until 4 hours after entry into MODE 3. Perform ACTUATION LOGIC TEST. 31 days on a Sl;AGGEREDtjlNSERT 1 TEST BASIS SR 3.3.1.6 --- .------------------------NOTE--------------------------------- N ot required to be performed until 24 hours after THERMAL POWER is~ 50% RTP. Calibrate, excore channels to agree with incore Q2 EFPD < ~INSERT 1 detector measurements. SR 3.3.1.7 -----------------------------NOTE-------------------------------- N ot required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 4 hours after entry into MODE 3. Perform COT. 92 days ~<--;JINSERT 1 (continued) HBRSEP Unit No. 2 3.3-9 Amendment No. 416
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.1.8 -----------------------------NOTE-------------------------------- T his Surveillance shall include verification that interlocks P-6 and P-10 are in their requ ired state for existing unit conditions. Perform COT. -----NOTE----- Only required when not the Frequency specified in the performed within Surveillance Frequency Control -----,.r_::: ~ pre11ious Q2 days Program Prior to reactor startup Four hours after reducing power below P-1 O for power and intermediate instrumentation Four hours after reducing power below P-6 for source range instrumentation Every Q2 days r thereafter ~,£..._-,4INSERT 1 (continued) HBRSEP Unit No. 2 3.3-10 Amendment No. 4+e
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.1.9 ------------------------------NOTE------------------------------- Ve rification of setpoint is not required . Perform TADOT. Q2days ~ SR 3.3.1.10 -----...-------------------------NOTE------------------------------ T his Surveillance shall include verification that the time constants are adjusted to the prescribed values where applicable. Perform CHANNEL CALIBRATION . 18 months tjNSERT 1 SR 3.3.1.11 -------------------------------NOTE------------------------------ Neutron detectors are excluded from CHANNEL CALIBRATION. Perform CHANNEL CALIBRATION . 18months ~ SR 3.3.1.12 -------------------------------NOTE------------------------------
. This Surveillance shall include verification that the electronic dynamic compensation time constants are set at the required values, and verification of RTD response time constants.
Perform CHANNEL CALIBRATION . 18months ~ SR 3.3.1.13 Perform COT. 18months ~ (continued) HBRSEP Unit No. 2 3.3-11 Amendment No. 4-7e
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.1 .14 ------------------------------NOTE------------------------------ Ve ri fi cation of setpoint is not required . Perform TADOT. 18months ~ SR 3.3.1.15 ------------------------------NOTE------------------------------ -------NOTE-------- Verification of setpoint is not required . Only required when not performed within previous 31 days Perform TADOT. Prior to reactor startup HBRSEP Unit No. 2 3.3-12 Amendment No. 4+e
ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS
NOTES-------------------------------------------------------------
- 1. Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function .
- 2. When a channel or train is placed in an inoperable status solely for the performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours provided the redundant train is OPERABLE.
SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK. 12 hours ~ -{INS ERT 1 SR 3.3.2.2 Perform ACTUATION LOGIC TEST . 31 days on a S+,A,GGeReQ t j NSERT 1
+ eS+ BASIS SR 3.3.2.3 Perform MASTER RELAY TEST. 18 months ( 11 NSERT 1 SR 3.3.2.4 Perform COT. Q2 days < IINS ERT 1 I SR 3.3.2.5 Perform SLAVE RELAY TEST . 18 months < 11 NSERT 1 SR 3.3.2.6 ---------------------------NOTE-----------------------------
Verification of setpoint not required for manual initiation functions. Perform TADOT. 18 months < 11 NSERT 1 SR 3.3.2.7 Perform CHANNEL CALIBRATION . 18 months IN HBRSEP Unit No. 2 3.3-24 Amendment No. 47e
PAM Instrumentation 3.3.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME G. As required by Required G.1 Initiate action in Immediately Action E.1 and referenced accordance with in Table 3.3.3-1. Specification 5.6.6 . SURVEILLANCE REQUIREMENTS
NOTE-----------------------------------------------------------
SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3 .3-1 ; except Functions 9, 22 , 23 , and 24. SR 3.3.3.3 applies only to Functions 9, 22, 23 , and 24 . SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required instrumentation channel that is normally energized . SR 3.3.3.2 ----------------------------N OT E------------------------------- 18months~ Ne utro n detectors are excluded from CHANNEL CALIBRATION . Perform CHANNEL CALIBRATION . SR 3.3.3.3 ----------------------------NOTE------------------------------ Ve rifi cation of setpoint not required . 18 months ~NSERT 1 Perform T ADOT. HBRSEP Unit No. 2 3.3-31 Amendment No. ~
Remote Shutdown System 3.3.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.4.1 Perform CHANNEL CHECK for each required 31 days ~<:___.i:;.PN"'S~E-R_T_1__, instrumentation channel that is normally energized. SR 3.3.4.2 Verify each required control circuit and transfer 18 months~ switch is capable of performing the intended function. SR 3.3.4.3 ----------------------------N()TE--------------------------------- Neutron detectors are excluded from CHANNEL CALIBRATl()N . Perform CHANNEL CALIBRATl()N for each required 18 months +-<-...,..jlNSERT 1 instrumentation channel. SR 3.3.4.4 Perform TAD()T of the reactor trip 18 months < jiNSERT 1 breaker open/closed indication. HBRSEP Unit No. 2 3.3-34 Amendment No. 47e
LOP DG Start Instrumentation 3.3.5 ACTIONS CONTINUED (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and 0 .1 Enter applicable Immediately associated Completion Condition(s) and Time not met. Required Action(s) for the associated DG made inoperable by LOP DG start instrumentation. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 -----------------------------NOTE----------------------------- Ve rifi cation of setpoint not required . Perform TADOT . 18months ~ SR 3.3.5.2 Perform CHANNEL CALIBRATION with Trip 18months~ Setpoints as follows:
- a. Loss of voltage Trip Setpoint of 328 V +/- 10%
with a time delay of ::S:1 second (at zero voltage) .
- b. Degraded voltage Trip Setpoint of 430 V +/- 4 V with a time delay of 10 +/- 0.5 seconds.
HBRSEP Unit No. 2 3.3-36 Amendment No. 47e
Containment Ventilation Isolation Instrumentation 3.3.6 SURVEILLANCE REQUIREMENTS
N()TE--------------------------------------------------------------
Refer to Table 3.3.6-1 to determine which SRs apply for each Containment Ventilation Isolation Function. SURVEILLANCE FREQUENCY SR 3.3.6.1 Perform CHANNEL CHECK. 1~ RSl:IFS NSE SR 3.3.6.2 Perform ACTUATl()N L()GIC TEST. 31 days en a STAGGEREDt j l NSERT 1 TEST BASIS SR 3.3.6.3 Perform MASTER RELAY TEST. 18 mentl=ls IN SR 3.3.6.4 Perform C()T. Q~ days INSE SR 3.3.6.5 Perform SLAVE RELAY TEST. 18 mentl=ls INS SR 3.3.6.6 ----------------------------N ()TE------------------- ,------------ Verification of setpoint is not required . Perform TAD()T. 18 mentl=ls IN SR 3.3.6.7 Perform CHANNEL CALIBRATl()N . 18 mentl=ls INS HBRSEP Unit No. 2 3.3-38 Amendment No. 4+e
CREFS Actuation Instrumentation 3.3.7 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time for Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours D. Required Action and D.1 Suspend movement of Immediately associated Completion irradiated fuel Time for Condition A or B assemblies. not met during movement of irradiated fuel assemblies. SURVEILLANCE REQUIREMENTS
NOTE--------------------------------------------------------
Refer to Table 3.3.7-1 to determine which SRs apply for each CREFS Actuation Function . SURVEILLANCE FREQUENCY SR 3.3.7.1 Perform CHANNEL CHECK. 12 hours ~(---+!INSERT 1 SR 3.3.7.2 Perform COT. SR 3.3 .7.3 Perform ACTUATION LOGIC TEST. 31 days on a STAGGERED ~ TEST BASIS (continued) HBRSEP Unit No. 2 3.3-41 Amendment No. 17e 195
CREFS Actuation Instrumentation 3.3.7 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.7.4 Perform MASTER RELAY CHECK. 18 months ~ SR 3.3.7.5 Perform SLAVE RELAY TEST . 18 months tjlNSERT 1 I . SR 3.3.7.6 Perform CHANNEL CALIBRATION . 18 months ~INSERT 1 HBRSEP Unit No. 2 3.3-42 . Amendment No. 47e
*Auxiliary Feedwater (AFW) System Instrumentation 3.3.8 SURVEILLANCE REQUIREMENTS
. ------------------- .-----*-----N.OTE-- . ---------- , --- .---- .-- .-----------------------------. -
Refer to Table 3.3.8-1 to determine which SRs apply fQr each AFW Function. SURVEILLANCE FREQUENCY SR 3.3.8.1 Perform .CHANNEL CHECK. 12hours ~ SR 3.3.8.2 Perform COT. Q2 days ~!INSERT 1 SR 3.3.8.3 ----------------------------NOTE- * * ----* ------- * '---- *--------- For Function 5, the TADOT shall include injection of a simulated or actual signal to verify channel OPERABILITY,. 7
---------------------- * ' ' - - . - - - - - - -* - -- - - - - - - i _.,. __ *- - - - - * - - * .. - - - -
Perform TADOT.
=-
SR 3.3.8.4 Perform CHANNEL CALIBRATION . 18months ~ HBRSEP Unit No. 2 3.3-46 Amendment No. 476
RCS Pressure, Temperature, and Flow DNB Limits 3.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1 .1 Verify pressurizer pressure is greater than or equal to INSERT 1 the limit specified in the COLR. SR 3.4.1.2 Verify RCS average temperature is less than or equal 42:oours INSERT 1 to the limit specified in the COLR. 6 SR 3.4.1.3 Verify RCS total flow rate is~ 97.3 x 10 lbm/hr and 42:oours INSERT 1 greater than or equal to the limit specified in the COLR. SR 3.4.1.4 ---------~----~-~------NOTE~----------~------------------- Not required to be performed until 24 hours after
~ 90% RTP.
Verify by precision heat balance that RCS total flow 48menths INSERT 1 6 rate is~ 97.3 x 10 lbm/hr and greater than or equal to the limit specified in the COLR. HBRSEP Unit No. 2 3.4-2 Amendment No. ~
RCS Minimum Temperature for Criticality 3.4 .2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.2.1 Verify RCS T avg in each loop~ 530°F . --------NOTE-------- 0 n ly required if low T avg alarm not reset and any RCS loop T avg
< 543°F .
d0 R:iinutes .,., ~ thereafter ~ HBRSEP Unit No. 2 3.4-4 Amendment No. 47e
RCS PIT Limits 3.4.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. -------------NOTE-------------- C.1 Initiate action to restore Immediately Required Action C.2 shall parameter(s) to within be completed whenever limits. this Condition is entered.
----------------------------------- AND Requirements of LCO not C.2 Determine RCS is Prior to entering met any time in other than acceptable for MODE4 MODE 1, 2, 3, or 4. continued operation.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 --------------------------------NOTE------------------------------ 0 nly required to be performed during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing . Verify RCS pressure, RCS temperature, and RCS JO minutes ~ heatup and cooldown rates are within the limits specified in Figures 3.4.3-1 and 3.4.3-2. HBRSEP Unit No. 2 3.4-6 Amendment No. 47e
RCS Loops - MODES 1 and 2 3.4.4 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.4 RCS Loops - MODES 1 and 2 LCO 3.4.4 Three RCS loops shall be OPERABLE and in operation . APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of LCO not A.1 Be in MODE 3. 6 hours met. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.4.1 Verify each RCS loop is in operation . 12hours ~ HBRSEP Unit No. 2 3.4-9 Amendment No. 4-+e
RCS Loops - MODE 3 3.4.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify required RCS loops are in operation . 12 hours ~l!NSERT 1 SR 3.4.5.2 Verify steam generator secondary side water levels 12hours ~ are ~ 16% for required RCS loops. SR 3.4.5.3 -----------------------------NOTE-------------------------------- 0 n ly required to be met if LCO 3.4.5.a is required to be met. Verify the Rod Control System is not capable of rod 12hours ~ withdrawal. SR 3.4.5.4 ------* ----------- *---------NOTE--------------------------------- 0 n ly required to be met if LCO 3.4.5.b is required to be met. Verify the reactor trip breakers are open . SR 3.4 .5.5 ----------------------------NOTE---------------------------------- 0 nIy required to be met if LCO 3.4 .5.c is required to be met. Verify the lift disconnect switches for all control rods 12hours~ not fully withdrawn are open . (continued) HBRSEP Unit No. 2 3.4-12 Amendment No. 479
RCS Loops - MODE 3 3.4.5 SURVELLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4.5.6 ------------------------------NOTE------------------------------- Only required to be met if LCO 3.4.5.d is required to be met. Verify SOM is within required limits specified in the COLR. SR 3.4.5.7 Verify correct breaker alignment and indicated power 7 days ~ are available to the required pump that is not in operation . HBRSEP Unit No. 2 3.4-13 Amendment No. 47e
RCS Loops - MODE 4 3.4.6 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. One required loop or B.1 Be in MODE 5. 24 hours train inoperable. AND One required RHR train OPERABLE. C. Two required loops or C. 1 Suspend operations that Immediately trains inoperable. would cause introduction into the OR RCS , coolant with boron concentration less than Required loop or train not requ ired to meet SOM in operation. of LCO 3.1.1. AND Immediately C.2 Initiate action to restore one loop or train to OPERABLE status and operation . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one RHR train or RCS loop is in operation . 12 hours ~ SR 3.4.6.2 Verify SG secondary side water levels are~ 16% for 12 hours ~ required RCS loops. SR 3.4.6.3 Verify correct breaker alignment and indicated power 7 days ~ are available to the requ ired pump that is not in operation . HBRSEP Unit No. 2 3.4-15 Amendment No. 17e 1QO
RCS Loops - MODE 5, Loops Filled 3.4 .7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR train inoperable. A.1 Initiate action to restore Immediately a second RHR train to AND OPERABLE status. Required SG secondary OR side water level not within limits. A.2 Initiate action to restore Immediately required SG secondary side water level to within limits. B. Required RHR trains B.1 Suspend operations that Immediately inoperable. would cause introduction into the OR RCS, coolant with boron concentration less than No RHR train in operation . required to meet SOM of LCO 3.1.1. AND B.2 Initiate action to restore Immediately one RHR train to OPERABLE status and operation . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify one RHR train is in operation . 12hours ~ SR 3.4.7.2 Verify SG secondary side water level is ~ 16% in 12hours ~ required SG. (continued) HBRSEP Unit No. 2 3.4-17 Amendment No. 17e,1QO
RCS Loops - MODE 5, Loops Filled 3.4.7 SURVELLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4.7.3 Verify correct breaker alignment and indicated power 7 days ~ are available to the requi red RHR pump that is not in operation . HBRSEP Unit No. 2 3.4-18 Amendment No. 47e
RCS Loops - MODE 5, Loops Not Filled 3.4.8 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required RHR trains B.1 Suspend operations that Immediately inoperable. would cause introduction into the RCS , coolant with boron concentration less than No RHR train in operation . required to meet SOM of LCO 3.1.1. B.2 Initiate action to restore Immediately one RHR train to OPERABLE status and operation . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR train is in operation . 12 hours~ SR 3.4.8.2 Verify correct breaker alignment and indicated power 7 days ~ are available to the required RHR pump that is not in operation . HBRSEP Unit No. 2 3.4-20 Amendment No. 17e 190
Pressurizer 3.4.9 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 6 hours associated Completion Time of Condition B or C AND not met. D.2 Be in MODE 4. 12 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 Verify pressurizer water level is within limits. 12hours ~ SR 3.4.9.2 Verify capacity of required pressurizer heaters is 18month~
~ 125 kW.
SR 3.4.9.3 Verify required pressurizer heaters are capable of being powered from an emergency power supply. HBRSEP Unit No. 2 3.4-22 Amendment No. 47e
Pressurizer PORVs 3.4.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME F. (continued) F.2 Restore one block valve 2 hours to OPERABLE status. AND F.3 Restore remaining 72 hours block valve to OPERABLE status. G. Required Action and G.1 Be in MODE 3. 6 hours associated Completion Time of Condition F not met. AND G.2 Be in MODE 4. 12 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 -----------------------------NOTE------------------------------- Not required to be met with block valve closed in accordance with the Required Action of Condition B or E. Perform a complete cycle of each block valve. Q2days ~ (continued) HBRSEP Unit No. 2 3.4-27 Amendment No. 476
Pressurizer PORVs 3.4.11 SURVEILLANVE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4 .11.2 ------------------------------NOTE----------------------------- N ot required to be performed until 12 hours after entry into MODE 3. Perform a complete cycle of each PORV. 18months~ SR 3.4.11 .3 Perform a complete cycle of each solenoid 18 months~ air control valve and check valve on the nitrogen " ~ accumulators in PORV control systems. SR 3.4.11.4 Verify accumulators are capable of operating PORVs 18 months~ through a complete cycle. HBRSEP Unit No. 2 3.4-28 Amendment No. 47e
LTOP System 3.4.12 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME G. Two required PORVs G.1 Depressurize RCS and 8 hours inoperable. establish RCS vent of
<! 4.4 square inches.
Required Action and associated Completion Time of Condition A, B, D, E, or F not met. OR LTOP System inoperable for any reason other than Condition A, B, C, D, E, or F. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 --------------------------------NOTE------------------------------ 0 n ly required to be met when all RCS c'old leg temperatures <! 175°F and requirements of LCO 3.4.12.b not met. Verify a maximum of one SI pump is capable of 12hours ~ injecting into the RCS . (continued) HBRSEP Unit No. 2 3.4-32 Amendment No. 47e
LTOP System 3.4.12 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.4.12.2 ------------------------------NOTE------------------------------- 0 n ly required to be met when any RCS cold leg temperature < 175°F and requirements of LCO 3.4.12.b not met. Verify no SI pumps capable of injecting into the RCS . 12 hours ~ SR 3.4.12.3 Verify each accumulator isolation valve is closed and 12 hours ~ deenergized. SR 3.4.12.4 ------------------------------NOTE------------------------------- 0 nIy required to be met when complying with LCO 3.4.12.b. Verify RCS vent ~ 4.4 square inches open . 12 hours for unlocke n vent valve(s)
!INSERT 1 AND 31 days for locked open vent valve(s)
SR 3.4.12.5 Verify PORV block valve is open for each required 72 hours +-(--jlNSERT 1 PORV. . (continued) HBRSEP Unit No. 2 3.4-33 Amendment No. 7e
LTOP System 3.4.12 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4.12.6 ---------------------------- NOT E----------------------------- Not required to be performed until 12 hours after decreasing RCS cold leg temperature to~ 350°F. Perform a COT on each required PORV, excluding 31 days INSERT 1 actuation. SR 3.4.12.7 Perform CHANNEL CALIBRATION for each required 18 months ~ PORV actuation channel. HBRSEP Unit No. 2 3.4-34 Amendment No. ~
RCS Operational LEAKAGE 3.4.13 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.13.1 ------------------------------NOTES-----------------------------
- 1. Not required to be performed until 12 hours after establishment of steady state operation.
- 2. Not applicable to primary to secondary LEAKAGE.
Verify RCS operational LEAKAGE is within limits by 72 hours INSERT 1 performance of RCS water inventory balance. SR 3.4.13.2 ---------------- *------------NOTE-------------------------------- Not required to be performed until 12 hours after establishment of steady state operation . Verify primary to secondary LEAKAGE is~ 75 72 hours INSERT 1 gallons per day through any one SG. HBRSEP Unit No. 2 3.4-36 Amendment No. 242-
RCS PIVs 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1 --------------------------------NOTES---------------------------
- 1. Not required to be performed in MODES 3 and 4.
- 2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.
- 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.
Verify leakage from each RCS PIV is less than or In accordance with equal to an equivalent of 5 gpm at an RCS pressure the Inservice
<?: 2235 psig , and verify the margin between the Testing Program results of the previous leak rate test and the 5 gpm and 18 months~
limit has not been reduced by <?: 50% for valves with leakage rates > 1.0 gpm. AND Prior to entering MODE2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months (continued) HBRSEP Unit No. 2 3.4-39 Amendment No. 4-7e
RCS PIVs 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1 (continued) Within 24 hours following valve actuation due to automatic or manual action or flow through the valve SR 3.4.14.2 Verify RHR System interlock prevents the valves 18 months tjlNSERT 1 from being opened with a simulated or actual RCS pressure signal> 474 psig . I
. ,\'
HBRSEP Unit No. 2 3.4-40 Amendment No. 176 , 182
RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued) CONDITION REQIRED ACTION COMPLETION TIME D. Required containment D.1 Restore required 30 days atmosphere radioactivity containment atmosphere monitor inoperable. radioactivity monitor to OPERABLE status. AND OR Required containment fan cooler condensate flow rate D.2 Restore required 30 days monitor inoperable. containment fan cooler condensate flow rate monitor to OPERABLE status. E. Required Action and E.1 Be in MODE 3. 6 hours associated Completion Time not met. AND E.2 Be in MODE 5. 36 hours F. All required monitors F.1 Enter LCO 3.0.3. Immediately inoperable. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of the required 12hours ~ containment atmosphere radioactivity monitor. (continued) HBRSEP Unit No. 2 3.4-43 Amendment No. 47e
RCS Leakage Detection Instrumentation 3.4.15 SURVELLANCE REQUIREMENTS (continued) SURVELLANCE FREQUENCY SR 3.4.15.2 Perform COT of the required containment atmosphere 92 days ~ radioactivity monitor. SR 3.4.15.3 Perform CHANNEL CALIBRATION of the required 18 months ~ containment sump monitor. SR 3.4.15.4 Perform CHANNEL CALIBRATION of the required 18 months~ containment atmosphere radioactivity monitor. SR 3.4.15.5 Perform CHANNEL CALIBRATION of the required 18 months ~ containment fan cooler condensate flow rate monitor. HBRSEP Unit No. 2 3.4-44 Amendment No. 47e
RCS Specific Activity 3.4.16 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C. 1 Be in MODE 3 with 6 hours associated Completion Tavg < 500 ° F. Time of Condition A not met. OR DOSE EQUIVALENT 1-131
> 60 µCi/gm .
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.16.1 Verify reactor coolant gross specific ?days ~ activity s 100/E µCi/gm . SR 3.4.16.2 -----------------------------NOTE-------------------------------- 0 nly required to be performed in MODE 1. Verify reactor coolant DOSE EQUIVALENT 1-131 14days ~ specific activity s 0.25 µCi/gm . AND Between 2 and 6 hours after a THERMAL POWER change of;:: 15% RTP within a 1 hour period (continued) HBRSEP Unit No. 2 3.4-46 Amendment No. 2 RCS Specific Activity 3.4.16 SURVELLANCE REQUIREMENTS continued SURVELLANCE FREQUENCY SR 3.4.16.3 ----------------------------N OT E--------------------------------- N ot required to be performed until 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for ~ 48 hours. Determine E from a sample taken in MODE 1 after a 184 days ~ minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for ~ 48 hours. HBRSEP Unit No. 2 3.4-47 Amendment No. 47e
eves 3.4.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify seal injection flow of 2: 6 gpm to each RCP. 12 hours ~ SR 3.4.17.2 Verify seal injection flow of 2: 6 gpm to each RCP 18 months tjlNSERT 1 from each Makeup Water Pathway from the RWST . SR 3.4.17.3 For Makeup Water Pathways from the RWST to be In accordance with OPERABLE, SR 3.5.4.2 is applicable. SR 3.5.4.2 HBRSEP Unit No. 2 3.4-51 Amendment No. 47e
Accumulators 3.5.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 .Se in MODE 3. 6 hours associated Completion Time of Condition A or B AND not met. D.2 Reduce pressurizer 12 hours pressure to s 1000 psig . E. Two or more E.1 Enter LCO 3.0.3. Immediately accumulators inoperable. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify each accumulator isolation valve is fully open. Once prior to removing power from the valve operator SR 3.5.1.2 Verify borated water volume in each accumulator is ~ Re\:lfS ~
~ 825 ft and s 841 ft .
3 3 SR 3.5.1 .3 Verify nitrogen cover pressure in each accumulator is ~ Re\:lfS ~
~ 600 psig ands 660 psig.
(continued) HBRSEP Unit No. 2 3.5-2 Amendment No. 4-7&
Accumulators 3.5.1 SURVEILLANCE REQUIREMENRTS continued SURVELLANCE FREQUENCY SR 3.5.1.4 Verify boron concentration in each accumulator is 31days ~
;:: 1950 ppm and :s; 2400 ppm.
AND
-----NOTE------
Only required to be performed for affected accumulators Once within 6 hours after each solution volume increase of ;:: 70 gallons that is not the result of addition from the
.refueling water storage tank SR 3.5.1.5 Verify control power is removed from each 31 days ~!INSERT 1 I accumulator i?olation valve operator.
HBRSEP Unit No. 2 3.5-3 Amendment No.-1-+e
ECCS - Operating 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) 8 .2 Remove control power or air 24 hours to valve. C. Required Action and C. 1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 4. 12 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify the following valves are in the 12hours ~ listed position with control power to the valve operator removed . Number Position Function Sl-862 A&B Open Low Head Safety Injection (LHSI) Sl-863 A&B Closed LHSI Sl-864 A&B Open LHSI , High Head Safety Injection (HHSI) Sl-866 A&B Closed HHSI Sl-878 A&B Open HHSI SR 3.5.2.2 Verify each ECCS manual , power operated , and 31days ~ automatic valve in the flow path , that is not locked, sealed , or otherwise secured in position , is in the correct position . (continued) HBRSEP Unit No. 2 3.5-5 Amendment No. 47e
ECCS - Operating 3.5.2 SUREILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify each ECCS pump's developed head at the test In accordance with flow point is greater than or equal to the required the lnservice developed head. Testing Program SR 3.5.2.4 Verify each ECCS automatic valve in the flow path 18 ffiORths ~ that is not locked , sealed , or otherwise secured in position , actuates to the correct position on an actual or simulated actuation signal. SR 3.5.2.5 Verify each ECCS pump starts automatically on an 18 A=Jonths ~!INSERT 1 I actual or simulated actuation signal. SR 3.5.2.6 Verify, by visual inspection, the ECCS train 18 A=Jonths INSERT 1 containment sump suction inlet is not restricted by debris and the suction inlet trash strainers show no evidence of structural distress or abnormal corrosion. (continued) HBRSEP Unit No. 2 3.5-6 Amendment No.--2-1-a
ECCS - Operating 3.5.2 SURVEILLANCE FREQUENCY SR 3.5.2.7 Verify the following valves in the listed position: Number Position Function FCV-605 Closed/Motive RHR Air Isolated HCV-758 Closed/Motive RHR Air Isolated SR 3.5.2.8 Verify the following manual valve is locked in the Q2days ~ listed position
- Number Position Function RHR-764 Locked Open LHSI HBRSEP Unit No. 2 3.5-7 Amendment No. 47e
RWST 3.5.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.4 .1 ---------------------------NOTE------- *--- .---------------------- n 0 ly required .to be performed when ambient 1 air temperature is .< 45°F or> 100~F.
---------------------------------- *---------- *---------- I--------- ,---
Verify RWST borated water temperature is 2!: 45°F ands 100°F. SR 3.5.4.2 . . . , Verify RWST borated water volume *is 2!: 300,000 7days ~
*..ga)lons.
SR 3.5.4.3. Verify RWST bors>n C(?ncentration is 2!: 1950 ppm arid 7 days ~ s 2400 ppm . HBRSEP Unit No. 2 3.5-11 Amendment No. 47e
Containment Air Lock 3.6.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1 ---------------------------NOTES---------------------------------
- 1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.
- 2. Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.
Perform required air lock leakage rate testing in In accordance with accordance with the Containment Leakage Rate the Containment Testing Program . Leakage Rate Testing Program . SR 3.6.2.2 Verify only .one door in the air lock can be 24 months +-<--1PNSERT 1 j opened at a time. HBRSEP Unit No. 2 3.6-6 Amendment No. ~
Containment Isolation Valves 3.6.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 6 hours associated Completion Time not met. AND OR D.2 Be in MODE 5. 36 hours 42 inch penetration (Supply qr Exhaust) purge valves open and 6 inch penetration (pressure or vacuum relief) valves open simultaneously. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1 ---------------------------NOTE--------------------------------- T he 42 inch and 6 inch valves may not be open simultaneously. Verify each 42 inch purge supply and exhaust valve 31 days and each 6 inch pressure and vacuum relief valve is closed , except when the valves are open for safety related reasons, or for tests or Surveillances that require the valves to be open. IINJRT1 I (continued) HBRSEP Unit No. 2 3.6-10 Amendment No. 476
Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS continued SR 3.6.3.2 --------------------------N()TE----------------------------------- Valves and blind flanges in high radiation areas may be verified by use of administrative controls . Verify each containment isolation manual valve and a1 days for blind flange that is located outside containment and contai ent not locked , sealed or otherwise secured and required isolatio manual to be closed during accident conditions is closed, valves (e cept except for containment isolation valves that are open Penetratio under administrative controls. Pressurizat, n System valv with a diamete
$ 3/8 inch) and blind flanges INSERT 1 Penetration Pressurization System valves with a diameter
$ 3/8 inch SR 3.6.3.3 -----------------------N ()TE--------------------------------------
Va Ives and blind flanges in high radiation areas may be verified by use of administrative means. Verify each containment isolation manual valve and Prior to entering blind flange that is located inside containment and M()DE 4 from not locked , sealed or otherwise secured and required M()DE 5 if not to be closed during accident conditions is closed , performed within except for containment isolation valves that are open the previous under administrative controls. 92 days (continued) HBRSEP Unit No. 2 3.6-11 Amendment No. 47e
Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.3.4 Verify the isolation time of each automatic power In accordance operated containment isolation valve is within limits. with the Inservice Testing Program SR 3.6.3.5 Verify each automatic containment isolation valve 18months ~ that is not locked , sealed or otherwise secured in position , actuates to the isolation position on an actual or simulated actuation signal. SR 3.6.3.6 Verify each 42 inch inboard containment purge valve 18months ~ is blocked to restrict the valve from opening > 70°. HBRSEP Unit No. 2 3.6-12 Amendment No. 4+e
Containment Pressure 3.6.4 3.6 CONTAINMENT SYSTEMS 3.6.4 Containment Pressure LCO 3.6.4 Containment pressure shall be~ -0 .8 psig and :s; +1 .0 psig . ,APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment pressure not A.1 Restore containment 1 hour within limits. pressure to within limits. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1 Verify containment pressure is within limits. 12 hours +-(----1jlNSERT 1 I HBRSEP Unit No. 2 3.6-13 Amendment No. 47e
Containment Air Temperature 3.6.5 3.6 CONTAINMENT SYSTEMS 3.6.5 Containment Air Temperature LCO 3.6.5 Containment average air'temperature shall be :s 120°F. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment average air A.1 Restore containment 8 hours temperature not within average air temperature limit. to within limit. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 Verify containment average air temperature is within 24 hours ~ limit. HBRSEP Unit No. 2 3.6-14 Amendment No. 4+e
Containment Spray and Cooling Systems 3.6.6 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Two containment cooling D.1 Restore one 72 hours trains inoperable. containment cooling train to OPERABLE status. E. Required Action and E.1 Be in MODE 3. 6 hours associated Completion Time of Condition C or D AND not met. E.2 Be in MODE 5. 36 hours F. Two containment spray F.1 Enter LCO 3.0.3. Immediately trains inoperable. OR Any combination of three or more trains inoperable. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power 31 days ~ operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position. (continued) HBRSEP Unit No. 2 3.6-16 Amendment No. 47e
Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.6.2 Operate each containment cooling train fan unit for
;:: 15 minutes.
31 days < IINS ERT 1 SR 3.6.6.3 Verify cooling water flow rate to each cooling unit is 31 days ( IINS ERT 1
;:: 750 gpm.
SR 3.6.6.4 Verify each containment spray pump's developed In accordance with head at the flow test point is greater than or equal to the lnservice the required developed head . Testing Program SR 3.6.6.5 Verify each automatic containment spray valve in the 1ij FReRtRS IN flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal. . SR 3.6.6.6 Verify each containment spray pump starts 1ij FR9RtRS IN automatically on an actual or simulated actuation signal. SR 3.6.6.7 Verify each containment cooling train starts 1ij FReRtRS INS automatically on an actual or simulated actuation signal. SR 3.6.6.8 Verify each spray nozzle is unobstructed . Following activities which could result in nozzle blockage HBRSEP Unit No. 2 3.6-17 Amendment No. 176 194
Spray Additive System 3.6.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.7.1 Verify each spray additive manual , power operated ,
- 31 days ~
and automatic valve in the flow path that is not locked , sealed , or otherwise secured in position is in the correct position . SR 3.6.7.2 Verify spray additive tank solution volume is 184 days ~
~ 2505 gal.
SR 3.6.7.3 Verify spray additive tank NaOH solution 184 days ~ concentration is ~ 30% by weight. SR 3.6.7.4 Verify each spray additive automatic valve in the flow 18 months ~ path that is not locked , sealed , or otherwise secured in position , actuates to the correct position on an actual or simulated actuation signal. HBRSEP Unit No. 2 3.6-19 Amendment No. 47e
Isolation Valve Seal Water System 3.6.8 3.6 CONTAINMENT SYSTEMS 3.6.8 Isolation Valve Seal Water (IVSW) System LCO 3.6.8 The IVSW System shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. IVSW system A.1 Restore IVSW system to 72 hours inoperable. OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not AND met. B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.8.1 Verify IVSW tank pressure is ~ 46.2 psig. 12hours ~ SR 3.6.8.2 Verify the IVSW tank volume is ~ 85 gallons. 31days ~ (continued) HBRSEP Unit No. 2 3.6-20 Amendment No. ~
Isolation Valve Seal Water System 3.6.8 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.8.3 Verify the opening time of each air operated In accordance with header injection valve is within limits. the Inservice Testing Program SR 3.6.8.4 Verify each automatic valve in the IVSW System 18A1onths ~ actuates to the correct position on an actual or simulated actuation signal. SR 3.6.8.5 Verify the IVSW dedicated nitrogen bottles will 18Alonths ~ pressurize the IVSW tank to~ 46.2 psig . SR 3.6.8.6 Verify total IVSW seal header flow rate is 1*8 AlORths ~
- 124 cc/minute HBRSEP Unit No. 2 3.6-21 Amendment No. ~
AFW System 3.7.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each AFW manual, power operated, and 31days ~ automatic valve in each water flow path , and in the steam supply flow path to the steam driven AFW pump, that is not locked , sealed , or otherwise secured in position, is in the correct position. SR 3.7.4.2 ----------------------------NOTE--------------------------------- Not required to be performed for the steam driven AFW pump until 24 hours after ~ 1000 psig in the steam generator. Verify the developed head of each AFW pump at the 31 days on a flow test point is greater than or equal to the required STAGGERED ~ developed head. TEST B,<\SIS SR 3.7.4 .3 ----------------------------NOTE--------------------------------- Not applicable in MODE 4 when steam generator is being used for heat removal. Verify each AFW automatic valve that is not locked, 18R1onths ~ sealed , or otherwise secured in position , actuates to the correct position on an actual or simulated actuation signal. (continued) HBRSEP Unit No. 2 3.7-12 Amendment No. 4+e
AFW System 3.7.4 SURFEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.7.4.4 -------------------------NOTES----------------------------------
- 1. Not required to be performed for the steam driven AFW pump until 24 hours after ~ 1000 psig in the steam generator.
- 2. Not applicable in MODE 4 when steam generator is being used for heat removal.
Verify each AFW pump starts automatically on an 18months ~ actual or simulated actuation signal. SR 3.7.4.5 -----------------------*--NOTE------------------------------------ Not required to be performed for the steam driven AFW pump until prior to entering MODE 1. Verify proper alignment of the required Prior to entering AFW flow paths by verifying flow from the MODE 2, condensate storage tank to each steam generator. whenever unit has been in MODE 5 or 6 for> 30 days SR 3.7.4.6 Verify the AFW automatic bus transfer switch 18months ~ associated with discharge valve V2-16A operates automatically on an actual or simulated actuation signal. HBRSEP Unit No. 2 3.7-13 Amendment No. 4-+e
CST 3.7.5 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. SWS supply to AFW C.1 Be in MODE 3. 6 hours system inoperable. C.2 Be in MODE 4 , without 18 hours reliance on steam generator for heat removal. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 Verify the CST level is~ 35,000 gal. 12hours ~ SR 3.7.5.2 Verify by administrative means OPERABILITY of d1days ~ backup SWS supply to the AFW System . HBRSEP Unit No. 2 3.7-15 Amendment No. 47e
CCW System 3.7.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7 .6.1 -------------------------------NOTE------------------------------- 1so Iat ion of CCW flow to individual components does not render the CCW System inoperable. Verify each required CCW manual, power operated , 31 days ~ and automatic valve in the flow path servicing safety related equipment, that is not locked , sealed , or otherwise secured in position , is in the correct position . SR 3.7.6.2 Verify each required CCW pump starts automatically 18 months ~NSERT 1 on an actual or simulated LOP DG Start undervoltage signal. HBRSEP Unit No. 2 3.7-17 Amendment No. 17e 18e I
sws 3.7.7 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Two Turbine Building loop C. 1 Close and deactivate 2 hours isolation valves inoperable. one inoperable Turbine Building loop isolation valve. D. Required Actions and D.1 Be in MODE 3. 6 hours associated Completion Times of Conditions A, B, AND or C not met. D.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.7.1 --------------------------NOTE----------------------------------- 1so Iati on of SWS flow to individual components does not render the SWS inoperable. Verify each SWS manual , power operated , and automatic valve in the flow path servicing safety related equipment, that is not locked , sealed , or otherwise secured in position , is in the correct position . SR 3.7.7.2 Verify each SWS automatic valve in the flow path 18 months ~ that is not locked , sealed , or otherwise secured in position , actuates to the correct position on an actual or simulated actuation signal. (continued) HBRSEP Unit No. 2 3.7-19 Amendment No. 47e
sws 3.7.7 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.7.7.3 Verify each SWS pump and SWS booster pump 18months ~ starts automatically on an actual or simulated actuation signal. SR 3.7.7.4 Verify the SWS automatic bus transfer switch 18months ~ associated with Turbine Building loop isolation valve V6-16C operates automatically on an actual or simulated actuation signal. HBRSEP Unit No. 2 3.7-20 Amendment No. 476
UHS 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Ultimate Heat Sink (UHS) LCO 3.7.8 The UHS shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Service water A.1 Verify required cooling 1 hour temperature not within capacity maintained . limit. AND Once per 12 hours thereafter AND A.2 Verify service water Once per hour temperature is :-=: ; 99°F. B. Required Action and 8 .1 Be in MODE 3. 6 hours associated Completion Time not met. AND OR 8.2 Be in MODE 5. 36 hours UHS inoperable for reasons other than Condition A. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 Verify water level of UHS is:::: 218 ft mean sea level. 24 hours ~ HBRSEP Unit No. 2 3.7-21 Amendment No. 494-
UHS 3.7.8 SURVEILLANCE REQUIREMENTS continued SR 3.7.8.2 Verify service water temperature is~ 97°F. 24hours ~ HBRSEP Unit No. 2 3.7-21a Amendment No. 494
CREFS 3.7.9 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME H Required Action and H. Be in MODE 3. 6 hours associated Completion Time of Condition G not AND met in MODE 1, 2, 3, or 4. H.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Operate each CREFS train for~ 15 minutes. 31 days ~ SR 3.7.9 .2 Perform required CREFS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). VFTP SR 3.7.9.3 Verify each CREFS train actuates on an actual or 18 months ~ simulated actuation signal. SR 3.7.9.4 Perform required CRE maintenance and testing in In accordance with accordance with the CRE Habitability Program . the CRE Habitability Program HBRSEP Unit No. 2 3.7-24 Amendment No. ~
CREATC 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Verify each CREA TC WCCU train has the capability 18 months ~ to remove the assumed heat load . HBRSEP Unit No. 2 3.7-27 Amendment No. 4+e
FBACS 3.7.11
- 3. 7 PLANT SYSTEMS 3.7.11 Fuel Building Air Cleanup System (FBACS)
LCO 3.7.11 The FBACS shall be OPERABLE and operating. APPLICABILITY: During movement of irradiated fuel assemblies in the fuel building . ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. The FBACS inoperable A.1 Suspend movement of Immediately during movement of irradiated fuel irradiated fuel assemblies assemblies in the fuel in the fuel building . building. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Operate the FBACS for 2: 15 continuous minutes with 31 days ~ the heaters operating automatically. SR 3.7.11 .2 Perform required FBACS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP) . the VFTP (continued) HBRSEP Unit No. 2 3.7-28 Amendment No. ~
FBACS 3.7.11 SURVEILLANCE REQUIREMENTS continued SR 3.7.11 .3 ---------------------------NOTE------ -------' --' . __ -- . ----- ,, --- . Not required to be met when the only movement of irradiated fuel is movement of fhe spent fuel 'shipping cask containing irradiated fuel. Verify the FBACS can maintain a negative pressure 18months _~ with respect to atmospheric .pressure.
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,' l HBRSEP Unit No. 2 3.7-29 Amendment No. 4+e
Fuel Storage Pool Water Level 3.7.12 3.7 PLANT SYSTEMS 3.7.12 Fuel Storage Pool Water Level LCO 3.7.12 The fuel storage pool water level shall be~ 21 ft over the top of irradiated fuel assemblies seated in the storage racks. APPLICABILITY: During movement of irradiated fuel assemblies in the fuel storage pool. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool water A.1 -----------NOTE------------- level not within limit. LCO 3.0.3 is not applicable. Suspend movement of Immediately irradiated fuel assemblies in the fuel storage pool. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 Verify the fuel storage pool water level is ~ 21 ft ?days ~ above the top of the irradiated fuel assemblies seated in the storage racks. HNRSEP Unit No. 2 3.7-30 Amendment No. 4-7e
Fuel Storage Pool Boron Concentration 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Fuel Storage Pool Boron Concentration LCO 3.7 .13 The fuel storage pool boron concentration shall be ;:: 1500 ppm. APPLICABILITY: At all times. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool boron -----------------NO TE-------------------- concentration not within LCO 3.0.3 is not applicable. limit. A.1 Suspend movement of Immediately fuel assemblies in the fuel storage pool. A.2 Initiate action to restore Immediately fuel storage pool boron concentration to within limit. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Verify the fuel storage pool boron concentration is 7 days -(--<!INSERT 1 I within limit. HBRSEP Unit No. 2 3.7-31 Amendment No. 4Q8
Secondary Specific Activity 3.7.15 3.7 PLANT SYSTEMS 3.7.15 Secondary Specific Activity LCO 3.7.15 The specific activity of the secondary coolant shall be~ 0.10 µCi/gm DOSE EQUIVALENT 1-131 . APPLICABILITY: MODES 1, 2, 3, and 4 . ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Specific activity not within A.1 Be in MODE 3. 6 hours limit. AND A .2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.15.1 Verify the specific activity of the secondary coolant is 31 days -<-.. .!INSERT 1 I
~ 0.10 µCi/gm DOSE EQUIVALENT 1-131.
HBRSEP Unit No. 2 3.7-33 Amendment No. 476
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated +Elays -<--!INSERT 1 l power availability for the offsite circuit. SR 3.8.1 .2 -------------------------NOTES--------------------------------
- 1. Performance of SR 3.8.1 .7 satisfies this SR.
- 2. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading .
- 3. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. When modified start
. procedures are not used , the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.
Verify each DG starts from standby conditions and 31 days ( . !INSERT 1 l achieves steady state voltage:::: 467 V ands; 493 V, and frequency:::: 58.8 Hz and s; 61.2 Hz. (continued) HBRSEP Unit No. 2 3.8-4 Amendment No. 4+e
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.3 -----------------------------N OTES------------------------------
- 1. DG loadings may include gradual loading as recommended by the manufacturer.
- 2. Momentary transients outside the load range do not invalidate this test.
- 3. This Surveillance shall be conducted on only one DG at a time.
- 4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.
- 5. During periods when a diesel generator is being operated for testing purposes , its protective trip~ need not be bypassed after the diesel generator has properly assumed the load on its bus.
. Verify each DG is synchronized and loaded and 31 days +-(-------11!NSERT 1 I operates for ~ 60 minutes at a load ~ 2350 kW and
~ 2500 kW.
SR 3.8.1.4 Verify each day tank contains~ 140 gallons of fuel oil. 31 days +-(--11!NSERT 1 I SR 3.8.1 .5 Check for and remove accumulated water from each 31 days ~<-~!INSERT 1 I day tank. (continued) HBRSEP Unit No. 2 3.8-5 Amendment No. 4+e
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1 .6 Verify the fuel oil transfer system operates to 31 days ~<---1jlNSERT 1 I automatically transfer fuel oil from storage tank to the day tank, SR 3.8.1.7 --------------------------NOTES-------------------------------- AII DG starts may be preceded by an engine prelube period . Verify each DG starts from standby condition and 184 days ~ achieves in s 1O seconds , voltage ~ 467 V and frequency ~ 58.8 Hz, and after steady state conditions are reached , maintains voltage~ 467 V ands 493 V and frequency ~ 58 .8 Hz and s 61.2 Hz. SR 3.8.1.8 ---------------------------N OTES-------------------------------
- 1. This Surveillance shall not be performed in MODE 1 or 2.
- 2. If performed with the DG synchronized with offsite power, it shall be performed at a power factors 0.9.
Ve'rify each DG rejects a load greater than or equal to 18 months ~ its associated single largest post-accident load and does not trip on overspeed. * (continued) HBRSEP Unit No. 2 3.8-6 Amendment No. 47e
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1 .9 ----------------------------N OTES------------------------------
- 1. All DG starts may be preceded by an engine prelube period.
- 2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
- 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
Verify on an actual or simulated loss of offsite power 18months ~ signal:
- a. De-energization of emergency buses; b Load shedding from emergency buses;
- c. DG auto-starts from standby condition and:
- 1. energizes permanently connected lo.ads in :s; 10 seconds,
- 2. energizes auto-connected shutdown loads through automatic load sequencer,
- 3. maintains steady state voltage 2!: 467 V and :s; 493 V,
- 4. maintains steady state frequency 2!: 58.8 Hz and :s; 61 .2 Hz, and
- 5. supplies permanently connected and auto-connected shutdown loads for 2!: 5 minutes.
(continued) HBRSEP Unit No. 2 3.8-7 Amendment No. 47e
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1 .10 ---------------------------NOTES------------------------------- 1 All DG starts may be preceded by prelube period .
- 2. This Surveillance shall not be performed in MODE 1 or 2.
- 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
- Verify on an actual or simulated Engineered Safety Feature (ESF) actuation signal each DG auto-starts from standby condition and:
- a. In :5 10 seconds after auto-start achieves voltage~ 467 V, and after steady state conditions are reached, maintains voltage
~ 467 V and :5 493 V;
- b. In :5 1O seconds after auto-start achieves frequency ~ 58.8 Hz, and after steady state conditions are reached, maintains frequency
~ 58.8 Hz and :5 61 .2 Hz; *
- c. Operates for ~ 5 minutes;
- d. Permanently connected loads remain energized from the offsite power system; and
- e. Emergency loads are energized through the automatic load sequencer from the offsite power system.
(continued) HBRSEP Unit No. 2 3.8-8 Amendment No. 4+e
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1 .11 Verify each DG's automatic trips are bypassed except engine overspeed . 24months ~ SR 3.8.1.12 ---------------------------NOTES--------------------------------
- 1. Momentary transients outside the load and power factor ranges do not invalidate this test.
- 2. This Surveillance shall not be performed in MODE 1 or 2.
- 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
Verify .each DG operating at a power factors 0.9 18months ~ operates for ~ 24 hours:
- a. For~ 1.75 hours loaded~ 2650 kW and s 2750 kW; and
- b. For the remaining hours of the test loaded
~ 2400 kW and s 2500 kW.
(continued) HBRSEP Unit No. 2 3.8-9 Amendment No. ~
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.13 -------------------------------NOTES----------------------------
- 1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated ~ 2 hours loaded ~ 2400 kW and
~ 2500 kW.
Momentary transients outside of load range do not invalidate this test.
- 2. All DG starts may be preceded by an engine prelube period .
Verify each DG starts and achieves, in ~ 1O seconds, 18 months ~ voltage~ 467 V, and frequency~ 58.8 Hz, and after steady state conditions are reached , maintains voltage~ 467 V and~ 493 V and frequency~ 58.8 Hz and~ 61 .2 Hz. SR 3.8.1 .14 * ' ----------------------------NOTE-------------------------------- This Surveillance shall not be performed in MODE 1, 2, 3, or 4. Verify actuation of each sequenced load block is 18months ~ within+/- 0.5 seconds of design setpoint for each emergency load sequencer. (continued) HBRSEP Unit No. 2 3.8-10 Amendment No. 47e
AC Sources-Operating 3.8 .1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1 .15 ---------------------------NOTES--------------------------------
- 1. All DG starts may be preceded by an engine prelube period.
- 2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
- 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
Verify on an actual or simulated loss of offsite power 18 months ~ signal in conjunction with an actual or simulated ESF actuation signal:
- a. De-energization of emergency buses;
- b. Load shedding from emergency buses; and
- c. DG auto-starts from standby condition and :
- 1. energizes permanently connected loads in
- 5 10 seconds,
- 2. energizes auto-connected emergency loads through load sequencer,
- 3. achieves steady state voltage 2: 467 V and
- 5 493 V,
- 4. achieves steady state frequency 2: 58.8 Hz and
- 5 61.2 Hz, and (continued)
HBRSEP Unit No. 2 3.8-11 Amendment No. 4+e
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.15 (continued)
- 5. supplies permanently connected and auto connected emergency loads for ;:: 5 minutes.
SR 3.8.1.16 -------------------------NOTE------------------------------------
- 1. This Surveillance shall not be performed in MODE 1 or 2.
- 2. SR 3.8.1.16 is not required to be met if 4.160 kV bus 2 and 480 V Emergency Bus 1 power supply is from the start up transformer.
Verify automatic transfer capability of the 4.160kV bus 18 months ~ 2 and the 480V Emergency bus 1 loads from the Unit auxiliary transformer to the start up transformer. SR 3.8.1 .17 ------------------------NOTE------------------------------------- A II DG starts *may be preceded by an engine *prelube period . Verify when started simultaneously from standby 10 years ~ condition, each DG achieves, in s 10 seconds, voltage
;:: 467 V and frequency ;:: 58.8 Hz, and after steady state conditions are reached, maintains voltage 2!
467 V ands 493 V and frequency;:: 58'.8 Hz and S61 .2Hz. HBRSEP Unit No. 2 3.8-12 Amendment No. 4+e
Diesel Fuel Oil , and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify 2! 19,000 gallons of diesel fuel oil available to ?days ~ the DGs from the Unit 2 DG fuel oil storage tank 2! 34,000 gallons available to the DGs from the combination of the Unit 1 IC turbine fuel oil storage tanks and the Unit 2 DG fuel oil storage tank. SR 3.8.3.2 Verify fuel oil properties of stored fuel oil are tested in In accordance with accordance with , and maintained within the limits of, the Diesel Fuel Oil the Diesel Fuel Oil Testing Program . Testing Program SR 3.8.3.3 Verify each DG air start receiver pressure is 31days ~ 2! 210 psig . SR 3.8.3.4 Check for and remove accumulated water from each a~~ays *~ fuel oil storage tank. HBRSEP Unit No. 2 3.8-18 Amendment No. 4+e
DC Sources-Operating
~
3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One DC electrical power A.1 Restore DC electrical 2 hours subsystem inoperable. power subsystem to OPERABLE status. B.* Required Action and B.1 Be in MODE 3. 6 hours Associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is~ 125.7 Von float 7days ~ charge . (continued) HBRSEP Unit No. 2 3.8-19 Amendment No.47e
DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.4.2 Verify battery cells, cell plates, and racks show no 18 months ~ visual indication of physical damage or abnormal deterioration that could degrade battery performance. SR 3.8.4.3 Remove visible terminal corrosion, verify battery cell to 18 months ~ cell and terminal connections are clean and tight, and are coated with anti-corrosion material. SR 3.8.4.4 Verify each battery charger supplies ~ 300 amps at 18 months ~
~ 125 V for~ 4 hours.
SR 3.8.4.5 -----------------------NOTES----------------------------------
- 1. The modified performance discharge test in SR 3.8.4.6 may be performed in lieu of the service test in SR 3.8.4.5.
- 2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
Verify battery capacity is adequate to supply, and 18months ~ maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test. (continued) HBRSEP Unit No. 2 3.8-20 Amendment No. ~
DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.4.6 ---------------------------NOTE---------------------------------- This Surveillance shall not be performed in MODE 1, 2, 3, or 4. Verify battery capacity is ~ 80% for the "A" Battery and 60months ~ 91 % for the "B" battery of the manufacturer's rating when subjected to a performance discharge test or a AND modified performance discharge test. 1 12 moaths~:~nSERT I battery shows degradation or has reached 85% of expected life with capacity
< 100% of manufacturer's rating .
AND lNSERT 1 j 24 months when
.. battery has reached 85% of expected life with capacity
~ 100% of manufacturer's rating .
HBRSEP Unit No. 2 3.8-21 Amendment No. ~
I Battery Cell Parameters I 3.8.6 ACTIONS (continued) I CONDITION REQUIRED ACTION COMPLETION TIME
- 8. Required Action and 8 .1 Declare associated Immediately associated Completion battery inoperable.
Time of Condition A not met. One or more batteries with average electrolyte temperature of the representative cells
< 67°F.
OR One or more batteries with one or more battery cell parameters not within Category C values. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 Verify battery cell parameters meet Table 3.8.6-1 7 days -(-jlNSERT 1 I Category A limits. (continued) H8RSEP Unit No. 2 3.8-25 Amendment No. 47e
Battery Cell Parameters 3.8.6 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.6.2 Verify battery cell parameters meet Table 3.8.6-1 Q2 days ~(-1jlNSERT 1 l Category B lirnits. Once within 24 hours after a battery discharge
< 110 V Once within 24 hours after a battery overcharge
> 150V SR 3.8.6.3 Verify average electrolyte temperature of Q2days ~
representative cells is~ 67°F. HBRSEP Unit No. 2 3.8-26 Amendment No. 4+e
NO CHANGE ON THIS PAGE - PROVIDED FOR Battery Cell Parameters INFORMATION ONLY 3.8.6 Table 3.8.6-1 (page 1 of 1) Battery Cell Parameters Requirements CATEGORY A: CATEGORY C: LIMITS FOR EACH CATEGORY B: ALLOWABLE LIMITS DESIGNATED PILOT LIMITS FOR EACH FOR EACH PARAMETER CELL CONNECTED CELL CONNECTED CELL Electrolyte Level > Minimum level > Minimum level Above top of plates, indication mark, and indication mark, and and not overflowing
- 5 % inch above :s; % inch above maximum level maximum level indication mark(a) indication mark(a)
Float Voltage ~ 2.13 V ~ 2.13 V > 2.07 V Specific Gravity(b)(c) ~ 1.200 ~ 1.195 Not more than 0.020 below average of all AND connected cells Average of all AND connected cells
> 1.205 Average of all connected cells
~ 1.195 (a) It is acceptable for the electrolyte level to temporarily increase above the specified maximum during equalizing charges provided it is not overflowing.
(b) Corrected for electrolyte temperature and level. Level correction is not required , however, when battery charging current is < 2 amps while on float charge. (c) A battery charging current of< 2 amps when on float charge is acceptable for meeting specific gravity limits following a battery recharge, for a maximum of 7 days. When charging current is used to satisfy specific gravity requirements, specific gravity of each connected cell shall be measured prior to expiration of the 7 day allowance. HBRSEP Unit No. 2 3.8-27 Amendment No. 176
AC Instrument Bus Sources-Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct inverter voltage, frequency , and 7 days ~ alignment to required AC instrument buses. SR 3.8.7.2 Verify voltage availability and correct CVT alignment 7 days ~!INSERT 1 I to required AC instrument buses. HBRSEP Unit No. 2 3.8-29 Amendment No. 479
AC Instrument Buses-Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SOM or boron concentration . A.2.4 Initiate action to restore Immediately AC instrument bus sources to OPERABLE status . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 ----------------------------NOTE--------------------------------- Actual voltage and frequency measurement is not required for AC instrument buses supplied from CVTs. Verify correct inverter voltage, frequency , and 7days ~ alignments to required AC instrument buses. HBRSEP Unit No. 2 3.8-31 Amendment No. 176,190
Distribution Systems-Operating 3.8.9 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME G. Two trains with inoperable G.1 .Enter LCO 3.0.3. Immediately distribution subsystems that result in a loss of safety function . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 ---------------------------NOTE---------------------------------- A ct ua I voltage measurement is not required for the AC vital buses supplied from the constant voltage transformers. Verify correct breaker alignments and voltage to AC , 7 days ~
- DC , and AC instrument bus electrical power distribution subsystems.
SR 3.8.9.2 Verify capability of the two molded case circuit breakers for AFW Header Discharge Valve to SIG "A", V2-16A to trip on overcurrent. SR 3.8.9.3 Verify capability of the two molded case circuit 18months ~ breakers for Service Water System Turbine Building Supply Valve (emergency supply) , V6-16C to trip on overcurrent. HBRSEP Unit No. 2 3.8-34 Amendment No. 47e
Distribution Systems-Shutdown 3.8.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SOM or boron concentration . AND A.2.4 Initiate actions to restore Immediately required AC , DC , and AC instrument bus electrical power distribution subsystems to OPERABLE status . AND A.2.5 Declare associated Immediately required residual heat removal subsystem(s) inoperable and not in operation . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 ---------------------------NOTE---------------------------------- A ct uaI voltage measurement is not required for the AC vital buses supplied from constant voltage transformers. Verify correct breaker alignments and voltage to ?days ~ required AC, DC , and AC instrument bus electrical power distribution subsystems. HBRSEP Unit No. 2 3.8-36 Amendment No. 176,190
Boron Concentration 3.9.1 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 Boron concentrations of the Reactor Coolant System , the refueling canal , and the refueling cavity shall be maintained within the limit specified in the COLR. APPLICABILITY: MODE 6. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Boron concentration not A.1 Suspend CORE Immediately within limit. ALTERATIONS . A.2 Suspend positive Immediately reactivity additions. A.3 Initiate action to restore Immediately boron concentration to within limit. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1 .1 Verify boron concentration is within the limit specified 72 hours +-(---1!1NSERT 1 I in COLR. HBRSEP Unit No. 2 3.9-1 Amendment No. 47e
Nuclear Instrumentation 3.9.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.2.1 Perform CHANNEL CHECK. SR 3.9.2.2 ----------------------N()TE-------------------------------------- Neutron detectors are excluded from CHANNEL CALIBRATl()N. Perform CHANNEL CALIBRATl()N. 18months ~ HBRSEP Unit No. 2 3.9-3a Amendment No. 17e,180,1QO I
Containment Penetrations 3.9.3 SURVEILLANCE REQUIREMENTS SURVEIL LANCE FREQUENCY SR 3.9.3.1 Verify each required containment penetration is in the 7 days ~ required status. SR 3.9.3.2 Verify each required containment ventilation valve 18 months ~ actuates to the isolation position on an actual or simulated actuation signal. HBRSEP Unit No. 2 3.9-5 Amendment No. 47e
RHR and Coolant Circulation-High Water Level 3.9.4 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Initiate action to satisfy Immediately RHR train requirements . AND A.4 Close all containment 4 hours penetrations providing direct access from containment atmosphere to outside atmosphere. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.4.1 Verify one RHR train is in operation . HBRSEP Unit No. 2 3.9-7 Amendment No. 17e,190
RHR and Coolant Circulation-Low Water Level 3.9.5 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2 Initiate action to restore Immediately one RHR train to operation . AND B.3 Close all containment 4 hours penetrations providing direct access from containment ~ atmosphere to outside atmosphere. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR train is in operation . 12hours ~ SR 3.9.5 .2 Verify correct breaker alignment and indicated power 7 days ~<----l!INSERT 1 l available to the required RHR pump that is riot in operation . HBRSEP Unit No. 2 3.9-9 Amendment No. 4+e
Refueling Cavity Water Level 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Refueling Cavity Water Level LCO 3.9.6 Refueling cavity water level shall be maintained ;:: 23 ft above the top of reactor vessel flange. APPLICABILITY: During movement of irradiated fuel assemblies within containment. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Refueling cavity water level A. 1 Suspend movement of Immediately not within limit. irradiated fuel assemblies within containment. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify refueling cavity water level is ;:: 23 ft above the 24 hours ~ top of reactor vessel flange. HBRSEP Unit No. 2 3.9-10 Amendment No. 17e 195
Containment Purge Filter System 3.9.7 SURVEILLANCE REQUIREMETS SURVEILLANCE FREQUENCY SR 3.9.7.1 Verify relative humidity of containment atmosphere to 4--RGYF ~ be processed by the Containment Purge Filter System is s 70%. SR 3.9.7.2 Verify the Containment Purge Filter System is in 12 hours ~!INSERT 1 I operation and maintaining containment pressure negative relative to the adjacent auxiliary building areas. SR 3.9 .7.3 Perform required Containment Purge Filter System In accordance with filter testing in accordance with the Ventilation Filter the VFTP Testing Program (VFTP) . HBRSEP Unit No. 2 3.9-12 Amendment No. 47e
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.17 Control Room Envelope Habitability Program (continued)
' ' ~ .' .
- a. The definition of the CRE and the CRE boundary.
- b. Requirements for maintaining the CRE boundary in its design condition ,
including configuration* control and preve.l'!tive, mainte~al")_ae: C. Requirements for: (i). determining the :unfiltered*air ri nleakage past the
.CRE boundary into .the CRE ~n accordance with th_e testing methods and c1t the frequencies spec(fied in St3ctions ..C.1 _~nd C.?: 9f Reg1,.1latory Guide 1.197, "Demonstratin*g Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0. The following excepti9ri i's takeh ki Sections C.1 and
. C.2* of Regulatory Guide 1.197, Revision* O:
- 1. Unfiltered air inleakage testing shall include*the ability to deviate from the test methodology of ASTM-E7 41. These exceptions shall be documented in the.test report.
- d. Measurement, at d~sig!lated loqations,, of the CRE pressure relative to external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFS , operating at the flow rate required*oy thef VFTP 1 at a frequency of 18 months on a STAGGERED
*if.ESt BASIS*. The re*sults shall be trended and used' as part of the assessment of the CRE boundary. ,* * *
- e. The quantitative limits on unfiltered air inleakage into the CRE . These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.
The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences. For hazardous chemicals, inleakage rates shall be less than assumed in the licensing bases.
- f. The provisions of SR 3.0.2 are applicable to the frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by
~---~
INSERT 2 paragraphs c and d, respectively. HBRSEP 5.0-22a Amendment No. -z4 Robinson Technical Specification Inserts for TSTF-425, Revision 3 Insert 1 In accordance with the Surveillance Frequency Control Program Insert 2 5.5.18 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.
- a. The Surveillance Frequency Control Program shall contain a list of FreqCJencies of those Surveillance Requirements for which the Frequency is controlled by the program .
- b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies, " Revision 1.
- c. The .provisions of Surveillance Requirement~ 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program .
to RNP-RA/18-0015
. . A ITACHMENT'*4
. s*
- License Amendment Request H.B. Robinson Steam *E lectric Plant, UnitNo. 2 (HBRSEP)
Docket No. 50-261 Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of.Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)
- Proposed Technical Specification Bases Page Changes
Robinson Technical Specification Bases Inserts for TSTF-425, Revision 3 Insert 3 The Surveillance F/eqyency is. contrpllep under the Surveillance Frequef1Cy C.ontrol Program. 1.,,.,, Insert 4
, * *. * ' .. ' *, . 1 1 > **
- l ,,. ' / * * * *. 'r . *, ,. , \ . . : . *' ,
The SurveUlc!nce freqµe~cie~i~r~ ,conyolled upder. ~he ?Urv~,il_lanee1 Frequer;:i,cy .C~>ntrql Program. *; : ; ,,.. *** ;:> '
SOM B 3.1.1 BASES SURVEILLANCE SR 3.1 .1.1 (continued) REQUIREMENTS
- c. RCS average temperature;
- d. Fuel burnup based on previous critical boron concentration;
- e. Xenon concentration ;
- f. Samarium concentration ; and
- g. Isothermal temperature coefficient (ITC).
Using the ITC accounts for Doppler reactivity in this calculation because the reactor is subcritical , and the fuel temperature will be changing at the same rate as the RCS.
+he Frequency of 24 hours is based on the generally slow change in required boron concentration and the low probability of an accident
!INSERT 3 i-1--->~ occurring without the required SOM . +his allows time for the operator to collect the required data, which includes performing a boron concentration analysis, and complete the verification.. REFERENCES 1. UFSAR, Section 3.1.
- 2. UFSAR, Section 15.1.5.
- 3. UFSAR, Section 15.4.6.
- 4. Deleted .
- 5. UFSAR, Table 15.4.6-1 .
- 6. UFSAR, Table 9.3.4-1 .
HBRSEP Unit No. 2 B 3.1-6 Revision No. 34-
Core Reactivity B 3.1.2 BASES (continued) SURVEILLANCE SR 3.1.2.1 REQUIREMENTS Core reactivity is verified by periodic comparisons of measured and predicted RCS boron concentrations. The comparison is made, considering that other core conditions are fixed or stable , including control rod position , moderator temperature, fuel temperature, fuel depletion, xenon concentration , and samarium concentration . The Surveillance is performed prior to entering MODE 1 as an initial check on core conditions and design calculations at BOC. The SR is modified by a Note. The Note indicates that the normalization of predicted core reactivity to the measured value must take place within the first 60 effective full power days (EFPD) after each fuel loading . This allows sufficient time for core conditions to reach steady state, but prevents operation for a large fraction of the fuel cycle without establishing a benchmark for the design calculations. The required subsequent i;requenoy of 31 Ei;Po, following the initial 60 Ei;Po after entering MODE 1, is aooeptable, based on the slow rate of sore changes due to fuel depletion and the presence of other indicators (QPTR , Ai;o , eto.) for f*8fflf3t indication of an anomaly. 1'
!INSERT 3 !
REFERENCES 1 .UFSAR Section 3.1.
- 2. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.1-12 Revision No. Q
Rod Group Alignment Limits B 3.1.4 BASES ACTIONS D.2 (continued) The allowed Completion Time is reasonab le, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.1.4.1 REQUIREMENTS 1*
\ ~ rifisation that individual rod positions are within alignmm~t limits at a Frequensy of 12 hours provides a history that allows the operator to detest a rod that is beginning to deviate from its expested position. If the
!INSERT 3 1-j->~ rod position deviation monitor in inoperable, a frequensy of 4 hours assomplishes the same goal. The spesified Frequensy takes into assount other rod position information that is sontinuously available to the operator in the sontrol room , so that during astual rod motion , deviations san immediately be detested . SR 3.1.4.2 Verifying each control rod is OPERABLE would require that each rod be tripped . However, in MODES 1 and 2, tripping each control rod would result in radial or axial power tilts, or oscillations. Exercising each individual control rod every 92 days provides increased confidence that all rods continue to be OPERABLE without exceeding the alignment limit, even if they are not regularly tripped. Moving each control rod by 1O steps will not cause radial or axial power tilts, or oscillations , to occur. ~ The 92 day Frequensy takes into consideration other information ~- ..... - - ~ available to the operator in the control room and SR 3.1.4 .1, which is !INSERT 3 j performed more frequently and adds to the determination of OPERABILITY of the rods. Between required performances of SR 3.1.4.2 (determination of control rod OPERABILITY by movement), if a control rod(s) is discovered to be immovable by the normal CROM , but remains trippable, the control rod(s) is considered to be OPERABLE. At any time, if a control rod(s) is immovable by the normal CROM , a determination of the trippability (OPERABILITY) of the control rod(s) must be made, and appropriate action taken. (continued) HBRSEP Unit No. 2 B 3.1-28 Revision No. G
!no changes on this page I Shutdown Bank Insertion Limits B 3.1.5 BASES APPLICABILITY move, and requires the shutdown bank to move below the LCO (continued) limits, which would normally violate the LCO .
ACTIONS A.1 .1, A.1 .2 and A.2 When one or both shutdown banks is not within insertion limits, 2 hours is allowed to restore the shutdown banks to within the insertion limits. This is necessary because the available SOM may be significantly reduced , with one or more of the shutdown banks not within their insertion limits. Also , verification of SOM or initiation of boration within 1 hour is required , since the SOM *in MODES 1 and 2 is ensured by adhering to the control and shutdown bank insertion limits (see LCO 3.1.1 ). If shutdown banks are not within their insertion limits, then SOM will be verified by performing a reactivity balance calculation , considering the effects listed in the BASES for SR 3.1.1.1. The allowed Completion Time of 2 hours provides an acceptable time for evaluating and repairing minor problems without allowing the plant to remain in an unacceptable condition for an extended period of time. If the shutdown banks cannot be restored to within their insertion limits within 2 hours, the unit must be brought to a MODE where the LCO is not applicable. The allowed Completion Time of 6 hours.is reasonable , based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.1.5.1 REQUIREMENTS Verification that the shutdown banks are within their insertion limits prior to an approach to criticality ensures that when the reactor is critical , or being taken critical , the shutdown banks will be available to shut down the reactor, and the required SOM will be maintained following a reactor trip. This SR and Frequency ensure that the (continued) HBRSEP Unit No. 2 B 3.1-33 Revision No. O
Shutdown Bank Insertion Limits B 3.1.5 BASES in accordance SURVEILLANCES SR 3.1 .5.1 (continued) REQUIREMENTS with the Surveillance shutdown banks are withdrawn before the control banks are withd Frequency Control during a unit startup. Program Since the shutdown banks are positioned manually by the control room operator, a verification of shutdown bank position at a Frequency ef 12 hours, after the reactor is taken critical , is adequate to ensure that they are within their insertion limits. Also , the 12 hour rrequensy takes into assount other information available in the sontrol room for the purpose of monitoring the status of shutdown rods. ~ N_S..._ER_T_3--,I 1,--1 REFERENCES 1. UFSAR, Section 3.1.
- 2. 10 CFR 50.46 .
- 3. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.1-34 Revision No. G
Control Bank Insertion Limits B 3.1.6 BASES SURVEILLANCE SR 3.1 .6.1 (continued) REQUIREMENTS criticality could be an unnecessary burden . There are a number of unit parameters requiring operator attention at that point. Performing the ECP calculation within 4 hours prior to criticality avoids a large error from changes in xenon concentration , but allows the operator some flexibility to schedule the ECP calculation with other startup activities. SR 3.1.6.2 With an OPERABLE bank insertion limit monitor, verification of the control bank insertion limits at a rrequenoy of 12 hours is sufficient to ensure OPERABILITY of the bank insertion limit monitor and to detest control banks that may be approaching the insertion limits since, IINSERT 3 I normally, very little rod motion ooours in 12 hoursWlf the insertion limit monitor becomes inoperable, verification of the control bank position at a Frequency is sufficient to detect control banks that may be in accordance approaching th insertion limits. with the Surveillance Frequency Control SR 3.1.6.3 Program When control banks are maintained within their insertion limits as checked by SR 3.1.6.2 above, it is unlikely that their sequence and overlap will not be in accordance with requirements provided in the COLR. A Frequency of 12 hours is consistent with the insertion limit check above in SR 3.1.6.2. REFERENCES 1. UFSAR, Sections 3.1 .2.14, 3.1.2.27, 3.1.2.28, 3.1.2.29, 3.1.2.30 , 3.1.2.31 , and 3.1.2.32 .
- 2. 10 CFR 50.46 .
- 3. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.1-40 Revision No. G
PHYSICS TESTS Exceptions - MODE 2 B 3.1.8 BASES ACTIONS (continued) When the RCS lowest Tavg is< 530°F , the appropriate action is to restore T avg to within its specified limit. The allowed Completion Time of 15 minutes provides time for restoring Tavg to within limits without allowing the plant to remain in an unacceptable condition for an extended period of time. Operation with the reactor critical and with temperature below 530EF could violate the assumptions for accidents analyzed in the safety analyses. D.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within an additional 15 minutes. The Completion Time of 15 additional minutes is reasonable, based on operating experience, for reaching MODE 3 in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.1 .8.1 REQUIREMENTS The power range and intermediate range neutron detectors must be verified to by OPERABLE in MODE 2 by LCO 3.3.1, "Reactor Protection System (RPS) Instrumentation." A CHANNEL OPERATIONAL TEST is performed on each power range and intermediate range channel within 7 days prior to initiation of the PHYSICS TESTS . This will ensure that the RPS is properly aligned to provide the required degree of core protection during the performance of PHYSICS TESTS . The 7 day time limit is sufficient to ensure that the instrumentation is OPERABLE before initiating PHYSICS TESTS . SR 3.1.8.2 Verification that the RCS lowest loop T avg is 2: 530°F will ensure that the unit is not operating in a condition that could invalidate the safety analyses. Verification of the RCS temperature at a Frequency of ao minutes during the (continued) HBRSEP Unit No. 2 B 3.1-55 Revision No. Q
PHYSICS TESTS Exceptions - MODE 2 B 3.1.8 BASES SURVEILLANCE SR 3.1.8.2 (continued) REQUIREMENTS performance of the PHYSICS TESTS will ensure that the initial conditions of tRe *-Y aAalyses are Rot violaled .ll~ERT I 3 SR 3.1 .8.3 Verification that the THERMAL POWER is :5 5% RTP will ensure that the plant is not operating in a condition that could invalidate the safety analyses. Verification of THERMAL POWER at a frequency of 30 minutes during the performance of the PHYSICS TEST will ensure
\ .
that the initial conditions of the safety analyses are not violated . ~
, INSERT 3 SR 3.1.8.4 The SOM is verified by performing a reactivity balance calculation ,
considering the following reactivity effects:
- a. RCS boron concentration ;
- b. Control bank position ;
- c. RCS average temperature;
- d.
- Fuel burnup based on gross thermal energy generation;
- e. Xenon concentration ;
- f. Samarium concentration ; and
- g. Isothermal temperature coefficient (ITC) .
Using the ITC accounts for Doppler reactivity in this calculation because the reactor is subcritical , and the fuel temperature will be changing at the same rate as the RCS. The Frequency of 24 hours is based on the generally slow change in required boron concentration and on the low probability of an accident oGG*rriA~ witRo*t tRe re~*ired SOM. li~ERT I 3 ( continued) HBRSEP Unit No. 2 B 3.1-56 Revision No. 0
F0 (Z) B 3.2.1 BASES SURVEILLANCE last verified to be within specified limits. Because Fb (Z) REQUIREMENTS could not have previously been measured in this reload core, (continued) there is a second Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP . This ensures that some determination of Fb (Z) is made at a lower power level at which adequate margin is available before going to 100% RTP. Also, this Frequency condition , together with the Frequency condition requiring verification of Fb (Z) following a power increase of more than 10%, ensures that they are verified as soon as RTP (or any other level for extended operation) is achieved . In the absence of these frequency conditions, it is possible to increase power to RTP and operate for 31 days without verification o f ~ ~ The Frequency condition is not intended to require verification of these parameters after every 10% increase in power level above the last verification . It only requires verification after a power level is achieved for extended operation that is 10% higher than that power at which F O was last measured. SR 3.2.1.1 The nuclear design process includes calculations performed to determine that the core can be operated within the F 0 (Z) limits. Because flux maps are taken in steady state conditions, the variations in power distribution resulting from normal operational maneuvers are not present in the flux map data. These variations are, however, conservatively calculated by considering a wide range of unit maneuvers in normal operation . The maximum peaking factor increase over steady state values, calculated as a function of core elevation , Z, is called V(Z). Multiplying the measured total peaking factor, Fg (Z) , by V(Z) gives the maximum F 0 (Z) calculated to occur in normal operation , Fb (Z) . The limit with which Fb (Z) is compared varies inversely with power and directly with the function K(Z) provided in the COLR. The V(Z) curve is provided in the COLR for discrete core elevations. Flux map data are typically taken for 30 to 75 core elevations. Fb (Z) evaluations are not applicable for the following axial core regions , measured in percent of core height: (continued) HBRSEP Unit No. 2 B 3.2-7 Revision No. Q
F0 (Z) B 3.2.1 BASES SURVEILLANCE SR 3.2.1.1 (continued) REQUIREMENTS
- a. Lower core region , from O to 10% inclusive; and
- b. Upper core region , from 90 to 100% inclusive.
The top and bottom 10% of the core are excluded from the evaluation because of the low probability that these regions would be more limiting in the safety analyses and because of the difficulty of making a precise measurement in these regions. Performing the Surveillance in MODE 1 prior to exceeding 75% RTP ensures that the F 0 (Z) limit is met when RTP is achieved , because peaking factors are generally decreased as power level is increased. F 0 (Z) is verified at power levels ~ 10% RTP above the THERMAL POWER of its last verification , 12 hours after achieving equilibrium conditions to ensure that F 0 (Z) is within its limit at higher power levels. The Surveillance rrequenoy of 31 ErPD is adequate to monitor the change of power distribution with sore burnup. The Surveillance may be done more frequently if required by the results of F 0 (Z) evaluations. T he r requenoy of 31 ErPD is adequate to monitor the change of power distribution because such a change is sufficiently slow, when the plant is operated in accordance with the TS , to preclude adverse peaking factors Oetweea 31 <lay """"'illaRGe&. ~Z';iERT I
- 3 REFERENCES 1. 10 CFR 50.46 , 1974.
- 2. UFSAR Section 4.4.2.1.
- 3. UFSAR Section 15.4.8.
- 4. UFSAR Section 3.1.
HBRSEP Unit No. 2 B 3.2-8 Revision No. G
F~H 8 3.2.2 BASES SURVEILLANCE SR 3.2.2.1 (continued) REQUIREMENTS reduction computer program then calculates the maximum value of F~ H from the measured flux distributions. The measured value of F~ H must be multiplied by 1.04 to account for measurement uncertainty before making comparisons to the F~ H limit. This Surveillance is modified by a Note that may require that the evaluation of F~ (Z) against its limits be performed with a penalty factor or that more frequent surveillances be performed . If F~ H is within limits and measurements indicate that F~ H is increasing with exposure, then F~ (Z) is increased by a factor of 1.02 , and F~ (Z) is then reverified to be within limits: or, SR 3.2.1.1 and SR 3.2.3.3 are ferformed once per 7 EFPDs until two successive measurements of Fti H show that F~ H is not increasing . These alternative requirements prevent F~ (Z) from exceeding its limit for any significant period of time during the surveillance interval. After each refueling , F~ H must be determined in MODE 1 prior to exceeding 75% RTP . This requirement ensures that F~ H limits are met at the beginning of each fuel cycle. The 31 Ef PD frequency is acceptable because the power distribution changes relatively slowly over this amount of fuel burnup . Accordingly, this frequency is short enough that the FiA-l-1 limit cannot be mmeeded for any significant period of operation . REFERENCES 1. UFSAR Section 4.4.2.1. INSERT 3
- 2. UFSAR Section 15.4.8.
- 3. UFSAR Section 3.1.
- 4. 10 CFR 50.46.
HBRSEP Unit No. 2 8 3.2-16 Revision No. G
AFD B 3.2.3 BASES ACTIONS D.1 (continued) Reducing the power level to < 15% RTP within the Completion Time of 9 hour$ and complying with LCO penalty deviation time requirements for subsequent increases in THERMAL POWER ensure that acceptable xenon conditions are restored . This Required Action must also be implemented either if the cumulative penalty deviation time is > 1 hour during the previous 24 hours, or the AFD is not within the target band and not within the acceptable operation limits. Condition Dis modified by a Note that requires Action D.1 be completed whenever this Condition is entered . SURVEILLANCE SR 3.2.3.1 REQUIREMENTS The AFD is monitored on an automatic basis using the unit process computer that has an AFD monitor alarm . The computer determines the 1 minute average of each of the OPERABLE excore detector outputs and
- provides an alarm message immediately if the AFDs for two or more OPERABLE excore channels are outside the target band and the THERMAL POWER is > 90% RTP or 0.9 APL, whichever is less. During operation at THERMAL POWER levels < 90% RTP or 0.9 APL,
- whi chever is less but > 15% RTP, the computer sends an alarm message when the cumulative penalty deviation time is > 1 hour in the previous 24 hours.
This Surveillance verifies that the AFD as indicated by the NIS excore channels is within the target band and consistent with the status of the AFD monitor alarm . The Surveillance r"requency of 7 days is adequate because the ArD is controlled by the operator and monitored by the process computer. rurthermore, any deviations of the ArD from the ta,get baA8 that is Rot ala"'1e8 sho"l8 Be ,ea8ily Aolise8 . ~ERT I 3 SR 3.2.3.2 With the AFD monitor alarm inoperable, the AFD is monitored to detect operation outside of the target band and to compute the penalty deviation time. During operation at~ 90% RTP or 0.9 APL, whichever is less, the AFDis (continued) HBRSEP Unit No. 2 B 3.2-23 Revision No. G
AFD B 3.2.3 BASES SURVEILLANCE SR 3.2.3.2 (continued) REQUIREMENTS monitored at a Surveillance Frequency of 15 minutes to ensure that the AFD is within its limits at high THERMAL POWER levels. At power levels
< 90% RTP or 0.9 APL, whichever is less, but> 15% RTP , the Surveillance Frequency is reduced to. 1 hour because the AFD may deviate from the target band for up to 1 hour using the methodology of Parts B and C of this LCO to calculate the cumulative penalty deviation time before corrective action is required .
SR 3.2.3.2 is modified by a Note that states that monitored and logged values of the AFD are assumed to exist for the preceding 24 hour interval in order for the operator to compute the cumulative penalty deviation time. The AFD should be monitored and logged more frequently in periods of operation for which the power level or control bank positions are changing to allow corrective measures when the AFD is more likely to move outside the target band. SR 3.2.3.3 Measurement of the target flux difference is accomplished by taking a flux map when the core is at equilibrium xenon conditions, preferably at high power levels with the control banks nearly withdrawn . This flux map provides the equilibrium xenon axial power distribution from which the target value can be determined . The target flux difference varies slowly with core burnup. A Frequency of 31 EFPD after each refueling and 31 EFPD thereafter for feffieasuring the target flux differences adjusts the target flux difference for each excore channel to the value measured at steady state
~
-~
A Note modifies this SR to allow the predicted beginning of cycle AFD from the cycle nuclear design to be used to determine the initial target flux difference after each refueling . A second Note modifies this SR to require that the target flux difference be determined in conjunction with the measurement of the heat flux hot channel factor, F 0 (Z), in accordance with SR 3.2.1.1. This is a requirement of the PDC-3 Axial Offset Control Methodology. (continued) HBRSEP Unit No. 2 B 3.2-24 Revision No. e
QPTR B 3.2.4 BASES SURVEILLANCE SR 3.2.4.1 (continued) REQUIREMENTS performance of SR 3.2.4.2 in lieu of SR 3.2.4.1. This Surveillance verifies that the QPTR, as indicated by the Nuclear Instrumentation System (NIS) excore channels or Emergency Response Facility Information System (ERFIS) , is within its limits. The Frequency of 7 days when the QPTR alarm is OPERABLE is acceptable because of the low probability that this alarm can remain inoperable without detection. ~ VI/hen the QPTR alarm is inoperable, the Frequenoy is inoreased to 12 hours. This Frequency is adequate to detect any relatively slow changes in QPTR , because for those causes of QPT that occur quickly (e.g., a dropped rod), there typically are other indications of abnormality that prompt a verification of core po11.ier tilt. SR 3.2.4.2 This Surveillance is modified by a Note, which states that it is not
.. ,. required until 12 hours after the input from one or niore Power Range Neutron Flux channels are inoperable and the* THERMAL POWER is
~ 75% RTP .
With an NIS power range channel inoperable, tilt monitoring for a portion of the reactor core becomes degraded . Large tilts are likely detected with the remaining channels, but the capability for detection of small power tilts in some quadrants is decreased . Performing SR 3.2.4 .2 at a Frequency of 12 hours provides an accurate alternative means for ensuring that any tilt remains wit.hin its limits. ~SERT ! 3 For purposes of monitoring the QPTR when one power range channel is inoperable, the moveable incore detectors are used to confirm that the normalized symmetric power distribution is consistent with the indicated QPTR and any previous data indicating a tilt. The symmetric thimble flux map can be used to generate symmetric thimble "tilt." This can be compared to a reference symmetric thimble tilt, from the most recent full (continued) HBRSEP Unit No. 2 B 3.2-32 Revision No. G
RPS Instrumentation B 3.3 .1 BASES SR 3.3.1.1 Performance of the CHANNEL CHECK once every 12 hours ensures that gross failure of instrumentation has not occurred . A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure ; thus, it is key to verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION . Deviation criteria are determined by the unit staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria , it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal , but more frequent, checks of channels during normal operational use of tRo Ois~lays assooiatOO witR tRe LGO req"ireO oRaaaols. ~ERT I 3 SR 3.3.1.2 SR 3.3.1.2 compares the calorimetric heat balance calculation to the NIS channel output every 24 hours. If the calorimetric exceeds the NIS channel output by> 2% RTP , the NIS is not declared inoperable, but must be adjusted . If the NIS channel output cannot be properly adjusted, the channel is declared inoperable. Two Notes modify SR 3.3.1 .2. The first Note indicates that the NIS channel output shall be adjusted consistent with the calorimetric results if the absolute difference between the NIS channel output and the calorimetric is > 2% RTP. The second Note clarifies that this Surveillance is required only if reactor power is;:: 15% RTP and that 12 (continued) HBRSEP Unit No. 2 B 3.3-47 Revision No. G;-4-e Amendment No. 4QG
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1 .2 (continued) REQUIREMENTS hours are allowed for performing the first Surveillance after reaching 15% RTP . At lower power levels, calorimetric data are inaccurate. The Frequency of every 24 hours is adequate. It is based on unit operating experience, considering instrument reliability and operating history data for instrument drift. Together these factors demonstrate the change in the absolute difference bet\*;een NIS and heat balance calculated powers rarely exceeds 2% in any 24 hour period . In addition , control room operators periodically monitor redundant indications and alarFRs to Eietest Eieviations in shannel o"tP"ts. ):SERT I 3 SR 3.3.1.3 SR 3.3.1 .3 compares the incore system to the NIS channel output ev-ery
. 31 EFPD. If the absolute difference is~ 3% , the NIS channel is still OPERABLE, but must be readjusted.
If the NIS channel cannot be properly readjusted, the channel is declared inoperable. This Surveillance is performed to verify the f(Lll) input to the overtemperature and overpower Ll T Functions. Two Notes modify SR 3.3.1.3. Note 1 indicates that the excore NIS channel shall be adjusted if the absolute difference between the incore and excore AFD is ~ 3%. Note 2 clarifies that the Surveillance is required only if reactor power is ~ 15% RTP and that 36 hours is allowed for performing the first Surveillance after reaching 15% RTP. The Frequency of every 31 EFPD is adequate. It is based on industry operating experience, considering instrument reliability and operating history data for instrument drift. Also , the slow changes in neutron flux during the fuel cycle can be detected during this interval ' - ....~ - - - , (@ERT3! (continued) HBRSEP Unit No. 2 B 3.3-48 Revision No. ~ Amendment No. 1QO
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1.4 REQUIREMENTS (continued) SR 3.3.1.4 is the performance of a TADOT every 31 days on a STAGGERED TEST BASIS . This test shall verify OPERABILITY by actuation of the end devices. The RTB test shall include separate verification of the undervoltage and shunt trip mechanisms. Independent verification of RTB undervoltage and shunt trip Function is not required for the bypass breakers. No capability is provided for performing such a test at power. The independent test for bypass breakers is included in SR 3.3.1.14. The bypass breaker test shall include a local shunt trip. A Note has been added to indicate that this test must be performed on the bypass breaker prior to placing it in service. The Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based on industry operating experience, considering iRslrumeRI ,eliability aREI operatiRg history Elala . @SERT I 3 SR 3.3.1.5 SR 3.3.1 .5 is the performance of an ACTUATION LOGIC TEST. The RPS is tested every 31 days on a STAGGERED TEST BASIS. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation . All possible logic combinations, with and without applicable permissives, are tested for each protection function . The Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based on industry operating experience, considering instrument reliability arid operating history data. ~ INSERT ! 3 A note is added to SR 3.3.1.5 stating that the SR is not requ ired to be performed for the source range neutron flux detector channels prior to entry into MODE 3 from MODE 2 until 4 hours after entry into MODE 3. This Note allows normal shutdown to proceed without delay for testing in MODE 2 and in MODE 3 until the RTBs are open and SR 3.3.1.5 is no longer required to be performed (i.e., the 4 hour delay allows a normal shutdown to be completed without a required hold on power reduction to perform the testing required by this SR) . If the unit is in MODE 3 with the RTBs closed for greater than 4 hours, this SR must be performed prior to 4 hours after entry into MODE 3. (continued) HBRSEP Unit No. 2 B 3.3-49 Revision No. G;-4e Amendment No. 49G
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1.6 REQUIREMENTS (continued) SR 3.3.1.6 is a calibration of the excore channels to the incore channels. If the measurements do not agree, the excore channels are not declared inoperable but must be calibrated to agree with the incore detector measurements. If the excore channels cannot be adjusted , the channels are declared inoperable. This Surveillance is performed to verify the f(lil) input to the overtemperature and overpower li T Functions. A Note modifies SR 3.3.1.6. The Note states that this Surveillance is required only if reactor power is> 50% RTP and that 24 hours is allowed for performing the first surveillance after reaching 50% RTP . The F"requency of Q2 EF"PD is adequate. It is based on industry operating experience, considering instrument reliability and operating history 8ata !or iastr"meat 8rill. [wsERT I 3 SR 3.3.1.7 SR 3.3.1.7 is the performance of a COT every Q2 days. A COT is performed on each requ ired channel to ensure the entire channel will perform the intended Function . Setpoints must be within the Allowable Values specified in Table 3.3.1-1. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 8) . The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology (Ref. 8) . The "as found" and "as left" values must also be recorded and reviewed for consistency with the assumptions of Reference 7. SR 3.3.1.7 is modified by a Note that provides a 4 hour delay in the requirement to perform this Surveillance for source range instrumentation when entering MODE 3 from MODE 2. This Note allows a normal shutdown to proceed without ( continued) HBRSEP Unit No. 2 B 3.3-50 Revision No. O
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1.7 (continued) REQUIREMENTS a delay for testing in MODE 2 and for a short time in MODE 3 until the RTBs are open and SR 3.3.1.7 is no longer required to be performed (i.e. , the 4 hour delay allows a normal shutdown to be completed without a required hold on power reduction to perform the testing required by this SR) . In addition , performing the COT of the source range instrumentation prior to entry into MODE 3 from MODE 2 may increase the probability of a reactor trip . If the unit is to be in MODE 3 with the RTBs closed for > 4 hours this Surveillance must be performed prior to 4 hours after entry into MODE 3. The FroqYCRG!f el 92 days is j Ystified ia Referoase ~;N~ ERT I 3 SR 3.3.1.8 SR 3.3.1.8 is the performance of a COT as described in SR 3.3.1.7, except it is modified by a Note that this test shall include verification that the P-6 and P-10 interlocks are in their required state for the existing unit condition . The Frequency is modified by a Note that allows this surveillance to be satisfied if it has been performed with* 92 days of the frequencies prior to reactor startup a s after reducing power the Frequency specified in below P-10 and P- uency of "prior to startup" ensures this the Surveillance _s.uni:e!H1!n1~1s performed prior to critical operations and applies to the Frequency Control source, intermediate and power range low instrument channels. The Program Frequency of "4 hours after reducing power below P-10" (applicable to intermediate and power range low channels) and "4 hours after reducing power below P-6" (applicable to source range channels) allows a normal shutdown to be completed and the unit removed from the MODE of Applicability for this surveillance without a delay to perform the testing required by this surveillance. The Frequency of every 92 days thereafter applies if the plant remains in the MODE of Applicability after the initial performances of prior to reactor startup and four hours after reducing power below P-10 or P-6. The MODE of Applicability for this surveillance is < P-10 for the power range low and intermediate range channels and < P-6 for the source range channels. Once the unit is in MODE 3, this surveillance is no longer required . If power is to be maintained < P-10 or < P-6 for more than 4 hours, then the (continued) HBRSEP Unit No. 2 B 3.3-51 Revision No. G
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3 .1.8 (continued) REQUIREMENTS testing required by this surveillance must be performed prior to the expiration of the 4 hour limit. Four hours is a reasonable time to complete the requ ired testing or place the unit in a MODE where this surveillance is no longer required . This test ensures that the NIS source, intermediate, and power range low channels are OPERABLE prior to taking the reactor critical and after reducing power into the applicable MODE(< P-10 or< P-6) for periods> 4 hours. '
~pN....,_S_E-RT~3I SR 3.3.1 .9 SR 3.3.1.9 is the performance of a TADOT an is performed every 92 days, as justified in Reference 7.
The SR is modified by a Note that excludes verification of setpoints from the TADOT . Since this SR applies to RCP undervoltage and underfrequency relays , setpoint verification requires elaborate bench calibration and is accomplished during the CHANNEL CALIBRATION . SR 3.3.1.10
/\ CHANNEL C/\LIBR/\TION is performed every 18 months, or approximately at every refueling . CHANNEL CALIBRATION is a complete check of the instrument loop , including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology (Ref. 8). The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 8) . The Frequency of 18 months is based on the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology (Ref. 8) . ,,........__*_ __,
@SERT 3!
(continued) HBRSEP Unit No. 2 B 3.3-52 Revision No. G
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3 .1.10 (continued) REQUIREMENTS SR 3.3.1 .10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. This Note applies to those Functions equipped with electronic dynamic compensation . Not all Functions to which SR 3.3.1.10 is applicable are equipped with electronic dynamic compensation. SR 3.3.1.11 SR 3.3.1.11 is the performance of a CHANNEL CALIBRATION , as described in SR 3.3.1.10, every 18 months. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION . The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux map performed above 15% RTP . The CHANNEL CALIBRATION for the source range and intermediate range neutron detectors consists of obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors. +Re 48-month F"requency is based on industry operating experience, considering instrument reliabi lity and operating history data. Operating experience has shown these components usually pass the Surveillance whoa ~ell<m.,ed oa the 16 moath F,eqyeasy. @SERT ] 3 SR 3 .3.1.12 SR 3.3.1 .12 is the performance of a CHANNEL CALIBRATION , as described in SR 3.3.1.10, every 18 months. For Table 3.3.1-1 Functions 5 and 6, the CHANNEL CALIBRATION shall include a narrow range RTD cross calibration . This SR is modified by a Note stating that this test shall include verification of the electronic dynamic compensation time constants and the RTD response time constants. The RCS (continued) HBRSEP Unit No. 2 B 3.3-53 Revision No. Q
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1.12 (continued) REQUIREMENTS narrow range temperature sensors response time shall be :5 a 4.0 second
- lag time constant.
The Frequency is justified by the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. rr§s:ERT ! 3 SR 3.3.1 .13 SR 3.3.1.13 is the performance of a COT of RPS interlocks evep;- 18 months. The Frequency is based on the known reliability of the interlocks and the multichannel redundancy available, and has been shown to be aGGeplable IAraugA aperaling e*periensejl~ERT I 3 SR 3.3.1.14 SR 3.3.1.14 is the performance of a TADOT of the Manual Reactor Trip , RCP Breaker Position , and the SI Input from ESFAS and the P-7 interlock. This TADOT is performed every 18 months. The test shall independently verify the OPERABILITY of the undervoltage and shunt trip mechanisms for the Manual Reactor Trip Function for the Reactor Trip Breakers and the undervoltage trip mechanism for the Reactor Trip Bypass Breakers. The test shall also independently verify the OPERABILITY of the low power reactor trip block from the Power Range Neutron Flux (P-10) interlock and turbine first stage pressure. The TADOT verifies that when either the Turbine Impulse Pressure inputs or the Power Range Neutron Flux (P-10) interlock engage, reactor trips that are blocked by P-7 are enabled . The Frequency is based on the known reliability of the Functions and the multichannel redundancy available, and has been shown to be asooplabla lAraugA aparaling e*periense. ~SERT I 3 (continued) HBRSEP Unit No. 2 B 3.3-54 Revision No. 0
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE A Note (Note 1) has been added to the SR Table to clarify REQUIREMENTS that Table 3.3.2-1 determines which SRs apply to which ESFAS (continued) Functions. Note that each channel of process protection supplies both trains of the ESFAS. When testing channel I, train A and train B must be examined . Similarly, train A and train B must be examined when testing channel II , channel Ill , and channel IV (if applicable) . The CHANNEL CALIBRATION and COTS are performed in a manner that is consistent with the assumptions used in analytically catculating the required channel accuracies. The Surveillances are also modified by Note 2 to indicate that when a channel is placed in an inoperable status solely for the performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours provided the redundant ESFAS train is OPERABLE. Upon completion of the Surveillance or expiration of the 6 hour allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and the Required Actions performed . If maintenance is to be subsequently performed as a result of a failed surveillance test, LCO 3.3,2 ACTIONS are applicable. Note 2 to the Surveillance Requirements is based on operating history which has shown that.6 hours is generally the time .required to perform the channel surveillance with additional time to allow for short term plant changes or verification of any abnormal responses. This 6 hour testing allowance does not significantly reduce the probability that the ESFAS will initiate when necessary. SR 3.3.2.1 Performance of the CHANNEL CHECK once every 12 hours ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure: thus, it is key to verifying the (continued) HBRSEP Unit No. 2 B 3.3-86 Revision No. G
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR 3.3.2.1 (continued) REQUIREMENTS instrumentation continues to operate properly between each CHANNEL CALIBRATION. Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and reliability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. The rrequency is based on operating experience that demonstrates channel failure is rare. The CHAN~JEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of
!Re <l isplays assasiale<l .wilR tRe LGO "'~"ire<I sRaRRels. IT[SERT j 3
SR 3.3.2.2 SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST. TRe ESr relay logic is tested every 31 days on a STAGGERED TEST BASIS. The train being tested is placed in the test condition. All possible logic combinations , with and without applicable permissives, are tested for each protection function. In addition, *the master relay coil is tested for continuity. This verifies that the logic modules are OPERABLE and that there is an intact voltage signal path to the master relay coils. TRe Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based on industry operating experience, eonsidering iRslr""'""I reliability aR<i aperatiR~ Rista,y <lata. ~ERT j 3 SR 3.3.2.3 SR 3.3.2.3 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay. The master relay is actuated by either a manual or automatic initiation of the function being tested. Contact operation is verified either by a continuity check of the circuit containing the master relay or proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 18 months. The 18 month rrequency is adequate, based on (continued) HBRSEP Unit No. 2 B 3.3-87 Revision No. O
ESFAS Instrumentation B 3 .3.2 BASES SURVEILLANCE SR 3.3.2 .3 (continued) REQUIREMENTS industry operating experience, and is consistent with the typical refueling Gl'*le, wAisA provi8es tAe plaat saa8itiaas aesessary far testiag . lSERT I 3 SR 3 .3.2.4 SR 3 .3.2.4 is the performance of a COT. A COT is performed on each required channel to ensure the entire channel , with the exception of the transmitter sensing device, will perform the intended Function. Setpoints must be found within the Allowable Values specified in Table 3 .3.2- 1. The difference between the current "as found " values and the previous test "as left" va lues must be consistent with the drift allowance used in the setpoint methodology (Ref. 9). The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology (Ref. 9) .
- The "as found" and "as left" values must also be recorded and reviewed for consistency with the assumptions of the surveillance interval extension analysis in WCAP- 10271-P-A (Ref. 8) when applicable.
TAe Fre~ueRG\' al 92 day& isjustifie8 iR Refereaoo \ ~ERT l 3 SR 3.3.2.5 SR 3 .3.2.5 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays . Contact operation is verified either by a continuity check of the circuit containing the slave relay, or by verification of proper operation of the end device during supported equipment simulated or actual automatic actuation test. +rus test is performed every 18 months. The 18 month rrequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary far testiag. ~SERT 31 (continued) HBRSEP Unit No. 2 B 3.3-88 Revision No. G
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR 3.3.2 .6 REQUIREMENTS (continued) SR 3.3.2.6 is the performance of a TADOT. This test is a check of Manual Actuation Functions. It is performed ei.*ery 18 months. Each Manual Actuation Function is tested up to, and including, the master relay coils. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.). The Frequency is adequate, based on industry operating experience and is consistent with the typical refueling cycle. ~ The SR is modified by a Note that excludes verification of setpoints during ~ the TADOT for manual initiation Functions. The manual initiation Functions have no associated setpoints. SR 3.3.2.7 SR 3.3.2.7 is the performance of a CHANNEL CALIBRATION . A CHANNEL CALIBRATION is performed every 18 months, or approximately at e11ery refueling . CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy. CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology (Ref. 9). The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The Frequency of 18 months is based on the assumption of an 18 month' oalibration interval in the determination of the magnitude of equipment Elrill iA !Re set~eiat metAeElelegy. v@s INSERT 3! REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 7.
- 3. UFSAR, Chapter 15.
- 4.
- UFSAR, Section 3.1.
(continued) HBRSEP Unit No. 2 B 3.3-89 Revision No. G
PAM Instrumentation B 3.3.3 BASES ACTIONS (continued) Condition H applies to the Containment Sump Water Level , Containment Pressure , Containment Area Radiation , Auxiliary Feedwater Flow, PORV Position , PORV Block Valve Position , and Safety Valve Position Functions, which have alternate monitoring means available for use. These alternate means may be temporarily installed if the normal PAM channel cannot be restored to OPERABLE status within the allotted time. If these alternate means are used , the Required Action is not to shut down the unit but rather to follow the directions of Specification 5.6.6, in the Administrative Controls section of the TS. The report provided to the NRC should discuss the alternate means used, describe the degree to which the alternate means are equivalent to the installed PAM channels, justify the areas in which they are not equivalent, and provide a schedule for restoring the normal PAM channels . SURVEILLANCE A Note has been added to the SR Table to clarify that REQUIREMENTS SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1 ; except Function 9, Containment Isolation Valve Position; Function 22, PORV Position (Primary); Function 23, PORV Block Valve Position (Primary) ; and Function 24, Safety Valve Position (Primary) . SR 3.3.3.3 applies only to Functions 9, 22 , 23, and 24. SR 3.3.3.1 Performance of the CHANNEL CHECK once every 31 days ensures that a gross instrumentation failure has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure ; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. The high radiation instrumentation (continued) HBRSEP Unit No. 2 B 3.3-106 Revision No. ~
PAM Instrumentation B 3.3.3 BASES SURVEILLANCE SR 3.3.3.1 (continued) REQUIREMENTS should be compared to similar unit instruments located throughout the unit. Channel deviation criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria , it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria , it is an indication that the channels are OPERABLE. As specified in the SR, a CHANNEL CHECK is only required for those channels that are normally energized . The Frequency of 31 days is based on operating mcperience that demonstrates that channel failure is rare. The Cl=IAN~JEL Cl=IECK supplements less formal , but more frequent, cheeks of ohannels during normal operational use of the displays assooiated with the LCO required ohannels. r::sERT ! 3 SR 3.3.3.2 A Cl=IA~JNEL CALIBRATIO~J is performed every 1B months, or approximately at every refueling . CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by a Note that excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1 , "Reactor Protection System (RPS) Instrumentation." The Frequenoy is based on operating experienoe and soRsis!eRsy wilh lhe lypisal iRd"s!ry ref"eliR§ sysle. (!NsERT I 3 SR 3.3.3.3 SR 3.3.3.3 is the performance of a TADOT of containment isolation valve position indication , PORV position (primary) indication, PORV block valve position (primary) indication, and safety valve position (primary) indication. This TADOT is performed every 18 months. The test shall independently (continued) HBRSEP Unit No. 2 B 3.3-107 Revision No. G
PAM Instrumentation B 3.3.3 BASES SURVEILLANCE SR 3.3.3.3 (continued) REQUIREMENTS verify the OPERABILITY of position indication against the actual position of the associated valves. The r"requency is based upon the known reliability of the runctions and has been shown to be acceptable through operating m<perience. ~
. INSERT 3!
The SR is modified by a Note that excludes verification of setpoints from the TADOT. The affected Functions have no setpoints. REFERENCES 1. NRC Safety Evaluation Report, H. B. Robinson Steam Electric Plant Unit No. 2, Docket No. 50-261 , Conformance to Regulatory Guide 1.97, transmitted to CP&L by letter dated March 5, 1987.
- 2. Regulatory Guide 1.97 , Revision 3, May 1983.
- 3. NUREG-0737 , Supplement 1, "TMI Action Items."
- 4. CP&L Letter to NRC , "Inadequate Core Cooling Instrumentation, Generic Letter 82-28 , NUREG-0737, Item 11.F.2, Implementation Letter/License Amendment Request," dated September 16, 1987.
- 5. CP&L letters dated December 31 , 1984, July 18, 1985, July 28, 1985, May 1, 1987, September 9, 1987, and September 14, 1999, regarding the HBRSEP Regulatory Guide 1.97 submittal.
HBRSEP Unit No. 2 B3.3-108 Revision No. ~
Remote Shutdown System B 3.3.4 BASES ACTIONS B.1 and B.2 (continued) If the Required Action and associated Completion Time of Condition A is not met, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status , the unit must be brought to at least MODE 3 within 6 hours and to MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.3.4.1 REQUIREMENTS Performance of the CHANNEL CHECK once every 31 days ensures that a gross failure of instrumentation has not occurred . A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION . Channel deviation criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If the channels are within the criteria, it is an indication that the channels are OPERABLE. If a channel is outside the criteria , it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. As specified in the Surveillance, a CHANNEL CHECK is only required for those channels which are normally energized. The i;requency of 31 days is based upon operating experience which demonstrates that channel fai lure is rare. The CHA~JNEL CHECK supplements less formal , but more frequent , checks of channels during normal operational use of the displays assosialeEI witR !Re LGO reqYireEI sRaaaels. n@ERT I 3 (continued) HBRSEP Unit No. 2 B 3.3-112 Revision No. G
Remote Shutdown System B 3.3.4 BASES SURVEILLANCE SR 3.3.4.2 REQUIREMENTS (continued) SR 3.3.4.2 verifies each required Remote Shutdown System control circuit and transfer switch performs the intended function . This verification is performed from the remote shutdown panel and locally, as appropriate. Operation of the equipment from the remote shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the unit can be placed and maintained in MODE 3 from the remote shutdown panel and the local control stations. The 18 month rrequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. (However, this Surveillance is not requ ired to be performed only during a unit outage.) Operating e>Eperience demonstrates that remote shutdown control channels usually pass the Surveillance test when performed at the 18 month rrequency. ~ .....----'----,
~ERT3!
SR 3.3.4 .3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. The rrequency of 18 months is based upon operating e>Eperience and GGRSisleRGl' wltR tile ty~isal iml"stl)I ,eh.Jeliag Gl'*le. rsERT I 3 SR 3.3.4.4 SR 3.3.4.4 is the performance of a TADOT e*.iery 18 months. This test should verify the OPERABILITY of the reactor trip breakers (RTBs) open and closed indication on the remote shutdown panel , by actuating the RTBs. The rrequency is based upon operating e>Eperience and consistency with the typical industry refueling outage. %SERT ! 3 REFERENCES 1. UFSAR, Section 7.4.1. HBRSEP Unit No. 2 B 3.3-113 Revision No. G
LOP DG Start Instrumentation B 3.3.5 BASES ACTIONS 8.1 (continued) The specified Completion Time and time allowed for tripping one channel are reasonable considering the Function remains fully OPERABLE on every bus and the low probability of an event occurring during these intervals. Condition C applies when more than one degraded voltage channel on a single bus is inoperable.
, Required Action C.1 requires restoring all but one channel on each bus to
. OPERABLE status. The 1 hour Completion Time should allow ample time to repair most failures and takes into account the low probability of an event requiring an LOP start occurring during this interval.
D.1 Condition D applies to each of the LOP DG start Functions when the Required Action and associated Completion Time for Condition A, B, or C are not met. In these circumstances the Conditions specified in LCO 3.8.1, "AC Sources - Operating ," or LCO 3.8.2, "AC Sources - Shutdown," for the DG made inoperable by failure of the LOP DG start instrumentation are required to be entered immediately. The actions of those LCOs provide for adequate compensatory actions to assure unit safety. SURVEILLANCE SR 3.3.5.1 REQUIREMENTS SR 3.3.5.1 is the performance of a TADOT. This test is performed every 18 months. The test checks trip devices that provide actuation signals directly, bypassing the analog process control equipment. :+Re Frequency is based on the known reliability of the relays and controls and the multichannel redundancy available, and has been shown to be acceptable through operating experience. ~ ....___.~---,
~ERT3!
(continued) HBRSEP Unit No. 2 B 3.3-119 Revision No. G
LOP DG Start Instrumentation B 3.3.5 BASES SURVEILLANCE SR 3.3.5.1 (continued) REQUIREMENTS The SR is modified by a Note that excludes verification of the setpoint from the TADOT. Setpoint verification is accomplished during the CHANNEL CALIBRATION . SR 3.3.5.2 SR 3.3.5.2 is the performance of a CHANNEL CALIBRATION. The setpoints, as well as the response to a loss of voltage and a degraded voltage test, should include a single point verification that the trip occurs within the required time delay, as shown in Reference 1. A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling . CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and .accuracy. The Frequency of 18 months is based on operating experience and consistency 1.vith the typical industry refueling cycle and is justified by the assumption of an 18 month calibration interval in the determination of the "1agai!Y<le of eq"ip"1eRI dFift ia the setpeial aaalysis. lmsERT I 3 REFERENCES 1. UFSAR, Section 8.3.
- 2. Calculation RNP-E-8.002, AC Auxiliary Electrical Distribution System Voltage/Load Flow/Fault Current Study
- 3. UFSAR, Chapter 15.
- 4. EGR-NGGC-0153, Engineering Instrument Setpoints
- 5. RNP-I/INST-1010, Emergency Bus- Degraded Grid Voltage Relay HBRSEP Unit No. 2 B 3.3-120 Revision No. ae
Containment Ventilation Isolation Instrumentation B 3.3.6 BASES ACTIONS A.1 and A.2 (continued) position is met, and the applicable Conditions of LCO 3.9.3, "Containment Penetrations," are met for each valve made inoperable by failure of isolation instrumentation . The Completion Time for these Required Actions is Immediately. SURVEILLANCE A Note has been added to the SR Table to clarify that REQUIREMENTS Table 3.3.6-1 determines which SRs apply to which Containment
- Ventilation Isolation Functions.
SR 3.3.6.1 Performance of the CHANNEL CHECK once every 12 hours ensures that a gross failure of the radiation monitor instrumentation has not occurred . The Frequency is based on operating e:><perience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal , but more frequent, checks of channels during normal operational use of tAe displays assesiated ~ilA IAe LGO re~"ired sAaaaels. [Ns"ERT I 3 SR 3.3.6.2 SR 3.3.6.2 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the test condition . All possible logic combinations, with and without applicable permissives , are tested for each protection function . In addition, the master relay coil is tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils . This test is performed every 31 days on a STAGGERED TEST BASIS. The Surveillance interval is acceptable based on instrument reliability and iad"stry eperatiag e*periease. !WSERT I 3 SR 3.3.6.3 SR 3.3.6.3 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay. (continued) HBRSEP Unit No. 2 B3.3-125 Revision No. G
Containment Ventilation Isolation Instrumentation B 3.3.6 BASES SURVEILLANCE SR 3.3.6.3 (continued) REQUIREMENTS The master relay is actuated by either a manual or automatic initiation of the function being tested. Contact operation is verified either by a continuity check of the circuit containing the master relay or proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 18 months. The 18 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which
~re,i8es l~e ~laAI GOA8iliaas aesessa,y far tesliag . ~ERT I 3
SR 3.3.6.4 A COT is performed every Q2 days on each required channel to ensure the entire channel will perform the intended Function . The Frequency is based on the staff recommendation for increasing the availability of radiation monitors according to t>JUREG 1366 (Ref. 2) . his test verifies the capability of the radiation monitor instrumentation to itiate Containment Ventilation System isolation. The setpoint s uld be left consist~nt with the calibration procedure tolerance. INSERT 3 SR 3.3.6.5 SR 3.3.6.5 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified either by a continuity check of the circuit containing the slave relay, or by verification of proper operation of the end device during the supported equipment simulated or actual automatic actuation test. ms test is performed every 18 months. The 18 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing . ~ SR 3.3.6.6 SR 3.3.6 .6 is the performance of a TADOT. This test is a check of the Manual Actuation Functions and is performed (continued) HBRSEP Unit No. 2 B 3.3-126 Revision No. Q
Containment Ventilation Isolation Instrumentation B 3.3.6 BASES (continued) SURVEILLANCE SR 3.3.6.6 (continued) REQUIREMENTS every 18 months. Each Manual Actuation Function is tested up to, and including , the master relay coils. In some instances, the test includes actuation of the end device (i.e., pump starts , valve cycles, etc.). The test also includes trip devices that provide actuation signals directly to the relay logic, bypassing the analog process control equipment. The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Functions tested have no setpoints associated with them . The rrequency is based on the known reliability of the runction and the redundancy available, and has been shown to be acceptable through operating m<perience. ~ .....~ ~ - - .
~ERT3!
SR 3.3 .6.7 A CHANNEL CALIBRATIO~J is performed every 18 months, or apprm<imately at every ref1::1eling . CHANNEL CALIBRATION is a complete check of the instrument loop; including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. The rrequency is based on operating experience and is consistent with the typical industry refueling cycle. ~ SERT 3! REFERENCES 1. Deleted.
- 2. ~JU REG 1366, "I mprovements to Technical Specification Surveillance Requirements,"' December, 1992. !Deleted.
HBRSEP Unit No. 2 B 3.3-127 Revision No. ~
CREFS Actuation Instrumentation B 3.3.7 BASES ACTIONS (continued) Condition B applies to the failure of two CREFS actuation trains, or the radiation monitor channel. The Required Action is to place one CREFS train in the emergency pressurization mode of operation immediately. This accomplishes the actuation instrumentation Function that may have been lost and places the unit in a conservative mode of operation . C.1 and C.2 Condition C applies when the Required Action and associated Completion Time for Condition A or B have not been met and the unit is in MODE 1, 2, 3, or 4. The unit must be brought to a MODE in which the LCO requirements are not applicable . To achieve this status, the unit must be brought to MODE 3 within 6 hours and MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems . 0 .1 and 0.2 Condition D applies when the Required Action and associated Completion Time for Condition A or B have not been met when irradiated fuel assemblies are being moved . Movement of irradiated fuel assemblies must be suspended immediately to reduce the risk of accidents that would require CREFS actuation. SURVEI LLANCEA Note has been added to the SR Table to clarify that REQUIREMENTS Table 3.3.7-1 determines which SRs apply to which CREFS Actuation Functions. SR 3.3.7.1 Performance of the CHANNEL CHECK once every 12 hours ensures that a gross failure of radiation monitor instrumentation has not occurred . (continued) HBRSEP Unit No. 2 B 3.3-131 Revision No. ~
CREFS Actuation Instrumentation B 3.3.7 BASES SURVEILLANCE SR 3.3.7.1 (continued) REQUIREMENTS The Frequency is based on operating e*perience that deR1onstrates channel failure is rare. The CHANNEL CHECK suppleR1ents less forR1al , but Rlore frequent, checks of channels during norR1al operational use of tRe Elisplays assesiateEI witR tRe LGO requireEI sRaaaels. sERT I 3 SR 3.3.7.2 A COT is performed once e1;ery 92 days on the required radiation monitor channel to ensure the entire channel will perform the intended function . This test verifies the capability of the instrumentation to provide actuation of both CREFS trains. The setpoint should be left consistent with the unit specific calibration procedure tolerance. The Frequency is based on the known reliability of the Rlonitoring equipR1ent and has been shown to be acceptable through operating e*perience. , .....- - - - - .
. ~SERT3!
SR 3.3.7 .3 SR 3.3.7.3 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the test condition . All possible logic combinations, with and without applicable permrssives , are tested for each protection function . In addition , the master relay coil is tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils . This test is performed every 31 days on a STAGGERED TEST BASIS. The Frequency is justified in WCAP 10271 P A, SuppleR1ent 2, Rev. 1 (Ref. 1). ~.------.
~ERT3!
SR 3.3.7.4 SR 3.3.7.4 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay. The master relay is actuated by either a manual or automatic initiation of the function being tested. Contact operation is verified either by a continuity check of the circuit containing the master relay or proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is perforR1ed every 18 (continued) HBRSEP Unit No. 2 83.3-132 Revision No. G
CREFS Actuation Instrumentation B 3.3.7 BASES SURVEILLANCE SR 3.3.7.4 (continued) REQUIREMENTS months. The 18 month F"requency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing . ~
~.--~S-E-RT---,3j SR 3.3.7.5 SR 3.3.7.5 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified either by a continuity check of the circuit containing the slave relay, or by verification of proper operation of the end device during the supported equipment simulated or actual automatic actuation test. Tflis test is performed every 18 months. The 18 month F"requency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary
!er lesliag. @SERT 31 SR 3.3.7.6 A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling . CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
The F"requency is based on operating experience and is consistent with the typical industry refueling cycle. l}ffi SERT 3! REFERENCES 1. WCAP 10271 PA, Supplement 2, Rev. 1, June 1990. !Deleted . HBRSEP Unit No. 2 B 3.3-133 Revision No. Q
Auxiliary Feedwater (AFW) System Instrumentation B 3.3.8 BASES ACTIONS E.1 and E.2 (continued) an OPERABLE status. If the Function cannot be returned to an OPERABLE status, 6 hours are allowed to place the unit in MODE 3. The allowed Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit systems. In MODE 3, the unit does not have any analyzed transients or conditions that require the explicit use of the protection function noted above. The allowance of 48 hours to return the train to an OPERABLE status is justified in WCAP-10271-P-A (Ref. 3). SURVEILLANCE The SRs for each AFW Actuation Function are identified by REQUIREMENTS the SRs column of Table 3.3.8-1 . A Note has been added to the SR Table to clarify that Table 3.3.8-1 determines which SRs apply to which Functions. The CHANNEL CALIBRATION and COTs are performed in a manner that is consistent with the assumptions used in analytically calculating the required channel accuracies. SR 3.3.8.1 Performance of the CHANNEL CHECK onoe every 12 hours ensures that a gross failure of instrumentation has not occurred . A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Channel deviation criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and reliability. If a channel is outside the criteria, it may be an indication (continued) HBRSEP Unit No. 2 B 3.3-142 Revision No. G
Auxiliary Feedwater (AFW) System Instrumentation B 3.3.8 BASES SURVEILLANCE SR 3.3.8 .1 (continued) REQUIREMENTS that the sensor or the signal processing equipment has drifted outside its limit. The Frequency is based on operating experience that demonstrates channel fai lure is rare . The CHi\t>lNEL CHECK supplements less formal , but more frequent , checks of channels during normal operational use of the Sis~lays assosiatea wRh the LGO ,eqaire8 shaaaels. rws:ERT J 3 SR 3.3.8.2 SR 3.3.8.2 is the performance of a COT . A COT is performed on each required channel to ensure the entire channel , with the exception of the transmitter sensing device, will perform the intended Function . Setpoints must be found within the tolerances and Allowable Values specified in Table 3.3.8-1. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 4) . The setpoint must be left set consistent with the assumptions of t he setpoint methodology (Ref. 4) . The "as found " and "as left" values must also be recorded and reviewed for consistency with the assumptions of the surveillance interval extension analysis in Reference 3 when applicable. The Frequency of 92 days is justified in Reference J . >'>-.
.--~-s""'""E-RT---.3!
SR 3.3.8.3 SR 3.3.8.3 is the performance of a TADOT. This test is a check of AFW automatic pump start on loss of offsite power, undervoltage RCP , and trip of all MFW pumps Functions. It is performed every 18 months. Each applicable Actuation Function is tested up to , and including , the end device start circuitry. In some instances, the test includes actuation of the end device (i.e. , pump starts, valve cycles, etc.) . As noted , this SR requires the injection of a simulated or actual signal for the Trip of Main Feedwater (continued) HBRSEP Unit No. 2 B 3.3-143 Revision No. Q
Auxiliary Feedwater (AFW) System Instrumentation B 3.3.8 BASES SURVEILLANCE SR 3.3.8.3 (continued) REQUIREMENTS Pumps Function. The injection of the signal should be as close to the sensor as practical. The rrequency is adequate, based on industry
- t::.:*perieRse aml is soRsisteRt witR tRe typisal releeliRg sysle. [NsERT J 3
SR 3.3.8.4 is the performance of a CHANNEL CALIBRATION. A CHAN~JEL CALIBRATION is performed every 18 months, or appro>Eimately at every refueling . CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy. CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology (Ref. 4). The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 4). The rrequency of 18 months is based on the assumption of an 18 month calibration interval in the determination of the magnitude of equipment Orilt iR tRe setpoiRI metRo8olo[jy (lsel. 4). l]N
. INSERT 3!
REFERENCES 1. UFSAR, Section 7.3.1
- 2. UFSAR, Section 3.1
- 3. WCAP-10271-P-A, Supplement 2, Rev. 1., June 1990
- 4. EGR-NGGC-0153, Engineering Instrument Setpoints HBRSEP Unit No. 2 B 3.3-144 Revision No. ea
RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 BASES ACTIONS (continued) If Required Action A.1 is not met within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status , the plant must be brought to at least MODE 2 within 6 hours. In MODE 2, the reduced power condition eliminates the potential for violation of the accident analysis bounds. The Completion Time of 6 hours is reasonable to reach the required plant conditions in an orderly manner. SURVEILLANCE SR 3.4.1.1 REQUIREMENTS Since Required Action A .1 allows a Completion Time of 2 hours to restore parameters that are not within limfts, the 12 hour Surveillance Frequency for pressurizer pressure is sufficient to ensure the pressure can be restored to a normal operation , steady state condition following toad changes and other expected transient operations. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and to verify operation is within safety aaalysis ass"m~tioa.s. ~ERT I 3 SR 3.4.1.2 Since Required Action A.1 allows a Completion Time of 2 hours to restore parameters that are not within limits, the 12 hour Surveillance Frequency for RCS average temperature is sufficient to ensure the temperature can be restored to a normal operation , steady state condition following load changes and other expected transient operations. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and to verify operation is within safely aaalysis ass"mptioas. ~ERT I 3 SR 3.4.1.3 The 12 hour Surveillance Frequency for RCS total flow rate is performed using the installed flow instrumentation. The 12 hour interval has been shown by operating practice to be (continued) HBRSEP Unit No. 2 B 3.4-4 Revision No. G
RCS Pressure, Temperature, and Flow DNB Limits B 3.4 .1 BASES SURVEILLANCE SR 3.4.1 .3 (continued) REQUIREMENTS sufficient to regularly assess potential degradation and to verify operation within safety analysis asssmfllians. gERT I 3 SR 3.4 .1.4 Measurement of RCS total flow rate by performance of a precision calorimetric heat balance once every 18 months allows the installed RCS flow instrumentation to be calibrated and verifies the actual RCS flow rate is greater than or equal to the minimum required RCS flow rate. The F=requency of 18 months reflects the importance of verifying flo1N after a refueling outage when the core has been altered , which may ha*;e caused an alteration of flo*N resistance. INSERT 3 This SR is modified by a Note that allows en ry 1n o ODE 1, without having performed the SR, and placement of the unit in the best condition for performing the SR. The Note states that the SR is not required to be performed until 24 hours after :l 90% RTP. This exception is appropriate since the heat balance requires the plant to be at a minimum of 90% RTP to obtain the stated RCS flow accuracies . The Surveillance shall be performed within 24 hours after reaching 90% RTP . REFERENCES 1. UFSAR, Chapter 15.
- 2. UFSAR, Section 4.4.2.
HBRSEP Unit No. 2 B 3.4-5 Revision No. G
RCS Minimum Temperature for Criticality B 3.4.2 BASES APPLICABILITY temperatures to fall below the temperature limit of this (continued) LCO . ACTIONS If the parameters that are outside the limit cannot be restored , the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 2 with Kett < 1.0 within 30 minutes. Rapid reactor shutdown can be readily and practically ach ieved within a 30 minute period . The allowed time is reasonable, based on operating experience, to reach MODE 2 with Kett < 1.0 in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.4.2.1 REQUIREMENTS RCS loop average temperature is required to be verified at or above 530°F every 30 minutes when the low T avg alarm is not reset and any RCS loop T avg < 543°F. The SR is modified by a Note which states that the Surveillance is only required when any RCS loop average temperature is < 543°F and the low T avg alarm is alarming , since RCS loop average temperatures could fall below the LCO requirement without additional warning . The SR to verify RCS loop average temperatures every 30 minutes is frequent enough to preyent the inad,;ertent violation et the LGO. l!&ERT I 3 REFERENCES 1. UFSAR, Section 15.0.4. HBRSEP Unit No. 2 B 3.4-8 Revision No. Q
RCS PIT Limits B 3.4.3 BASES ACTIONS C.1 and C.2 (continued) Condition C is modified by a Note requiring Required Action C.2 to be completed whenever the Condition is entered . The Note emphasizes the need to perform the evaluation of the effects of the excursion outside the allowable limits. Restoration alone per Required Action C.1 is insufficient because higher than analyzed stresses may have occurred and may have affected the RCPB integrity. SURVEILLANCE SR 3.4 .3.1 REQUIREMENTS Verification that operation is within the limits of Figures 3.4.3-1 and 3.4 .3-2 is required every 30 minutes when RCS pressure and temperature conditions are undergoing planned changes. +ms Frequency is considered reasonable in view of the control room indication available to monitor RCS status . Also, since temperature rate of change limits are specified in hourly increments, 30 minutes permits assessment and correction for minor deviations 'Nithin a reasonable time . Surveillance for heatup, cooldown , or ISLH testing may be discon ,nue when the definition given in the relevant plant procedure for ending the activity is satisfied . This SR is modified by a Note that only requires this SR to be performed during system heatup, cooldown , and ISLH testing . No SR is given for criticality operations because LCO 3.4 .2 contains a more restrictive requirement. REFERENCES 1. 10 CFR 50 , Appendix G .
- 2. ASME , Boiler and Pressure Vessel Code, Section XI , Appendix G, 1995 Edition with 1996 Addenda .
- 3. Yanichko, S. E. , "Carolina Power & Light Company, H. B.
Robinson Unit No. 2 Reactor Vessel Radiation Surveillance Program ," Westinghouse Nuclear Energy Systems, WCAP-7373 , January, 1970.
- 4. Laubham , T. J., et al , "Analysis of Capsule X from the Carolina Power and Light H. B. Robinson Unit No. 2 Reactor (continued)
HBRSEP Unit No. 2 B 3.4-17 Revision No. ~
RCS Loops - MODES 1 and 2 B 3.4.4 BASES (continued) SURVEILLANCE SR 3.4.4.1 REQUIREMENTS This SR requires verification every 12 hours that each RCS loop is in operation . Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal while maintaining the margin to DNB. The frequency of 12 hours is sufficient considering other indications and alarms available to the operator in lhe oonlrol room lo monitor RCS loop performanoo. ~ - SERT 3 j REFERENCES 1. UFSAR, Section 15.3. HBRSEP Unit No. 2 B 3.4-22 Revision No. Q
RCS Loop - MODE 3 B 3.4.5 BASES ACTIONS 0 .1, 0 .2, and D.3 (continued) With Required Action C.1 and associated Completion Time not met, two required RCS loops inoperable, or no RCS loops in operation (except during the conditions permitted by the Note in the LCO section), all CRDMs must be de-energized by opening the RTBs or de-energizing the MG sets. All operations involving introduction of coolant into the RCS with boron concentration less than required to meet the minimum SOM of LCO 3.1.1 must be suspended , and action to restore one of the RCS loops to OPERABLE status and operation must be initiated. A planned reduction in RCS boron concentration requires forced circulation for proper mixing , and opening the RTBs or de-energizing the MG sets removes the possibility of an inadvertant rod withdrawal. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SOM of LCO 3.1.1 is required to assure continued safe operation . With coolant added without forced circulation , unmixed coolant could be introduced to the core, however, coolant added with boron concentration meeting the minimum SOM maintains acceptable margin to subcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation . SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR requires verification every 12 hours that the required loops are in operation . Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. The Frequency of 12 hours is sufficient considering other indications and alarms available to the operator in the control room to monitor RC~ loop performance. l!NSERT I 3 SR 3.4.5.2 SR 3.4.5.2 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is
~ 16% for required RCS loops. If the SG secondary side narrow range water level is< 16%, the tubes may become uncovered and the associated loop may (continued)
HBRSEP Unit No. 2 B 3.4-28 Revision No. G,--1-e Amendment No. 49G
RCS Loop - MODE 3 B 3.4.5 BASES SURVEILLANCE . SR 3.4 .5.2 (continued) REQUIREMENTS not be capable of providing the heat sink for removal of the decay heat. The 12 hour Frequensy is sonsidered adequate in view of other indisations available in the sontrol room to alert the operator to a loss of SG level. [wsERT 31 SR 3.4.5.3, SR 3.4.5.4, SR 3.4.5.5, and SR 3.4.5.6 Periodic verification of the alternate administrative controls established by LCO 3.4.5 items a, b, c, or d, is prudent to preclude the possibility of a power excursion associated with an inadvertent control rod withdrawal when only one RCS loop is in operation . The 12 hour Frequensy f.or SR 3.4.5 .3, SR 3.4 .5.4, and SR 3.4 .5.5 is asseptable sinse the status of the affested somponents is not likely to shange without the operator being aware of it. The 24 hour Frequensy for SR 3.4.5 .6 is based on the generally slow shange in the required boron sonsentration and the low probability of an assident ossurring without the required SOM. ~INSERT 1 4 SR 3.4 .5.3, SR 3.4.5.4 , SR 3.4.5.5 and SR 3.4.5.6 have been modified by Notes, which* clarify that these SRs are not required to be met if the alternate requirements of SR 3.4.5.3, SR 3.4.5.4, SR 3.4.5.5, SR 3.4.5.6, as applicable, are satisfied . SR 3.4.5.7 Verification that the required RCPs are OPERABLE ensures that safety analyses limits are met. The requirement also ensures that an additional RCP can be placed in operation , if needed , to maintain decay heat removal and reactor coolant circulation . Verification is performed by verifying proper breaker alignment and power availability to the required RCPs. ifNs INSERT 3 I REFERENCES None. HBRSEP Unit No. 2 B 3.4-29 Revision No. Q,-4e Amendment No. 4W
RCS Loops - MODE 4 B 3.4.6 BASES ACTIONS C.1 and C.2 (continued) maintaining operation for decay heat removal. The action to restore must be continued until one loop or train is restored to OPERABLE status and operation . SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification every 12 hours that one RCS loop or RHR train is in operation. Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. The frequency of 12 hours is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS loop and RHR train performance. ~~-;::,,._-~ SR 3.4.6.2 ~ERT 3 ! SR 3.4.6.2 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is 2: 16%. If the SG secondary side narrow range water level is < 16%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink necessary for removal of decay heat. The 12 hour Frequency is considered adequate in viei.v of other indications available in the control room to alert the operator to the loss of SG level. [msERT 31 SR 3.4.6.3 Verification that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation , if needed, to maintain decay heat removal and reactor coolant circulation . Verification is performed by verifying proper breaker alignment and power available to the required pump. The frequency of 7 days is considered reasonable i:s in view of other administrative controls available and has been shown to be acceptable by operating experience. REFERENCES None. INSERT
.___ _ _3_._ !
HBRSEP Unit No. 2 B 3.4-34 Revision No. G,4e Amendment No. 400
RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES ACTIONS B.1 and B.2 (continued) the RCS of coolant with boron concentration less than requ ired to meet the minimum SOM of LCO 3.1.1 is required to assure continued safe operation . With coolant added without forced circulation , unmixed coolant could be introduced to the core, however, coolant added with boron concentration meeting the minimum SOM maintains acceptable marg in to subcritical operations . The immediate Completion Times reflect the importance of maintaining operation for heat removal. SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This SR requ ires verification every 12 hours that the required train is in operation . Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. The Frequency of 12 hours is sufficient considering other indications and alarms available to the operator in the control room to monitor R~R train performance. r@sERT I 3 SR 3.4.7.2 Verifying that at least one SG is OPERABLE by ensuring its secondary side narrow range water level is ~ 16% and the RCS is not vented ensures an alternate decay heat removal method in the event that the second RHR train is not OPERABLE. If both RHR trains are OPERABLE, this Surveillance is not needed . The 12 hour Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of SG level or the RCS pressure boundary. PFJsERT I 3 SR 3.4.7.3 Verification that a second RHR pump is OPERABLE ensures that an additional pump can be placed in operation , if needed , to maintain decay heat removal and reactor coolant circulation . Verification is performed by verifying proper breaker alignment and power available to the RHR pump. If secondary (continued) HBRSEP Unit No. 2 B 3.4-39 Revision No. O, 1e, 18 Amendment No. 4-QQ
RCS Loops - MODE 5, Loops Filled 8 3.4.7 BASES SURVEILLANCE SR 3.4.7.3 (continued) REQUIREMENTS side water level is ~ 16% in at least one SG and the RCS is not vented , this Surveillance is not needed . The frequency of 7 days is considered reasonable in 1Jiew of other administrati'le controls a1Jailable and has been shown to be acceptable by operating experience. ~ERT I 3 REFERENCES 1. NRC Information Notice 95-35 , "Degraded Ability of Steam Generators to Remove Decay Heat by Natural Circulation ," August 28, 1995. HBRSEP Unit No. 2 B 3.4-39a Revision No. G,-4e Amendment No. 4W
RCS Loops - MODE 5, Loops Not Filled B 3.4.8 BASES (continued) ACTIONS A.1 If only one RHR train is OPERABLE and in operation , redundancy for RHR is lost. Action must be initiated to restore a second train to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal. B.1 and B.2 If no required RHR trains are OPERABLE or in operation , except during conditions permitted by Note 1, all operations involving introduction of coolant into the RCS with boron concentration less than required to meet the minimum SOM of LCO 3.1.1 must be suspended and action .must be initiated immediately to restore an RHR train to OPERABLE status and operation . A planned reduction in RCS boron concentration requires forced circulation for uniform dilution, and the margin to criticality must not be reduced in this type of operation . Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SOM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation , unmixed coolant could be introduced to the core, however, coolant added with boron concentration meeting the minimum SOM maintains acceptable margin to subcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must continue until one train is restored to OPERABLE status and operation. SURVEILLANCE SR 3.4 .8.1 REQUIREMENTS This SR requires verification every 12 hours that one train is in operation . Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. +l=le Frequenoy of 12 hours is suffioient oonsidering other indioations and alarms available to the operator in the eontrol room to monitor Rl=IR train
~effe,maaoo. [Ns'ERT 31 (continued)
HBRSEP Unit No. 2 B 3.4-42 Revision No. G,4e Amendment No. 49G
RCS Loops - MODE 5, Loops Not Filled B 3.4.8 BASES SURVEILLANCE SR 3.4 .8.2 (continued) REQUIREMENTS Verification that the required number of pumps are OPERABLE ensures that additional pumps can be placed in operation , if needed , to maintain decay heat removal and reactor coolant circulation . Verification is performed by verifying proper breaker alignment and power available to the required pumps. The F'requency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience. @i SERT 3 ! REFERENCES None. HBRSEP Unit No. 2 B 3.4-43 Revision No. G;--4-e Amendment No. 4W
Pressurizer B 3.4.9 BASES SURVEILLANCE SR 3.4 .9.1 (continued) REQUIREMENTS limit to provide a minimum space for a steam bubble. The Surveillance is performed by observing the indicated level. The Frequenoy of 12 hours oorresponds to verifying the parameter eaoh shift. The 12 hour interval has been shown by operating praotioe to be suffioient to regu larly assess level for any deviation and verify that operation is within safety analyses assumptions. Alarms are also available for early deteotion of abnormal le"81 iaElisalioas. [NsERT I 3 SR 3.4.9.2 The SR is satisfied when the power supplies are demonstrated to be capable of producing the minimum power and the associated pressurizer heaters are verified to be at their design rating . This may be done by testing the power supply output and heater current, or by performing an electrical check on heater element continuity and resistance. +fte Frequenoy of 18 months is oonsidered adequate to detest heater degradation and has been shown by operating experienoe to be aooeptable. ~ ....~--__,
~ERT3!
SR 3.4 .9.3 This Surveillance demonstrates that the heaters can be manually transferred from the normal to the emergency power supply and energized . The Frequenoy of 18 months is based on a typioal fuel oyole and is oonsistent with similar verifioations of emergenoy power supplies. '@:sERT I 3 REFERENCES 1. UFSAR, Chapter 15.
- 2. NUREG-0737, November 1980.
HBRSEP Unit No. 2 B 3.4-48 Revision No. G
Pressurizer PORVs B 3.4.11 BASES SURVEILLANCE SR 3.4.11 .1 REQUIREMENTS Block valve cycling verifies that the valve(s) can be opened and closed if needed. The basis for the Frequency of 92 days is the ASME Code,
* . If the block valve is closed to isolate a PORV that is capable of be* anually cycled , the OPERABILITY of the block valve is of imp ce, because opening the block valve is necessary to permit ORV to be used for manual control of reactor pressure. If the block INSERT 3 valve is closed to isolate an inoperable PORV that is incapable of being manually cycled , the maximum Completion Time to restore the PORV and open the block valve is 72 hours, which is well within the allowable limits (25%) to extend the block valve Frequency of 92 days.
Furthermore, these test requirements would be completed by the reopening of a recently closed block valve upon restoration of the PORV to OPERABLE status. The Note modifies this SR by stating that it is not required to be met with the block valve closed , in accordance with the Required Action of this LCO. SR 3.4.11 .2 SR 3.4.11.2 requires a complete cycle of each PORV. Operating a PORV through one complete cycle ensures that the PORV can be manually actuated. Testing thePORVs in MODE 3 is required in order to simulate the temperature and pressure environmental effects on PORVs. In the HBRSEP Unit No. 2 PORV design, testing in MODE 4 or MODE 5 is not considered to be a representative test for assessing PORV performance under normal plant operating conditions. The Frequency of 18 months is based on a typical refueling cycle and industry accepted practice. ~ The Note provides guidance to perform this SR within 12 hours of entering MODE 3. This allows adequate time to establish proper plant conditions and ensures the SR is performed in a timely manner. (continued) HBRSEP Unit No. 2 B 3.4-59 Revision No. O
Pressurizer PORVs B 3.4.11 BASES SURVEILLANCE SR 3.4.11.3 REQUIREMENTS (continued) Operating the solenoid air control valves and check valves on the nitrogen accumulators ensures the PORV control system actuates properly when called upon. The Frequency of 18 months is based on a typical refueling cycle and the Frequency of the other SuF\leillances used ta demaast,ate PG~V OPERAB ILITY. ==..--....___-----.
~ERT3!
SR 3.4.11.4 The Surveillance demonstrates that the accumulators are capable of supplying sufficient nitrogen to operate the PORVs if they are needed for RCS pressure control, and normal nitrogen and the backup instrument air systems are not available. Backup instrument air is supplied when the accumulator reaches its low pressure setpoint. This SR must be performed by isolating the normal air and nitrogen supplies from the cycle and industry accepted practice. 1M PORVs. The Frequency of 18 months is based on a typical refueling SERT 3 ! REFERENCES 1. UFSAR, Section 15.6.
- 2. Generic Letter 90-06, "Resolution of Generic Issue 70, ' Power-Operated Relief Valve and Block Valve Reliability,' and Generic Issue 94, 'Additional Low-Temperature Overpressure Protection for Light-Water Reactors,' Pursuant to 10 CFR 50 .54(f)," dated June 25, 1990.
- 3. ASME, Boiler and Pressure Vessel Code, Section XI. !Deleted .
HBRSEP Unit No. 2 B 3.4-60 Revision No. O
LTOP System B 3.4.12 BASES SURVEILLANCE SR 3.4.12.1, SR 3.4.12.2, and SR 3.4.12.3 (continued) REQUIREMENTS The SI pump is rendered incapable of injecting into the RCS through removing the power from the pumps by racking the breakers out under administrative control. An alternate method of LTOP control may be employed using at least two independent means to prevent a pump start or to isolate the injection flow paths into the RCS such that a single failure or single action will not result in an injection into the RCS . This may be accomplished through removal of control power fuses and at least one valve in the injection flow paths being closed , or at least one valve in the injection flow paths being locked closed or closed and deenergized. The rrequency of 12 hours is sufficient, considering other indications and alarms available to the operator in the control room , to 1,erify the required status of the equipment. ~ SR 3.4.12.1 is modified by a Note indicating that this SR is only required to be met when all RCS cold leg temperatures are ~ 175°F and the requirements of LCO 3.4.12.b are not met. Below an RCS temperature of 175°F with the requirements of LCO 3.4.12.b not met, all SI pumps must be incapable of injection into the RCS , as required by SR 3.4.12.2. SR 3.4.12.2 is modified by a Note indicating that this SR is only requ ired to be met when any RCS cold leg temperature is < 175°F and the requirements of LCO 3.4.12.b are not met. Below an RCS temperature of 175°F with the requirements of LCO 3.4.12.b not met, all SI pumps must be incapable of injection into the RCS . Above an RCS temperature of 175°F, only one SI pump may be capable of injecting into the RCS as required by SR 3.4.12.1. SR 3.4.12.4 The RCS vent of~ 4.4 square inches is proven OPERABLE by verifying its open condition eitAeF. Once every 12 hours for a *.ialve that cannot be locked. (continued) HBRSEP Unit No. 2 B 3.4-72 Revision No. G
LTOP System B 3.4.12 BASES SURVEILLANCE SR 3.4.12.4 (continued) REQUIREMENTS b:- Once ei;ery 31 days for a i;ali;e that is locked , sealed , or secured in position . A remo*.ied pressurizer safety i;ali;e fits this category. ~ The passive vent arrangement must only be open to be OPERABLE. ~ This Surveillance is requi red to be met if the vent is being used to satisfy the pressure rel ief requirements of the LCO 3.4.12.b. SR 3.4 .12.5 The PORV block valve must be verified open ei;ery 72 hours to provide the flow path for each required PORV to perform its function when actuated . The valve must be remotely verified open in the main control room . This Surveillance is performed if the PORV satisfies the LCO . The block valve is a remotely controlled , motor operated valve . The power to the valve operator is not required removed , and the manual operator is not required locked in the inactive position . Thus, the block valve can be closed in the event the PORV develops excessive leakage or does not close (sticks open) after relieving an overpressure situation. The 72 hour i;::requency is considered adequate in i;ie11,1 of other administratii;e controls available to the operator in the control room , such as i;ali;e position indication, that i;erify that the PORV block valve remains
~ ~
I',--~N""'-;S-E-RT-3-,I SR 3.4.12.6 Performance of a COT is required within 12 hours after decreasing RCS cold leg temperature to~ 350°F and every 31 days on each required PORV to verify and , as necessary, adjust its lift setpoint. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The COT will verify the setpoint is within the allowed maximum limits in the LTOP analysis. PORV actuation could depressurize the RCS and is not required . (continued) HBRSEP Unit No. 2 B 3.4-73 Revision No. e4
LTOP System B 3.4.12 BASES SURVEILLANCE SR 3.4 .12.6 (continued) REQUIREMENTS To provide operators flexibility during MODE 4 transition activities a note has been added indicating that this SR is not required to be performed until 12 hours after decreasing RCS cold leg temperature to ~ 350°F . The 12 hour FREQUENCY considers the unlikelihood of a low temperature overpressure event during this time. The COT is required to be performed within 12 hours after entering the LTOP MODES when the PORV lift setpoint is reduced to the LTOP setting . The d1 day FR~QIJ~l>JGY soRsiders experieRse with *~"ipmeRI reliaBility. fJNSERT I 3 SR 3.4.12.7 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 18 months to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input. if§s . INSERT 3 ! REFERENCES 1. 10 CFR 50 , Appendix G.
- 2. Generic Letter 88- 11 .
- 3. UFSAR, Chapter 5.
- 4. Letter, RNP-RA/96-0141 , CP&L (R. M. Krich) to NRC, "Request for Technical Specifications Change, Conversion to Improved Standard Technical Specifications Consistent with NUREG-1431 ,
- Standard Technical Specifications-Westing house Plants,'
Revision 1," August 30, 1996, Enclosure 5.
- 5. Letter, NG-77-1215, CP&L (B . J . Furr) to NRC (R. W . Reid) ,
"Reactor Vessel Overpressurization Protection ," October 31 ,
1977.
- 6. Letter, NG-77-1426, CP&L (E. E. Utley) to NRC (R. W . Reid) ,
"Response to Overpressure Protection System Questions,"
December 15, 1977. ( continued) HBRSEP Unit No. 2 B 3.4-74 Revision No. e4
RCS Operational LEAKAGE B 3.4 .13 BASES SURVEILLANCE SR 3.4.13.1 REQUIREMENTS Verifying RCS LEAKAGE to be within the LCO limits ensures the integrity of the RCPB is maintained. Pressure boundary LEAKAGE would at first appear as unidentified LEAKAGE and can only be positively identified by inspection. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. Unidentified LEAKAGE and identified LEAKAGE are determined by performance of an RCS water inventory balance. The RCS water inventory balance must be met with the reactor at steady state operating conditions. The surveillance is modified by two notes. Note 1 states that this SR is required within 12 hours after reaching continuous steady state operation . Steady state operation is required to perform a proper inventory balance; calculations during maneuvering are not useful and a Note requires the Surveillance to be met when steady state is established . For RCS operational LEAKAGE determination by water inventory balance, steady state is defined as stable RCS pressure, temperature , power level , pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows . An early warn ing of pressure boundary LEAKAGE or unidentified LEAKAGE is provided by the automatic systems that monitor the containment atmosphere radioactivity and the containment sump level. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. These leakage detection systems are specified in LCO 3.4 .15, "RCS Leakage Detection Instrumentation." Note 2 states that this SR is not applicable to primary to secondary LEAKAGE because LEAKAGE of 75 gallons per day cannot be measured accurately by an RCS water inventory balance. The 72 hour Frequency during steady state operation is a reasonable interval to trend LEAKAGE and recognizes the importance of early leakage deloolioR iR t~e ~F<lllORtioR of assideats. ~ERT I 3 (continued) HBRSEP Unit No. 2 B 3.4-80 Revision No. ~
RCS Operational LEAKAGE B 3.4.13 BASES SURVEILLANCE SR 3.4.13.4 [j REQUIREMENTS (continued) This SR verifies that primary to secondary LEAKAGE is less or equal to 75 gallons per day through any one SG. Satisfying the primary to secondary LEAKAGE limit ensures that the operational LEAKAGE performance criterion in the Steam Generator Program is met. If this SR is not met, compliance with LCO 3.4.18, "Steam Generator Tube Integrity," should be evaluated . The 75 gallons per day limit is measured at room temperature as described in Reference 4. The operational LEAKAGE rate limit applies to LEAKAGE through any one SG . If it is not practical to assign the LEAKAGE to an individual SG , the entire primary to secondary LEAKAGE should be conservatively assumed to be from one SG . The Surveillance is modified by a Note which states that the Surveillance is not required to be performed until 12 hours after establishment of steady state operation . For RCS primary to secondary LEAKAGE determination, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown , and RCP seal injection and return flows. The Surveillance frequency of 72 hours is a reasonable interval to trend primary to secondary LEAKAGE and recognizes the importance of early leakage detection in the prevention of accid'ents. he primary to secondary LEAKAGE is determined using continu s process radiation monitors or radiochemical grab sampling in accorda e with the EPRI
. guidelines (Ref. 4).
INSERT 3 REFERENCES 1. UFSAR, Section 3.1.
- 2. UFSAR, Chapter 15.
- 3. NEI 97-06 , "Steam Generator Program Guidelines."
- 4. EPRI , "Pressurized Water Reactor Primary-to-Secondary Leak Guidelines."
HBRSEP Unit No. 2 B 3.4-81 Revision No. 32
RCS PIVs B 3.4.14 BASES SURVEILLANCE SR 3.4.14.1 (continued) REQUIREMENTS To satisfy ALARA requirements, leakage may be measured indirectly (as from the performance of pressure indicators) if accomplished in accordance with approved procedures and supported by computations showing that the method is capable of demonstrating valve compliance with the leakage criteria. Leakage rates> 1.0 gpm and s 5.0 gpm are considered unacceptable if the latest measured rate exceeds the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the 5.0 gpm limit by~ 50% . Leakage rates> 5.0 gpm are considered to be unacceptable. More than one valve may be tested in parallel. The combined leakage must be within the limits of this SR. In addition , the minimum differential pressure when performing the SR shall not be < 150 psid . For two PIVs in series , the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested , one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation , the protection provided by redundant valves would be lost. Testing is to be performed every 18 months, a typical refueling cycle. Testing must atse be performed once prior to entering MODE 2 whenever the unit has been in MODE 5 for at least 7 days if leakage testing has not been performed in the previous 9 months. The 18 month Frequency is consistent with the frequency allowed by the American Society of Mechanical Engineers (ASME) Code, Section XI (Ref. 6) . ~ INSERT 3 ! n addition , testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating . PIVs disturbed in the performance of this Surveillance should also be tested unless it has been established per Note 3 that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours after the valve has been reseated if in MODES 1 or 2, or prior to entry into MODE 2 if not in MODES 1 or 2 at the end of the 24 hour period . Within 24 hours is a reasonable and practical time limit for performing this test after opening or reseating a valve. (continued) HBRSEP Unit No. 2 B 3.4-87 Revision No. 0
RCS PIVs B 3.4.14 BASES SURVEILLANCE SR 3.4.14.1 (continued) REQUIREMENTS The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures . Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complementary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. In addition, this Surveillance is not required to be performed on the RHR System when the RHR System is aligned to the RCS in the shutdown cooling mode of operation . PIVs contained in the RHR shutdown cooling flow path must be leakage rate tested after RHR is secured and stable unit conditions and the necessary differential pressures are established . SR 3.4.14.2 Verifying that the RHR interlock is OPERABLE ensures that RCS pressure will not pressurize the RHR system beyond 125% of its design pressure of 600 psig . The interlock setpoint prevents the valves from being opened and is set so the actual RCS pressure must be< 474 psig to open the valves. This setpoint ensures the RHR design pressure will not be exceeded and the RHR relief valves will not lift. The 18 month rrequency is based on the need to perform the Surveillance under conditions that apply during a plant outage. The 18 month rrequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment. ~ INSERT ~ 3 REFERENCES 1. 10 CFR 50.2.
- 2. 10 CFR 50 .55a(c) .
- 3. UFSAR, Section 3.1.
- 4. WASH-1400 (NUREG-75/014) , Appendix V, October 1975.
(continued) HBRSEP Unit No. 2 B 3.4-88 Revision No. G;--7 Amendment No. ~
RCS PIVs B 3.4.14 BASES REFERENCES 5. NUREG-0677, May 1980. (continued) ASME , Boiler and Pressure Vessel Code, Section XI. !Deleted . ! HBRSEP Unit No. 2 B 3.4-89 Revision No. {)
RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS E.1 and E.2 (continued) If a Required Action of Condition A, B, C, or D cannot be met, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. F.1 With all required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required . SURVEILLANCE SR 3.4.15.1 REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. The check gives reasonable confidence that the channel is operating properly. +Re rrequency of 12 hours is based on instrument reliability and is reasonable for detecting off normal conditions . ~~~--~
~SERT3j SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the required containment atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string . +Re rrequency of Q2 days considers instrument reliabi lity, and operating
**~eFieRse Ras sRowR tRat it is ~re~er for lleteatiR§ QegrallatioR. @SERT I 3
(continued) HBRSEP Unit No. 2 B 3.4-96 Revision No. ~
RCS Leakage Detection Instrumentation B 3.4.15 BASES SURVEILLANCE SR 3.4.15.3, SR 3.4.15.4, and SR 3.4 .15.5 REQUIREMENTS (continued) These SRs require the performance of a CHANNEL CALIBRATION for each of the required RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string , including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability. A~aiR, eperatiR~ **pe,ieaoo Ras P"'""".tilat tilis ~'"q"""GY is asoopta81e. !WSERT I 4 REFERENCES 1. UFSAR, Section 3.1 .
- 2. UFSAR, Section 5.2.
HBRSEP Unit No. 2 B 3.4-97 Revision No. ~
RCS Specific Activity B 3.4.16 BASES (continued) SURVEILLANCE SR 3.4.16.1 REQUIREMENTS SR 3.4.16.1 requires performing a gamma isotopic analysis as a measure of the gross specific activity of the reactor coolant at least once every 7 days. The analysis shall consist of a qualitative measurement of the total radioactivity of the primary coolant in units of µCi/gm. While basically a quantitative measure of radionuclides with half lives longer than 15 minutes, excluding iodines, this measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken . This Surveillance provides an indication of any increase in gross specific activity. Trending the results of this Surveillance allows proper remedial action to be taken before reaching the LCO limit under norrt1al operating conditions. The Surveillance is applicable in MODES 1 and 2, and in MODE 3 with Tavg at least 500°F. The 7 day Frequency considers the unlikelihood of a gross fuel failure during the time. ~ ....--"'------. l!!i_SERT 3 ! SR 3.4.16.2 This Surveillance is performed in MODE 1 only to ensure iodine remains within limit during normal operation and following fast power changes when fuel failure is more apt to occur. The 14 day Frequency is adequate to trend changes in the iodine activity level , considering gross activity is monitored every 7 days. The Frequency, between 2 and 6 hours after a power change 2!: 1 o RTP within a 1 hour period, is established because the iodine lev Is peak during this time following fuel failure ; samples at other times wou d provide inaccurate results . INSERT 3 SR 3.4.16.3 . A radiochemical analysis for E determination is required every 184 days (6 months) with the plant operating in MODE 1 equilibrium conditions. The E determination directly relates to the LCO and is required to verify plant operation within the specified gross activity LCO limit. The analysis for E is a measurement of the average energies per disintegration for isotopes with half lives longer than (continued) HBRSEP Unit No. 2 B 3.4-102 Revision No.G
RCS Specific Activity B 3.4.16 BASES SURVEILLANCE SR 3.4.16.3 (continued) REQUIREMENTS 15 minutes, excluding iodines. The rrequency of 184 days recognizes E does not change rapidly. This SR has been modified y a o e at indicates the e determination is required to be performed within 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for at least 48 hours. This ensures that the radioactive materials are at equilibrium so the analysis for E is representative and not skewed by a crud burst or other similar abnormal event. REFERENCES 1. 10 CFR 100.11 .
- 2. UFSAR, Section 15.6.3 .
HBRSEP Unit No. 2 B 3.4-103 Revision No. ~
eves B 3.4.17 BASES ACTIONS F.1 and F.3 (continued) required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.4.17.1 REQUIREMENTS Verification of seal injection to the RCP seals ensures that adequate cooling to the RCP seals is maintained. Verification of seal injection flow is accomplished by direct measurement of seal injection flow or by other means as defined in procedures. ,A., 12 hour Frequency is considered reasonable in view of other administrative controls and the existence of plant alarms that will ensure that an undetected loss of seal injection for mere u,aa a sRert time is ualikely. ~ERT I 3 SR 3.4.17.2 Verification of seal injection flow to the RCP seals via the Makeup Water Pathways ensures that adequate cooling to the RCP seals can be maintained from the RWST. /l.n 18 month Frequency is considered reasonable considering the unlikely failure mechanisms associated with passive piping and operation of the two valves. ~INSERT 1 3 Verification of OPERABILITY of the Makeup Water Pathways from the RWST is also satisfied by SR 3.5.4.2, which verifies an adequate inventory of makeup water. REFERENCES 1. UFSAR Paragraph 9.3.4 .
- 2. CP&L Letter to NRC , 'Submittal of Independent Plant Examination (IPE)," dated August 31 , 1992.
HBRSEP Unit No. 2 B 3.4-109 Revision No. G
Accumulators B 3.5.1 BASES ACTIONS 0 .1 and 0 .2 (continued) 6 hours and pressurizer pressure reduced to [IpOO psig within 12 hours. The allowed Completion Times are reasonable , based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. If more than one accumulator is inoperable, the plant is in a condition outside the accident analyses; therefore, LCO 3.0.3 must be entered immediately. SURVEILLANCE SR 3.5.1.1 REQUIREMENTS Each accumulator isolation valve should be verified to be fully open prior to removing power from the operator. This verification ensures that the accumulators are available for injection. If an isolation valve is not fully open , the rate of injection to the RCS would be reduced . Although a motor operated valve position should not change with power removed , a closed valve could result in not meeting accident analyses assumptions. This Frequency is considered reasonable in view of other administrative controls that ensure a mispositioned isolation valve is unlikely. SR 3.5.1.2 and SR 3.5.1.3 (fil E¥ery 12 hours, b orated water volume and nitrogen cover pressure are verified for each accumulator. This Frequency is sufficient to ensure adequate injection during a LOCI\. Because of the static design of the accumulator, a 12 hour Frequency usually allows the operator to identify changes before limits are reached . Operating mcperience has shown this Frequency to be appropriate for early detection and correctiorref.-eff
"""""I lreR~S. IWsERT 41 (continued)
HBRSEP Unit No. 2 B 3.5-7 Revision No. G
Accumulators B 3.5.1 BASES SURVEILLANCE SR 3.5.1.4 REQUIREMENTS (continued) The boron concentration should be verified to be within required limits for each accumulator every 31 days since the static design of the accumulators limits the ways in which the concentration can be changed . The 31 day Frequency is adequate to identify changes that could occur from mechanisms such as stratification or inleakage. ~ Sampling the affected accumulator within 6 hours after a 2: 70 gallon n ,~lN~!S_E_R_T-3
~1 volume increase will identify whether inleakage has caused a reduction ._ ______._
in boron concentration. The 70 gallon volume increase and time limit of 6 hours is based on preventing a reduction in boron concentration in an accumulator below 1950 ppm with an initial boron concentration of 2000 ppm assuming in-leakage of 70 gallons pure water at a maximum in-leakage rate of 0.2 gpm . It is not necessary to verify boron concentration if the added water inventory is from the refueling water storage tank (RWST), because the water contained in the RWST is within the accumulator boron concentration requirements. This is consistent with the recommendation of NUREG-1366 (Ref. 4). SR 3.5.1.5 Verification every 31 days that control power is removed from each accumulator isolation valve operator ensures that an active failure could not result in the undetected closure of an accumulator motor operated isolation valve. If this were to occur, only one accumulator would be available for injection given a single failure coincident with a LOCA.
~ince power is removed under administrative control , the 31 day Frequency will provide adequate assurance that power is removed . ~SERT I 3
This SR allows power to be supplied to the motor operated isolation valves when pressurizer pressure is< 1000 psig , thus allowing operational flexibility by avoiding unnecessary delays to manipulate the breakers during plant startups or shutdowns. REFERENCES 1. UFSAR, Section 6.2.1.
- 2. 10 CFR 50.46.
(continued) HBRSEP Unit No. 2 B 3.5-8 Revision No. Q
ECCS - Operating B 3.5.2 BASES ACTIONS B.1 and B.2 (continued) control power restored . Additionally, Required Action B.2 requires the control power to be removed to the valve within 24 hours. In this condition, the valves could be subject to a spurious single failure that could result in closure of the valve and isolation of an accumulator. During the interval in which control power is restored, the valve remains in its required position or if a valve is repositioned after the restoration of power, the applicable condition associated with the ECCS train or flow path must be entered. The flow path to FCV-605 may be isolated in lieu of FCV-605 being in the required position. The 24 hour Completion Time is reasonable considering a low probability of a"spurious single failure coincident with a LOCA. C.1 and C.2 If the inoperable trains cannot be returned to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status , the plant must be brought to MODE 3 within 6 hours and MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.5.2.1 REQUIREMENTS Verification of proper valve position ensures that the flow path from the ECCS pumps to the RCS is maintained. Misalignment of these valves could render both ECCS trains inoperable. Securing these valves in position by removal of control power or by key locking the control in the correct position ensures that they cannot change position as a result of an active failure or be inadvertently misaligned . These valves are of the type , described in Reference 6, that can disable the function of both ECCS trains and invalidate the accident analyses. A 12 hour Frequency is considered reasonable in view of other administrative controls that will
"""""' a mispositioAeO val"" is ""likely. ~ERT I 3
(continued) HBRSEP Unit No. 2 B 3.5-17 Revision No. ~
ECCS - Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.2 REQUIREMENTS (continued) Verifying the correct alignment for manual , power operated , and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation . This SR does not apply to valves that are locked , sealed , or otherwise secured in position , since these were verified to be in the correct position prior to locking , sealing , or securing . A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve will automatically reposition within the proper stroke time . This Surveillance does not require any testing or valve manipulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct position. +Re J1 day frequency is appropriate because the valves are operated under adR1inistrative control, and an iRlproper valve position would only affect a single train . This frequency has been shown to be acceptable through o~erating e*~erienoo. ~ERT I 3
.SR 3.5.2.3 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by Section XI of the ASME Code. This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the plant safety analysis. This ensures that pump performance is consistent with the pump curve. SRs are specified in the lnservice Testing Program ,
which encompasses Section XI of the ASME Code . Section XI of the Code provides the activities and Frequencies necessary to satisfy the requirements. SR 3.5.2.4 and SR 3.5.2.5 These Surveillances demonstrate that each automatic ECCS valve actuates to the required position on an actual or (continued) HBRSEP Unit No. 2 B 3.5-18 Revision No. G
ECCS - Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.4 and SR 3.5.2.5 (continued) REQUIREMENTS simulated SI signal and that each ECCS pump starts on receipt of an actual or simulated SI signal. This Surveillance is not required for valves that are locked , sealed , or otherwise secured in the required position under administrative controls. The 18 month frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for unplanned plant transients if the Surveillances were performed with the reactor at power. The 18 month frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment. The actuation logic is tested as part of ESf Actuation System testing , and equipment performance is monitored as part of the lnservice Testing Program . lffisERT 4 j SR 3.5.2.6 Periodic inspections of the containment sump suction inlet ensure that it is unrestricted and stays in proper operating condition . The 18 month frequency is based on the need to perform this Surveillance under the 68-R4itions that apply during a plant outage, on the need to have access to the location, and because of the potential for an unplanned transient if the Surveillance were performed with the reactor at power. This frequency has been found to be sufficient to detect abnormal degradation and is oonli,med by o~eraling e*~e,ienoe. ~.---"----,
~ERT3j SR 3.5.2.7 Verification of proper valve position ensures the proper flow path is established for the LHSI system following operation in RHR mode. '.1=Re frequency of 31 days is commensurate with the accessibility and radiation le11els involved in ~erle,ming 11,e """'eillanoo (Rel. ~). ~ERT j 3
SR 3.5.2.8 Verification of proper valve position ensures the proper flow path is established for the LHSI system following operation in RHR mode. '.1=Re Frequency of 92 days is based on (continued) HBRSEP Unit No. 2 B 3.5-19 Revision No. G
ECCS - Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.8 (continued) REQUIREMENTS the locked status for the valve as well as the accessibility and radiation levels invol 11ed in performing the surveillance (Ref. 6) . !S-,. N-S-E-RT-3--,l
.--!I REFERENCES 1. UFSAR Paragraph 3.1 .2.37.
- 2. 10 CFR 50.46 .
- 3. UFSAR, Chapter 15.
- 4. UFSAR,*Chapter 6.
- 5. NRC Memorandum to V . Stello , Jr., from R.L. Baer, "Recommended Interim Revisions to LCOs tor ECCS Components," December 1, 1975 .
. . a-:- IE Information Notice No. 87 01 . !Deleted.!
- 7. CP&L Letter to NRC, from G. E. Vaughn ,*"Emergency Core Cooling System *(ECCS) Failure Mode and Effects Analysis (FMEA)
Summary Information," May 7, 1991 . HBRSEP Unit No. 2 B 3.5-20 Revision No. G
RWST B 3.5.4 BASES ACTIONS B.1 (continued) In this Condition , neither the ECCS nor the Containment Spray System can perform its design function . Therefore, prompt action must be taken to restore the tank to OPERABLE status or to place the plant in a MODE in which the RWST is not required . The short time limit of 1 hour to restore the RWST to OPERABLE status is based on this condition simultaneously affecting redundant trains. C.1 and C.2 If the RWST cannot be returned to OPERABLE status within the associated Completion Time , the plant must be brought to a MODE in which the LCO does not apply. To achieve this status , the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.5.4.1 REQUIREMENTS The RWST borated water temperature should be verified every 24 hours to be within the limits assumed in the accident analyses band . +his Frequency is sufficient to identify a temperature change that would approach either limit and has been shown to be acceptable through operating experience.~INSERT 3 I The SR is modified by a Note that eliminates the requirement to perform this Surveillance when ambient air temperatures are within the operating limits of the RWST. With ambient air temperatures within the band , the RWST temperature should not exceed the limits. SR 3.5.4.2 The RWST water volume should be verified every 7 days to be above the required minimum level in order to ensure that a sufficient initial supply is available for injection and to support continued ECCS and Containment Spray System pump (continued) HBRSEP Unit No. 2 B 3.5-29 Revision No. ()
RWST B 3.5.4 BASES SURVEILLANCE SR 3.5.4.2 (continued) REQUIREMENTS operation on recirculation . Since the RWST volume is normally stable and is protected by an alarm , a 7 day Frec:iuency is appropriate and has Oeea showa 1G Oe aGGeptaOle threagh ope,atiag e*perieaoo. il@ERT I 3 SR 3.5.4.3 The boron concentration of the RWST should be verified every 7 days to be within the required limits. This SR ensures that the reactor will remain subcritical following a LOCA. Further, it assures that the resulting sump pH will be maintained in an acceptable range so that boron precipitation in the core will not occur and the effect of chloride and caustic stress corrosion on mechanical systems and components will be minimized. Since the RWST volume is normally stable, a 7 day sampling Frec:iuency to verify boron concentration is appropriate and has been shovm to be
*.GGeptaOle thr~agh ope,atiag e*peFiease. ~N~ERT I 3
REFERENCES 1. UFSAR, Chapter 6 and Chapter 15. HBRSEP Unit No. 2 B 3.5-30 Revision No. G
Containment Air Lock B 3.6.2 BASES SURVEILLANCE SR 3.6.2.2 REQUIREMENTS (continued) The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment OPERABILITY. Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment. Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely meshanisal nature of this interlosk, and given that the interlosk meshanism is not normally shallenged when the sontainment air losk door is used for entry and exit (prosedures require strist adherense to single door opening), this test is only required to be performed every 24 months. The 24 month Frequensy is based on the need to perform this Surveillanse under the sonditions that apply during a plant outage, and the potential for loss of sontainment OPeRABILITY if the surveillanse were performed with the roaster at power. The 24 month Frequensy for tAe-ffiterlosk is justified based on generis operating experiense. The 24 month Frequensy is based on engineering judgment and is sonsidered adequate given that the interlosk is not shallenged during the use of the interlosk. ~ - - - - - -- - -~ - _INSERT 3-j - - - - - - - - - - - - REFERENCES 1. 10 CFR 50, Appendix J, Option B.
- 2. UFSAR, Paragraph 6.9.2 .
HBRSEP Unit No. 2 B 3.6-12 Revision No. e-9
Containment Isolation Valves B 3.6 .3 BASES SURVEILLANCE SR 3.6 .3.1 (continued) REQUIREMENTS safety related considerations (equipment or personnel) to support plant operations and maintenance activities within containment. Examples of
* : this may include operating the valves to reduce activity to increase stay
-~ , . : times, eliminate the need for respiratory protective equipment, reduce
* , a,mbient temperatures during hot months, to increase the effectiveness of
*. workers and to minimize occupational effects of necessary, non-routine activities in containment, .or for Surveillances that require the valves to be
. open . The valves are capable of closing in the *e*nvironment following a LOCA. Therefore , these valves are allowed to be open for limited periods
,of time . The 3.1 day Frequunoy is consistent with other oontainment isolation valve requirements discussed in SR 3.6.3.3. ince it is not operationally necessary, it is desirable to preclude the 2 inch valves and
.6 inch valves frer:n being open at the same time. A Not to this SR restricts the 6 inch and 42 inch valves from being opens ultaneously.
INSERT 3
. .. SR 3.6.3.2
.. * '. ,. This. SR requires verification that each* containment isolation manual valve
**and blind flange* lo:9ated outside containment and ndt locked , sealed or
"'., '. : - otherwi~e secured and -required to be closed during accident conditions is
- clos.e~t The :SRhelps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits.
This* SR does not require any testing or valve manipulation . Rather, it involves verification , through a system walkdown , that those containment isolation valves outs*ide containment and capable of being mispositioned are in the correct position. 8inoe verifioation of valve position for containment isolation valves outside ocmta1nment is relatively easy, the 31 day Frequenoy is applioable to oontainment isolation valves (exoept Penetration Pressurization System valves with a diameter < 3/8 inoh) and blind flanges. The 18 month Frequency is applioable to Penetration Pressurization System valves 1Nith a diameter < 3/8 inoh. These Frequencies are based on engineering judgment and were chosen to provide added assuranoe of the correct positions. The 18 month Frequenoy for Penetration Pressurization System val 11es < 3/8 inoh in diameter is oonsidered aooeptable based on the low (continued) HBRSEP Unit No. 2 B 3.6-22 Revision No. a+-
Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6 .3.2 (continued) REQUIREMENTS probability of these valves being mispositioned and the minimal consequences associated with mispositioning one of these valves . SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time INSERT 3 the valves are open . This SR does not apply to valves that are locked , sealed or otherwise secured in the closed position , since these were verified to be in the correct position upon locking , sealing or securing . The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3 and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in the proper position , is small. SR 3.6.3.3 This SR requires verification that each containment isolation manual valve and blind flange located inside containment and not locked , sealed or otherwise secured and required to be closed during accident cond itions is closed . The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. For containment isolation valves inside containment, the Frequency of "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is appropriate since these containment isolation valves are operated under administrative controls and the probability of their misalignment is low. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time they are open . This SR does not apply to valves that are locked, sealed or otherwise secured in the closed position , since these were verified to be in the correct position upon locking , sealing or securing . This Note allows valves and blind flanges located in high radiation areas to be verified closed by use of (continued) HBRSEP Unit No. 2 B 3.6-23 Revision No. 3-7
Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6 .3.3 (continued) REQUIREMENTS administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, and 4, for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position , is small. SR 3.6.3.4 Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time and Frequency of this SR are in accordance with the lnservice Testing (1ST) Program . In addition to the 1ST program testing frequency, the 42 inch purge supply and exhaust valves will be tested prior to use if not tested within the previous quarter. Otherwise, the 42 inch purge supply and exhaust valves are not cycled quarterly only for testing purposes. SR 3.6.3 .5 Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a OBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. This surveillance is not required for valves that are locked, sealed , or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this Surveillance Vlhen performed at the 18 month Frequency. Therefore , the Frequency was soasl"ded tG be asseptable Imm a reliability staadpoiat. )sERT I 3 (continued) HBRSEP Unit No. 2 B 3.6-24 Revision No . .a+
Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.6 REQUIREMENTS (continued) Verifying that each 42 inch inboard containment purge valve is blocked to restrict opening to s 70° is required to ensure that the valves can close under OBA conditions within the times assumed in the analyses of References 1 and 2. If a LOCA occurs, the purge valves must close to maintain containment leakage within the values assumed in the accident analysis . At other times when purge valves are required to be capable of closing (e.g ., during movement of irradiated fuel assemblies), pressurization concerns are not present, thus the purge valves can be fully open . The 18 month rrequency is appropriate because the blocking deyises ar<> typisally "'"'oved ORiy dYriR§ a re!YeliR§ 0Yta9e. ~SERT I 3 REFERENCES 1. UFSAR, Chapter 15.
- 2. UFSAR, Section 6.2.
- 3. Standard Review Plan 6.2.4.
HBRSEP Unit No. 2 B 3.6-25 Revision No. ~
Containment Pressure B 3.6.4 BASES (continued) ACTIONS When containment pressure is not within the limits of the LCO , it must be restored to within these limits within 1 hour. The Required Action is necessary to return operation to within the bounds of the containment analysis. The 1 hour Completion Time is consistent with the ACTIONS of LCO 3.6.1 , "Containment," which requires that containment be restored to OPERABLE status within 1 hour. B.1 and B.2 If containment pressure cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable , based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.4.1 REQUIREMENTS Verifying that containment pressure is within limits ensures that unit operation remains within the limits assumed in the containment analysis. The 12 hour Frequenoy of this SR was developed based on operating experienoe related to trending of oontainment pressure variations during the applioable MODES . Furthermore, the 12 hour Frequenoy is oonsidered adequate in view of other indioations available in the oontrol room , inoluding alarms, to alert the operator to an abnormal oontainment pressure oondition . ~ INSERT 3 I REFERENCES 1. UFSAR, Section 6.2 .
- 2. 10 CFR 50 , Appendix K.
HBRSEP Unit No. 2 B 3.6-28 Revision No. G
Containment Air Temperature B 3.6.5 BASES (continued) SURVEILLANCE SR 3.6.5.1 REQUIREMENTS Verifying that containment average air temperature is within the LCO limit ensures that containment operation remains w ithin the limit assumed for the containment analyses. In order to determine the containment average air temperature, a volumetric average is calculated using measurements taken at locations within the containment selected to provide a representative sample of the overall containment atmosphere. The 24 hour F"requenoy of this SR is oonsidered aooeptable based on observed slow rates of temperature inorease within oontainment as a result of environmental heat souroes (due to the large volume of oontainment). F"urthermore, the 24 hour F"requenoy is oonsidered adequate in view of other indioations available in the oontrol room to alert the operator to an abnormal oontainment temperature oondition . ~ INSERT 3 I REFERENCES 1. UFSAR, Section 6.2.
- 2. 10 CFR 50.49.
HBRSEP Unit No. 2 B 3.6-32 Revision No. G
Containment Spray and Cooling Systems B 3.6.6 BASES ACTIONS Ll (continued) With two containment spray trains or any combination of three or more containment spray and cooling trains inoperable, the unit is in a condition outside the accident analysis . Therefore, LCO 3.0.3 must be entered immediately. SURVEILLANCE SR 3.6.6.1 REQUIREMENTS Verifying the correct alignment for manual, power operated , and automatic valves in the containment spray flow path provides assurance that the proper flow paths will exist for Containment Spray System operation . This SR does not apply to valves that are locked , sealed , or otherwise secured in position , since these were verified to be in the correct position prior to locking , sealing , or securing . This SR does not require any testing or valve manipulation. Rather, it involves verification , through a system walkdown , that those valves outside containment and capable of potentially being mispositioned are in the correct position .
~
SR 3.6.6.2 Operating each containment cooling train fan unit for 2!: 15 minutes ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure , or excessive vibration can be detected for corrective action . +Re 31 day Frequency was developed considering the known reliability of the fan units and controls , the two train redundancy available, and the low probability of significant degradation of the containment cooling train occurring between surveillances. It has also been shown to be acceptable through operating experience. ~ .....- - ---.
~ERT3!
SR 3.6.6.3 Verifying that each containment cooling SW cooling flow rate to each cooling unit is 2!: 750 gpm provides assurance that the design flow rate assumed in the safety analyses will be achieved (Ref. 4) . The Frequency was developed considering the known reliability of the Cooling VVater System , the two (continued) HBRSEP Unit No. 2 B 3.6-40 Revision No. G
Containment Spray and Cooling Systems B 3.6.6 BASES SURVEILLANCE SR 3.6.6.3 (continued) REQUIREMENTS train redundancy available, and the low probabi lity of a significant de§radalioa al flow osseFFiR§ belweea serveillaases. [JNS'ERT I 3 SR 3.6.6.4 Verifying each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential pressure are normal tests of centrifugal pump performance required by Section XI of the ASME Code (Ref. 5) . Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on recirculation flow. This test confirms pump performance is consistent with the pump design curve and is indicative of overall performance, by setting the pump head and measuring the test flow. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of the SR is in accordance with the lnservice Testing Program . SR 3.6.6.5 and SR 3.6.6.6 These SRs require verification that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation of a containment High - High pressure signal. SR 3.6.6.5 is not required for valves that are locked , sealed , or otherwise secured in the required position under administrative controls. SR 3.6.6.6 must be performed with the isolation valves in the spray supply lines at the containment and spray additive tank locked closed . The 18 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillances when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a rel iability slaad~oiat. ~ERT I 4 (continued) HBRSEP Unit No. 2 B 3.6-41 Revision No. G
Containment Spray and Cooling Systems B 3.6.6 BASES SURVEILLANCE SR 3.6.6 .7 REQUIREMENTS (continued) This SR requires verification that each containment cooling train actuates upon receipt of an actual or simulated safety injection signal. The 18 month Frequency is based on engineering judgment and has been sho'Nn to be acceptable through operating experience. See SR 3.6 .6.5 and SR 3.6 .6.6, above, for further discussion of tile basis for tile 18 meRtll Fre~"eRsy. ~~--""---~
~ERT3!
SR 3.6.6.8 With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degraded . Performance is required following activities which could result in nozzle blockage. Such activities may include: (1) a major configuration change; or (2) a loss of foreign material control such that the final condition of the system cannot be assured . The frequency is considered adequate due to the passive design of the nozzles, the stainless steel construction of the piping and nozzles, and the use of foreign material exclusion controls during system opening . REFERENCES 1. UFSAR, Section 3.1.
- 2. 10 CFR 50, Appendix K.
- 3. UFSAR, Section 6.2.
- 4. UFSAR, Section 9.4 .
- 5. ASME , Boiler and Pressure Vessel Code, Section XI.
HBRSEP Unit No. 2 B 3.6-42 Revision No. ~
Spray Additive System B 3.6.7 BASES ACTIONS 8 .1 (continued) account the time necessary to restore the System to Operable Status, the relative importance of pH adjustment of the Containment Spray System flow for corrosion protection and iodine removal as well as the low probability of the worst case DBA occurring during this period . C.1 and C.2 If the Spray Additive System cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 84 hours. The allowed Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows 48 hours for restoration of the Spray Additive System in MODE 3 and 36 hours to reach MODE 5. This is reasonable when considering the reduced pressure and temperature conditions in MODE 3 for the release of radioactive material from the Reactor CooJant System. SURVEILLANCE SR 3.6.7.1 REQUIREMENTS Verifying the correct alignment of Spray Additive System manual , power operated , and automatic valves in the spray additive flow path provides assurance that the system is able to provide additive to the Containment Spray System in the event of a DBA. This SR does not apply to valves that are locked , sealed , or otherwise secured in position , since these valves were verified to be in the correct position prior to locking , sealing , or securing. This SR does not require any testing or valve manipulation. Rather, it involves verification , through a system walkdown , that those valves outside containment and capable of potentially being mispositioned are in the correct position .
~
(continued) HBRSEP Unit No. 2 B 3.6-46 Revision No. Q
Spray Additive System B 3.6.7 BASES SURVEILLANCE SR 3.6.7.2 REQUIREMENTS (continued) To provide effective iodine removal , the containment spray must be an alkaline solution. Since the RWST contents are normally acidic, the volume of the spray additive tank must provide a sufficient volume of spray additive to adjust pH for all water injected . This SR is performed to verify the availability of sufficient NaOH solution in the Spray Additive System. The 184 day Frequency was developed based on the low probability of an undeteeted change in tank volume oeeurring during the SR interval (the tank is isolated during normal unit operations) . Tank level is also indieated and alarmed in the eontrol room , so that there is Ri~R soRMeRoo tRat a s"BstaRtial sRaR~e iR IC\lel wo"IEI Be EletesteEI. ITN?ERT I 3 SR 3.6.7.3 This SR provides verification of the NaOH concentration in the spray additive tank and is sufficient to ensure that the spray solution being injected into containment is at the correct pH level. The 184 day Frequency is sufficient to ensure that the coneentration level of ~JaOH in the spray *additive tank remains above the limit. This is based on the low likelihood of an uncontrolled change in concentration (the tank is normally isolated) and the probability that any substantial variance in tank volume will Be EleteateEI. ~ERT I 3 SR 3.6.7.4 This SR provides verification that each automatic valve in the Spray Additive System flow path actuates to its correct position. This Surveillance is not required for valves that are locked , sealed , or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillanee under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at pov.ier. Operating experience has shown that these components usually pass the Surveillanee when performed at the 18 month Frequeney. Therefore, the Frequency was concluded to be asooptal,le fro"' a reliaBility staRElpoiRt. ~ERT I 3 (continued) HBRSEP Unit No. 2 B 3.6-47 Revision No. Q
IVSW System B 3.6.8 BASES ACTIONS B.1 and B.2 (continued) If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status , the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. Tt:ie allowed Completion Times are reasonable , based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.8.1 REQUIREMENTS This SR verifies the IVSW tank has the necessary pressure to provide motive force to the seal water. A pressure ~ 46.2 psig ensures the containment penetration flowpaths that are sealed by the IVSW System are maintained at a pressure which is at least 1.1 times the calculated peak containment internal pressure (Pa) related to the design bases accident. Verifisation of the IVSW tank pressure on a Frequensy of onse per 12 hours is asseptable. This Frequensy is suffisient to ensure availability of IVSW. Operating experiense has shown this Frequensy to be ap"'9priale fer early Oelestiea aaO sorrestioa el ell ROFffial treaOs. [!Ns'ERT I 3 SR 3.6.8.2 This SR verifies the IVSW tank has an initial volume of water necessary to provide seal water to the containment isolation valves served by the IVSW System . An initial volume~ 85 gallons ensures the IVSW System contains the proper inventory to maintain the required seal. Verifisation of IVSVV tank level on a Frequensy of onse per 31 days is asseptable sinse alarm iR t~e soatfol reOffi-j'>Fief te level Oesreasiag te 85 galleas. #RT tank level is sontinueusly monitored by installed instrumentation and will I 3 SR 3.6.8.3 This SR verifies the stroke time of each automatic air operated header injection solenoid valve is within limits. The frequency is specified by the lnservice Testing (continued) HBRSEP Unit No. 2 B 3.6-52 Revision No. a4
IVSW System B 3.6.8 BASES SURVEILLANCE SR 3.6.8.3 (continued) REQUIREMENTS Program , and previous operating experience has shown that these valves usually pass the required test when performed. SR 3.6.8.4 This SR ensures that automatic header injection valves actuate to the correct position on a simulated or actual signal. The 18 month i;::requensy is based on the need to perform this Surveillanse under the sonditions that apply during a plant outage and the potential for an unplanned transient if the Surveillanse were performed with the roaster at power. Operating experiense has shown these somponents usually pass the Surveillanse *.vhen performed at the 18 month i;::requensy. Therefore, the
- q:.: a: was oaaol"EiaEi ta be aoseptable. [N&ERT I 5 3 This SR ensures the capability of the dedicated nitrogen bottles to pressurize the IVSW system independent of the Plant Nitrogen System .
The 18 month i;::requensy is based on the need to perform this Surveillanse under the sonditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were perler"1eEi witR !Re reaotar at power. ~ERT I 3 SR 3.6.8.6 Integrity of the IVSW seal boundary is important in providing assurance that the design leakage value required for the system to perform its sealing function is not exceeded. The 18 month i;::requensy is based on the need to perform this Surveillanse under the sonditions that apply during a plant outage and the potential for an unplanned transient if the S"rveillaaoe were perlem,eEi witR !Re reaotar at power. ~ERT I 3 (continued) HBRSEP Unit No. 2 B 3.6-53 Revision No. G
AFW System B 3.7.4 BASES ACTIONS F.1 (continued) In MODE 4, either the reactor coolant pumps or the RHR loops can be used to provide forced circulation . This is addressed in LCO 3.4 .6, "RCS Loops - MODE 4 ." With one required AFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status. The immediate Completion Time is consistent with LCO 3.4.6. SURVEILLANCE SR 3.7.4.1 REQUIREMENTS Verifying the correct alignment for manual, power operated , and automatic valves in the AFW System water and steam supply flow paths provides assurance that the proper flow paths will exist for AFW operation. This SR does not apply to valves that are locked , sealed , or otherwise secured in position, since they are verified to be in the correct position prior to locking , sealing , or securing . This SR also does not apply to valves that cannot be inadvertently misaligned , such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position . The 31 day frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation , and ensures oorrest **l*e ~asitiaRs. @sERT I 3 SR 3.7.4.2 Verifying that each AFW pump's developed head at the flow test point is greater than or equal to the required developed head ensures that AFW pump performance has not degraded during the cycle. Flow and differential head are normal tests of centrifugal pump performance required by Section XI of the ASME Code (Ref. 4) to monitor centrifugal pump performance. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. This ensures that pump performance is consistent with the pump curve . Performance of inservice testing discussed in the ASME Code, Section XI (Ref. 4) ( continued) HBRSEP Unit No. 2 B 3.7-28 Revision No. ~
AFW System B 3.7.4 BASES SURVEILLANCE SR 3.7.4.2 (continued) REQUIREMENTS (only required at 3 month intervals) satisfies this requirement. :+Re 31 day Frequensy on a STAGGERED TEST BASIS results in te~sting eash pump onse every 3 months, as required by Referense 4. INSERT 3 This SR is modified by a Note indicating that the SR should be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test. SR 3.7.4.3 This SR verifies that AFW can be delivered to the appropriate steam generator in the event of any accident or transient that generates an AFW actuation signal , by demonstrating that each automatic valve in the flow path actuates to its correct position on an actual or simulated actuation signal. This Surveillance is not required for valves that are locked , sealed , or otherwise secured in the required position under administrative controls. The 18 month i;:requensy is based on the need to perform this Surveillanse under the sonditions that apply during a unit outage and the potential for an unplanned transient if the Surveillanse were performed with the reastor at power. The 18 month i;:requensy is asseptable based on operating e*periense and the design reliability of the equipment. ~ This SR is modified by a Note that states the SR is not required in MODE 4 when AFW is being used for heat removal. In MODE 4, the required AFW train is already aligned and operating . SR 3.7.4.4 This SR verifies that the AFW pumps will start in the event of any accident or transient that generates an AFW actuation (continued) HBRSEP Unit No. 2 B 3.7-29 Revision No. 49
AFW System B 3.7.4 BASES SURVEILLANCE SR 3.7.4.4 (continued) REQUIREMENTS signal by demonstrating that each AFW pump starts automatically on an actual or simulated actuation signal in MODES 1, 2, and 3. In MODE 4, the autostart function is not required . The 18 A1onth Frequency is based on the need to perforA1 this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were perforA1ed with the reactor at power. ~ This SR is modified by two Notes. Note 1 indicates that the SR be deferred until suitable test conditions are established . This deferral is required because there is insufficient steam pressure to perform the test. Note 2 states that the SR is not required in MODE 4. In MODE 4 , the heat removal requirements would be less providing more time for operator action to manually start the required AFW pump. SR 3.7.4.5 This SR verifies proper AFW System alignment and flow path OPERABILITY from the CST to each SG following extended outages to determine that no misalignment of valves has occurred . The SR is performed prior to entering MODE 2 after more than 30 days in MODE 5 or 6. OPERABILITY of AFW flow paths must be verified before sufficient core heat is generated that would require the operation of the AFW System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgment and other administrative controls that ensure that flow paths remain OPERABLE. This SR is modified by a Note that allows entry into and operation in MODE 3 and MODE 2 prior to performing the SR for the steam driven AFW pump. This is necessary because sufficient decay heat is not available following an extended outage. The unit must be at a point of adding minimum core heat in order to provide sufficient steam to operate the steam driven AFW pump to verify water flow. ( continued) HBRSEP Unit No. 2 B 3.7-30 Revision No. G
AFW System B 3.7.4 BASES SURVEILLANCE SR 3.7.4.6 REQUIREMENTS (continued) This SR verifies that the automatic bus transfer switch associated with the "swing" motor driven AFW flow path discharge valve V2-16A will function properly to automatically transfer the power source from the aligned emergency power source to the other emergency power source upon loss of power.to the aligned emergency power source. The
- Surveillance consists of two tests to assure that the switch will perform in either direction. One test is performed with the automatic bus transfer switch aligned to one emergency power source initially, and the test is repeated with the switch initially aligned to the other emergency power source. Periodic testing of the switch is necessary to demonstrate OPERABILITY. Operating experience has sho1Nn that this component usually passes the Surveillance when performed at the 18 month rrequency. Therefore, the rrequency is acceptable from a reliability standpoint. ~ ~ - - - ~
- - - - - - - ----1 ~ERT 3!1---- ---------- REFERENCES 1. UFSAR, Section 10.4.8.
- 2. UFSAR, Section 15.2.8.
- 3. UFSAR, Section 15.2.7.
- 2. ASME , Boiler and Pressure Vessel Code, Section XI.
HBRSEP Unit No. 2 B 3.7-31 Revision No. 49
CST B 3.7.5 BASES ACTIONS C.1 and C.2 (continued) reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.5.1 REQUIREMENTS This SR verifies that the CST contains the required volume of cooling water. The 12 hour Frequency is based on operating experience and the need for operator awareness of unit evolutions that may affect the CST inventory between checks. Also , the 12 hour Frequency is considered adequate in view of other indications in the control room , including alarms, to alert tRe o~orator to aOaormal ~eviatioas iR tRe CST le¥CI. UNs:ERT I 3 SR 3.7.5.2 This SR verifies by administrative means that the backup water supply to the AFW System from the SWS is OPERABLE. In this situation , verification by administrative means is necessary because it is not prudent to cycle the valves and risk introduction of non-feedwater grade water into the SGs. An administrative verification of OPERABILITY is simply a visual inspection of the water supply connection between the SWS and the AFW System to verify that the valves are in place and locked closed , the tell-tale drain valve is open , and the piping is intact and free from leakage. The 31 day Frequency is based on engineering judgement, and is consistent with the procedural controls that ensure that a water supply is OPERABLE. Also, the 31 day Frequency is considered adequate in view of the infrequent need to operate val 11es in the flow paths due to testing or operational requirements. ~
---,_INSERT 3 I- - - - - - - -
REFERENCES 1. UFSAR, Section 9.2.5.
- 2. UFSAR, Chapter 6.
- 3. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.7-35 Revision No. G
CCW System B 3.7.6 BASES ACTIONS 8 .1 and 8.2 (continued) allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.6.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the CCW flow to individual components may render those components inoperable but does not affect the OPERABILITY of the CCW System . Verifying the correct alignment for manual, power operated , and automatic valves in the required CCW flow path provides assurance that the proper flow paths exist for CCW operation . This SR does not apply to valves that are locked , sealed , or otherwise secured in position , since these valves are verified to be in the correct position prior to locking , sealing , or securing . This SR also does not apply to valves that cannot be inadvertently misaligned , such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position . The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation , and ensures oarrost valve ~asiliaas. ~ERT I 3 SR 3.7.6.2 This SR verifies proper automatic operation of the required CCW pumps on an actual or simulated LOP DG start undervoltage signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation . The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating e:><perience has shown that these components usually pass the Surveillance when performed at (continued) HBRSEP Unit No. 2 B 3.7-39 Revision No. ~ Amendment ..:j.g6
CCW System B 3.7.6 BASES SURVEILLANCE SR 3.7.6 .2 (continued) REQUIREMENTS the 18 month frequency. Therefore , the frequency is acceptable from a reliability standpoint. :'::ilNSERT 3 I REFERENCES 1. UFSAR, Section 9.2.2. HBRSEP Unit No. 2 B 3.7-40 Revision No. G
sws B 3.7.7 BASES ACTIONS 0 .1 and D.2 (continued) If the Required Actions and associated Completion Times of Conditions A, B, or C cannot be met, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status , the unit must be placed in at least MODE 3 within 6 hours and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditfons from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.7.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the SWS component~ or systems may render those components inoperable, but does not affect the OPERABILITY of the SWS . Verifying the correct alignment for manual , power operated , and automatic valves in the SWS flow path provides assurance that the proper flow paths exist for SWS operation . This SR does not apply to valves that are locked , sealed , or otherwise secured in position, since they are verified to be in the correct position prior to being locked , sealed , or secured . This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position . This SR does not apply to valves that cannot be inadvertently misaligned , such as check valves. The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures oorreot valve ~osilioas. [!NsERT j 3 SR 3.7.7.2 This SR verifies proper automatic operation of the SWS valves on an actual or simulated actuation signal. The SWS is a normally operating system that cannot be fully actuated as part of normal testing . This Surveillance is not required for valves that are locked , sealed , or otherwise secured in the requi red position under administrative (continued) HBRSEP Unit No. 2 B 3.7-45 Revision No. G
sws B 3.7.7 BASES SURVEILLANCE SR 3.7.7.2 (continued) REQUIREMENTS controls. The 18 Rlonth F"requensy is based on the need to perforRl this Surveillanse under the sonditions that apply during a unit outage and the potential for an unplanned transient if the Surveillanse were perforR1ed v;ith the reastor at power. Operating experiense has shown that these soR1ponents usually pass the Surveillanse when perforR1ed at the 18 Rlonth F"requensy. Therefore, the F"requensy is asseptable froRl a reliability standpoint. '~--"'---~
~ERT3!
SR 3.7.7.3 This SR verifies proper automatic operation of the SWS pumps and SWS booster pumps on an actual or simulated actuation signal. The SWS is a normally operating system that cannot be fully actuated as part of normal testing during normal operation . The 18 R1onth F"requensy is based on the need to perforRl this Surveillanse under the sonditions that apply during a unit outage and the potential for an unplanned transient if the Surveillanse were perforR1ed with the reastor at power. Operating experiense has shown that these GORlponents usually pass the Surveillanse when perforR1ed at the 18 Rlonth F"requensy. Therefore, the Fre~""""Y is asse~tal,le fro"' a relial,ility staaO~oiat. ~ R T I 3 SR 3.7.7.4 This SR verifies that the automatic bus transfer switch associated with turbine building service water isolation valve V6-16C, will function properly to automatically transfer the power source from the aligned emergency power source to the other emergency power source upon loss of power to the aligned emergency power source. The surveillance consists of two tests to assure that the switch will perform in either direction . One test is performed with the automatic bus transfer switch aligned to one emergency power source initially, and the test is repeated with the switch initially aligned to the other emergency power source. Periodic testing of the switch is necessary to demonstrate OPERABILITY. Operating experiense has shown that this soR1ponent usually passes the Surveillanse when perforR1ed at the 18 Rlonth F"requensy. (continued) HBRSEP Unit No. 2 B 3.7-46 Revision No. O
sws B 3.7.7 BASES SURVEILLANCE SR 3.7.7.4 (continued) REQUIREMENTS TlaeFe!or<>, !Re ~""l"ensy is asse~lalale lraFA a r<>lialailily stan<l~oinl. ~'ifERT [ 3 REFERENCES 1. UFSAR, Section 9.2.1.
- )
*o
- 2. UFSAR, Section 6.2 .
- 3. UFSAR, Section 5.4.4.
HBRSEP Unit No. 2 B 3.7-47 Revision No. G
UHS 8 3.7.8 BASES ACTIONS A.1 and A.2 (continued) The Completion Time of Required Action A.1 was developed considering that some activities required to complete the evaluation of required cooling capacity could be completed prior to the Condition being entered . The Completion Time of Required Action A.2 is based on shift schedules for convenience and is considered acceptable since temperature
- monitoring capability is available to detect an increase in* SW temperature throughout the period of Condition A.
8 .1 and 8 .2 If the Required Actions and associated Completion Times are not met or the UHS is inoperable for reasons other than Condition A , the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours and in MODE 5 within 36 hours. The allowed Completion Times are reasonable , based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.8.1 REQUIREMENTS This SR verifies that adequate long term (22 day) cooling can be maintained. The specified level also ensures that sufficient NPSH is available to operate the SWS pumps. The 24 hour Frequency is based on operating experience related to trending of the parameter variations during the applisaBle MODE~. ' \is SR ~erifies that the UHS water level is
;;:: 218 ft MSL.
INSERT 3 (continued) HBRSEP Unit No. 2 B 3.7-50a Revision No. ~ Amendment No. 4B4
UHS B 3.7.8 BASES SURVEILLANCE SR 3.7.8.2 REQUIREMENTS This SR verifies that the SWS is available to cool the CCW System to at least its maximum design temperature with the maximum accident or normal design heat loads for 30 days following a Design Basis Accident. The 24 hour F'requenoy is based on operating experience related to trending of the parameter variations during the applicable MODES. This SR verifies that the service water temperature is::;; 97°F. - - - - - - - - - - - - - - - - - - - - - - ---1 1NSERT 3 REFERENCES 1. UFSAR, Section 9.2.4.
- 2. UFSAR Section 2.4.6.1.
- 3. UFSAR Section 2.1.1.2.
- 4. NUREG-75/024, "Final Environmental Statement Related to the Operation of H. B. Robinson Nuclear Steam-Electric Plant Unit 2,"
U. S. Nuclear Regulatory Commission , Washington DC 20555 , April 1975, page 3-7.
- 5. USGS Historical Daily Values for Station Number 02130900, Black Creek Near McBee, South Carolina , Years 1960-1993.
HBRSEP Unit No. 2 B 3.7-51 Revision No. ~ Amendment No. 4S+
CREFS B 3.7 .9 BASES ACTIONS H.1 (continued) Conditions A or E for other reasons which may make one or more CREFS trains inoperable. Similarly, entry into Conditions A or E for reasons other than Condition G , does not preclude entry into Condition G at the same or later time. In MODE 1, 2, 3, or 4, if the inoperable CRE boundary cannot be restored to OPERABLE status within the requi red Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the un it must be placed in at least MODE 3 within 6 hours, and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challeng ing unit systems. SURVEILLANCE SR 3.7.9.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on th is system are not too severe, testing each train once every month provides an adequate check of this system . Operation for ~ 15 minutes is adequate to demonstrate the function of the system . The 31 day Frequency is based on the rel iability of the equipment and the two train
- "::*:: a,ailaBi li!~. TusERT 31 This SR verifies that the required CREFS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP) . The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate , and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.
(continued) HBRSEP Unit No. 2 B 3.7-58 Revision No. 48
CREFS 8 3.7.9 BASES SURVEILLANCE SR 3.7.9.3 REQUIREMENTS (continued) This SR verifies that each CREFS train starts and operates on an actual or simulated actuation signal. The Frequency of 1g months is consistent with Position C.5 of Regu latory Guide 1.52 (Ref. 4) . The rn month Frequency is based on the refueling cycle. Operating experience has shO\'.'n that these components usually pass the Surveillance when performed at the 1g month Frequency.
~ERT31 SR 3.7.9.4 This SR verifies the integrity of the CRE boundary. The CRE Habitability Program specifies administrative controls for temporary breaches to the boundary, preventative maintenance requirements to ensure the boundary is maintained , and leak test surveillance requirements. The details and frequencies for these requirements are specified in the CRE Habitability Program.
REFERENCES 1. UFSAR, Section 6.4.
- 2. UFSAR Section 6.4.2.3.
- 3. UFSAR, Chapter 15.
I Regulatory Guide 1.52, Rev. 2, March 197g_ Deleted . j HBRSEP Unit No. 2 B 3.7-58a Revision No. 48
CREATC 83.7.10 BASES ACTIONS F.1 and F.2 (continued) In MODE 1, 2, 3, or 4, if both inoperable WCCU trains cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.10.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the heat load assumed in the control room . This SR consists of a combination of testing and calculations. +he 18 month frequency is appropriate since significant degradation of the WCCUs is slow and is not
. e*pesled """.' l~is liffie--pe~ ~s'ERT I 3
REFERENCES 1. . UFSAR, SectLon 6..4. HBRSEP Unit No. 2 B 3.7-62 Revision No. Q
FBACS B 3.7.11 BASES (continued) SURVEILLANCE SR 3.7.11 .1 REQUIREMENTS The FBACS should be checked periodically to ensure that it functions properly. As the environmental and normal operating conditions on this system are not severe, testing once every month provides an adequate check on this system. Operation with the heaters on for ~ 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that heater failure , blockage, fan or motor failure , or excessive vibration can be detected for corrective action. The a1 day Frequenoy is based on the kROWR ,elia~ilily el Ike e~ei~RaeRI. ~ERT I 3 SR 3.7.11 .2 This SR verifies that the requ ired FBACS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA fi lter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal. (general use and following specific operations) . Specific test frequencies and add itional information are discussed in detail in the VFTP. SR 3.7.11.3 This SR verifies the integrity of the fuel build ing enclosure. The ability of the fuel building to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the FBACS. The FBACS is designed to maintain a slight negative pressure in the fuel building , to prevent unfiltered LEAKAGE. The Frequenoy of 18 months is oonsistent with the guidanoe provided in NUREG 0800, Seotion 6.5.1 (Ref. 5) . ~INSERT 31 ISTS SR 3. 7 .13.4 is modified by a Note. This Note provides clarification that the Surveillance is not applicable when the only movement of irradiated fuel is movement of a spent fuel shipping cask containing irradiated fuel. This Note is necessary to permit the shipping cask to be removed from the fuel handling building . When the side walls are opened to (continued) HBRSEP Unit No. 2 B 3.7-65 Revision No. +:J:
FBACS B 3.7.11 BASES SURVEILLANCE SR 3.7.11 .3 (continued) REQUIREMENTS (continued) permit cask egress, ISTS SR 3.7.13.4 cannot be met. OPERABILITY of the FBACS is not necessary when irradiated fuel assemblies are in a spent fuel shipping cask because irradiated fuel assemblies are protected from damage and associated release of fission products by the cask and other controls associated with shipments of spent fuel assemblies. The terms "shipping cask" and "shipment" used within this specification and bases also applies to the transfer cask/dry fuel storage container used to transfer fuel to the onsite Independent Spent Fuel Storage Installation (ISFSI). REFERENCES 1. UFSAR, Section 6.5.1.
- 2. UFSAR, Section 9.4.5 .
- 3. UFSAR, Sectiqn 15.7.4 .
- 4. 10 CFR 50 .67.
NUREG 0800, Section 6.5.1, Rev. 2, July 1981 . !Deleted. !
- 6. Licensee Event Report (LER) 50-26/97-05 , dated May 22 , 1997.
- 7. Deleted .
- 8. Regulatory Guide 1.183.
HBRSEP Unit No. 2 B 3.7-66 Revision No. ~
Fuel Storage Pool Water Level 8 3.7.12 8 3. 7 PLANT SYSTEMS BASES LCO storage racks. The specified water level preserves the (continued) assumptions of the fuel handling accident analysis (Ref. 3) and time to boil calculations (Ref. 2) . As such , it is the minimum required for fuel movement within the fuel storage pool. APPLICABILITY This LCO applies during movement of irradiated fuel assemblies in the fuel storage pool , since the potential for a release of fission products exists. ACTIONS Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply. When the initial conditions for prevention of an accident cannot be met, steps should be taken to preclude the accident from occurring . When the fuel storage pool water level is lower than the required level, the movement of irradiated fuel assemblies in the fuel storage pool is immediately suspended to a safe position . This action effectively precludes the occurrence of a fuel handling accident. This does not preclude movement of a fuel assembly to a safe position. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action . If moving irradiated fuel assemblies while in MODES 1, 2, 3, and 4 , the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown . SURVEILLANCE SR 3.7.12.1 REQUIREMENTS This SR verifies sufficient fuel storage pool water is available in the event of a fuel handling accident. The water level in the fuel storage pool must be checked periodically. The 7 day rrequency is appropriate because ( continued) HBRSEP Unit No. 2 8 3.7-68 Revision No. G
Fuel Storage Pool Water Level B 3.7.12 B 3.7 PLANT SYSTEMS BASES SURVEILLANCE SR 3.7.12.1 (continued) REQUIREMENTS ., the volume in the pool is normally stable. Water level changes are controlled by plant procedures and are acceptable based on operating experience. ~ During fuel transfer operations, the level in the fuel storage pool is in equilibrium with the refueling canal , and the level in the refueling canal is_ checked daily in accordance with SR 3.9.6.1. REFERENCES 1. UFSAR, Section 9.1.2.
- 2. UFSAR, Section 9.1.3.
- 3. UFSAR, Section 15.7.4.
- 4. 10 CFR 50 .67.
HBRSEP Unit No. 2 B 3.7-69 Revision No.~
Fuel Storage Pool Boron Concentration B3.7.13 BASES ACTIONS The Required Actions are modified by a Note indicating that LCO 3.0.3 does not apply. The movement or storage of fuel in the spent fuel storage pool is independent of reactor operation . Therefore, inability to suspend movement of fuel assemblies or maintain the fuel storage pool boron concentration greater than 1500 ppm is not sufficient reason
. to require a reactor shutdown When the concentration of boron in the fuel storage pool is less than required , immediate action must be taken to preclude the occurrence of an accident or to mitigate the consequences of an accident in progress.
This is most efficiently achieved by immediately suspending the movement of fuel assemblies. Prior to resuming movement of fuel assemblies, the concentration of boron must be restored. This does not preclude movement of a fuel assembly to a safe position. When the concentration of boron in the fuel storage pool is less than required , immediate action must be taken to return the concentration to the required limit to ensure K ett remains less than or equal to 0.95 in the high density storage racks .. SURVEILLANCE SR 3.7.13.1 REQUIREMENTS This SR verifies that the concentration of boron in the fuel storage pool is within the required limit. As long as this SR is met, the analyzed accidents and criticality analyses are fully addressed . The 7 day rrequency is appropriate because no major replenishment of pool *.vater is e*~eeted ta take ~lase aver sush a short ~eriad al time. ~§ERT I 3 REFERENCES 1. UFSAR Section 9.1.2. HBRSEP Unit No. 2 B 3.7-72 Revision No. ~
Secondary Specific Activity B3.7.15 BASES SURVEILLANCE SR 3.7.15 .1 (continued) REQUIREMENTS isotopic concentrations th~t might indicate changes in reactor coolant activity or LEAKAGE.
- The 31 day frequency is based on the detection of increasing trends of the level of DOSE EQUIVALENT I 131 , and allows for *~~"'~riate asliaR ta be takeR ta maiRtaiA levels belaw the bGO limit. ~RT I 3
REFERENCES 1. UFSAR, Chapfer 15.
- 2. . 10 CFR 50 .67.
HBRSEP Unit No. 2 B 3.7-80 Revision No. ~
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE The AC sources are designed to permit inspection and REQUIREMENTS testing of all important areas and features , especially those that have a standby function , in accordance with HBRSEP Design Criteria (Ref. 1). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for demonstrating the OPERABILITY of the DGs are consistent with the recommendations of Regulatory Guide 1.137 (Ref. 6), as addressed in the UFSAR. Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. The minimum steady state output voltage of 467 V is 97% of the nominal 480 V output voltage. It allows for voltage drops to motors and other equipment down through the 120 V level where minimum operating voltage is also usually specified as 90% of name plate rating . The specified maximum steady state output voltage of 493 V is within the maximum operating voltage specified for the motors supplied by the 480 V subsystem . It ensures that for a lightly loaded distribution system , the voltage at the terminals of motors is no more than the maximum rated operating voltages. The specified minimum and maximum frequencies of the DG are 58.8 Hz and 61.2 Hz, respectively. These values are equal to +/- 2% of the 60 Hz nominal frequency and are consistent with the recommendations given in Regulatory Guide 1.9 (Ref. 7) . SR 3.8.1.1 This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source. The 7 day rrequency is adequate since breaker position is not likely to change 1.vithout the operator being aware of ii and ~osa"so its stat"s is dis~layed in l~e sonlrol ream . ~ERT I 3 (continued) HBRSEP Unit No. 2 B 3.8-11 Revision No. e7
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.7 REQUIREMENTS (continued) These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and to maintain the unit in a safe shutdown condition . To minimize the wear on moving parts that do not get lubricated when the engine is not running , these SRs are modified by a Note (Note 2 for SR 3.8.1.2) to indicate that all DG starts for these Surveillances may be preceded by an engine prelube period and followed by a warmup period prior to loading . For the purposes of SR 3.8.1.2 and SR 3.8.1.7 testing , the DGs are started from standby conditions. Standby conditions for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations. In order .to reduce stress and wear on diesel engines, the manufacturer recommends a modified start in which the starting speed of DGs is limited , warmup is limited to this lower speed , and the DGs are gradually accelerated to synchronous speed prior to loading . These start procedures are the intent of Note 3, which is only applicable when such modified start procedures are recommended by the manufacturer. SR 3.8.1.7 requ ires that, at a 184 day Frequency, the DG starts from standby conditions and achieves required voltage and frequency within 10 seconds. The minimum voltage and frequency stated in the SR are those necessary to ensure the DG can accept DBA loading while maintaining acceptable voltage and frequency levels. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application . This period may extend beyond the 10 second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR, HBRSEP Unit No. 2 will monitor and trend the actual (continued) HBRSEP Unit No. 2 B 3.8-12 Revision No. &l-
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR -3.8.1.2 and SR 3.8.1.7 (continued) REQUIREMENTS time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 1O second' start requirement supports the ass1:1mptioris of the design basis LOCA analysi*s in the UFSAR, Chapter 15 (Ref. 4) . The 1O second start requirement is not applicable to SR 3.8.1.2 (see Note 3) when a modified start procedure as described above is used. If a modified start is not used , the 10 second start requirement of SR 3.8.1.7 ap'plies.
- Since SR 3.8.1.7 requires a 10 second start, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2. This is the intent of Note 1 of SR 3.8.1.2. * *
.' )
The 31 day Frequency for SR a.8.'1 .2 is' eonsistent with Regulatory Guide 1".9 (Ref: 7) . *rhe 184 eay"Frequency for SR 3:8.1.7 is a reduction in
* *: cold testiAg consistent with Generic Letter 84
- 15 (Ref. 5) . These
~* Frequencies pro 1Jide adequate assuran*c e of DG OPERABILITY, while
. ~iaimiziag degradali~R re_~"lti~g lro~ testiag . ,
\.** *:, *, , 'c." '*',*. '*,r-;;-. , 1 _ - ~
. SR 3*.*8.1".3* ' * ',. :
This Surveillance verifies thatthe* bGs are capable of synchronizing with the offsite electrical system *an ct*accepting loads approximating the design rating of the DGs: A minimum run tinie of 60 minutes is requ ired to stabilize
. engine temperatures, Wt-lile m-iriimi:Zing the time that the DG is connected to the offsite *source. * * ** -* *, * : *-
. '*. ,.} '
Although nci power factor requireme*nts are established by this SR , the DG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while the 1.0 is a physical limitation. The load band is provided to avoid routine overloading of the DG . Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The J1 day Frequency for this Surveillance is eonsistent with Regulatory G"ide 1.9 (Rel. 7). ~ERT 31 (continued) HBRSEP Unit No. 2 B 3.8-13 Revision No. G
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1 .3 (continued) REQUIREMENTS This SR is modified by five Notes. Note 1 indicates that diesel engine runs for this Surveillance may include gradual loading , as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 2 states that momentary transients , because of changing bus loads, do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. Note 3 indicates that this Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations . Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DG start must precede this test to credit satisfactory performance. Note 5 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus . This reduces exposure of the DG to undue risk of damage that might render it inoperable. SR 3.8.1.4 This SR provides verification that the level of fuel oil in the day tank is at or above the level at which fuel oil is automatically added . The level specified is 140 gallons , which is approximately equal to 1/2 full , and is selected to ensure adequate fuel oil for a minimum of 35 minutes of DG operation at full load plus 10%. The a1 day Frequency is adequate to assure that a sufficient supply of fuel oil is available, since low level alarms are provided and facility operators
,..,ould be a,Nare of any large uses of fuel oil during this period . ,
SR 3.8.1.5 ~ Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling , but all must have a water environment in order to survive. Removal of water from the fuel oil day tanks once every a1 days eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling . In addition , it eliminates the potential for water entrainment in the fuel oil during DG operation . Water may (continued) HBRSEP Unit No. 2 B 3.8-14 Revision No. Q
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.5 (continued) REQUIREMENTS come from any of several sources, including condensation , ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system . The Surveillance r"requencies are established by Regu latory Guide 1.137 (Ref. 6) . This SR is for preventative maintenance. he presence of water does not necessarily represent failure of this provided the accumulated water is removed during the performanc of this Surveillance. INSERT 3 SR 3.8.1.6 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from the storage tank to its associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed , and the controls and control systems for automatic fuel transfer systems are OPERABLE. The frequency of 31 days is based on the design of fuel transfer system. The pumps operate automatically in order to maintain an adequate volume of fuel oil iR !Re Elay laRks El"riRg or foll&WiRg EJG lesliRg. ~ERT I 3 SR 3.8.1 .7 See SR 3.8.1 .2. SR 3.8.1.8 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which , if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG load (continued) HBRSEP Unit No. 2 B 3.8-15 Revision No. 0
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1 .8 (continued) REQUIREMENTS response characteristics and capability to reject the largest single load without exceeding the overspeed trip. For this unit, the single load for each DG is a safety injection pump rated at 380 Brake Horsepower. This Surveillance may be accomplished by:
- a. Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus; or
- b. Tripping its associated single largest post-accident load with the DG solely supplying the bus.
The 18 month Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 8) . ~INSERT 3 1 This SR is modified by two Notes. The reason for Note 1 is that during operation with the reactor critical , performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and , as a result, unit safety systems. In order to ensure that the DG is tested under load conditions that are as close to design basis conditions as possible, Note 2 requires that, if synchronized to offsite power, testing must be performed using a power factors; 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience. SR 3.8.1.9 This Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source . This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time. The DG autostart time of 10 seconds is derived from requirements of the accident analysis to respond to a design (continued) HBRSEP Unit No. 2 B 3.8-16 Revision No. G
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.9 (continued) REQUIREMENTS basis large break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability is achieved . The requirement to verify the connection and power supply of permanent and auto connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, emergency Core Cooling Systems (ECCS) injection valves are not required to be stroked open, or high pressure injection systems are not capable of being operated at full flow, or residual heat removal (RHR) systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG systems to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified .
+he frequensy of 18 months takes into sonsideration unit sonditions required to perform the Surveillanse, and is intended to be sonsistent with expested fuel sysle lengths. ~
This SR is modified by three Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing . For the purpose of this testing , the DGs must be started from standby conditions , that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus. This reduces exposure of the DG to undue risk of damage that might render it inoperable. (continued) HBRSEP Unit No. 2 B 3.8-17 Revision No. G
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.10 REQUIREMENTS (continued) This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates for~ 5 minutes. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application . This period may extend beyond the 1O second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR, HBRSEP Unit No. 2 will monitor and trend the actual time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.1 O.d and SR 3.8.1.1O.e ensure that permanently connected loads and emergency loads are energized from the offsite electrical power system on an ESF signal without loss of offsite power. The requirement to verify the connection of permanent and autoconnected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation . For instance, ECCS injection valves are not required to be stroked open , or high pressure injection systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation . In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential , overlapping , or total steps so that the entire connection and loading sequence is verified . The Frequency of 18 months takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with the mEpected fue l cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the (continued) HBRSEP Unit No. 2 B3.8-18 Revision No. G
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1 .1~ (continued) REQUIREMENTS 18 month frequency. Therefore, the frequency was concluded to be acceptable from a reliability standpoint. ~ This SR is modified by three Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing . For the purpose of this testing , the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that during operation with the reactor critical , performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and , as a result, unit safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus . This reduces exposure of the DG to undue risk of damage that might render it inoperable. SR 3.8.1.11 This Surveillance demonstrates that DG noncritical protective functions (e.g., high coolant water temperature) are bypassed . A manual switch is provided which bypasses the non-critical trips. The noncritical trips are normally bypassed during DBAs and provide an alarm on an abnormal engine condition . This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG . This SR is satisfied by simulating a trip signal to each of the non-critical trip devices and observing the DG does not receive a trip signal. The 24 month frequency is based on engineering judgment and is intended to be consistent with DG maintenance interval. The equipment being tested is a manually operated switch . Therefore, frequency was soasluEleEI lo be asse~lable lrom a reliabilily slaREl~oiRI. ~ R T I 3 ( continued) HBRSEP Unit No. 2 B 3.8-19 Revision No. ~
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.12 REQUIREMENTS This SR requires demonstration once per 18 months that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours, ~ 1. 75 hours of which is at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG . The DG start shall be a manually initiated start followed by manual syncronization with other power sources. Additionally, the DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup , discussed in SR 3.8.1.2, and for gradual loading , discussed in SR 3.8.1.3, are applicable to this SR. In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a power factor of !5: 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience. The load band is provided to avoid routine overloading of the DG . Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The 18 month rrequency takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. ~ This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the power factor limit will not invalidate the test. The reason for Note 2 is that during operation with the reactor critical , performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and , as a result, unit safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus. (continued) HBRSEP Unit No. 2 B 3.8-20 Revision No. 30
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.12 (continued) REQUIREMENTS This reduces exposure of the DG to undue risk of damage that might render it inoperable. SR 3.8.1.13 This Surveillance demonstrates that the diesel engine can restart from a hot condition , such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 1O seconds. The 10 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed . This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application . This period may extend beyond the 1O second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR, HBRSEP Unit No. 2 will monitor and trend the actual time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 18 month r"requency is based on engineering joogment and is intended to be consistent with expected fuel cycle lengths. , This SR is modified by two Notes. Note 1 ensures that the test is ~ performed with the diesel sufficiently hot. The load band is provided to avoid routine overloading of the DG . Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The requirement that the diesel has operated for at least 2 hours at full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing . (continued) HBRSEP Unit No. 2 B 3.8-21 Revision No. G
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.14 REQUIREMENTS (continued) Under accident and loss of offsite power conditions, loads are sequentially connected to the bus by the automatic load sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents . The
+/- 0.5 seconds load sequence time setpoint tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equ ipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses.
The Frequency of 18 months takes into consideration unit conditions required to perform the Surveillance , and is intended to be consistent with expected fuel cycle lengths. ~ This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system , and challenge safety systems. SR 3.8.1.15 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel , RCS , and containment design limits are not exceeded . This Surveillance demonstrates the DG operation , as discussed in the Bases for SR 3.8.1.9, during a loss of offsite power actuation test signal in conjunction with an ESF actuation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential , overlapping , or total steps so that the entire connection and loading sequence is verified . The Frequency of 18 months takes into consideration unit conditions required to perform the SuF\1eillance and is intended to be consistent with aa e*~esle<l l<lel sysle leagtR at 18 meatlls. ~ R T I 3 (continued) HBRSEP Unit No. 2 B 3.8-22 Revision No. Q
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.15 (continued) REQUIREMENTS This SR is modified by three Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing . For the purpose of this testing , the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations for DGs. The reason for Note 2 is that the performance of the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system , and challenge safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus. This reduces exposure of the DG to undue risk of damage that might render it inoperable. SR 3.8.1.16 Transfer of the 4.160 kV bus 2 power supply from the auxiliary transformer to the start up transformer demonstrates the OPERABILITY of the offsite circuit network to power the shutdown loads. In lieu of actually initiating a circuit transfer, testing that adequately shows the capability of the transfer is acceptable. This transfer testing may include any sequence of sequential , overlapping , or total steps so that the entire transfer sequence is verified . The 18 month Frequenoy is based on engineering judgement taking into oonsideration the plant oonditions required to perform the Surveillance, and is intended to be oonsistent with expeoted fuel oyole length. ~ This SR is modified by two Notes. The reason for Note 1 is that, during operation with the reactor critical , performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. As stated in Note 2, automatic transfer capability to the SUT is not required to be met when the associated 4.160 kV bus and Emergency Bus are powered from the SUT. This is acceptable since the automatic transfer capability function has been satisfied in this condition . (continued) HBRSEP Unit No. 2 B 3.8-23 Revision No. Q
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1 .17 REQUIREMENTS (continued) This Surveillance demonstrates that the DG starting independence has not been compromised . Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the DGs are started simultaneously. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed . This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application . This period may extend beyond the 10 second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR , HBRSEP Unit No. 2 will monitor and trend the actual time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 10 year Frequency is based on engineering judgment. ~ This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing . For the purpose of this testing , the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. REFERENCES 1. UFSAR, Section 3.1.
- 2. UFSAR , Chapter 8.
- 3. UFSAR, Chapter 6.
- 4. UFSAR, Chapter 15.
- 5. Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," July 2, 1984.
- 6. Regulatory Guide 1.137, Rev. 1, October 1979.
(continued) HBRSEP Unit No. 2 B 3.8-24 Revision No. 0
AC Sources - Operating B 3.8.1 BASES REFERENCES 7. Regulatory Guide 1. 9, Rev. 3, July 1993. (continued) Regulatory Guide 1.108, Rev. 1, August 1977. !Deleted .!
- 9. Regulatory Guide 1.93 , Rev. 0, December 1974.
HBRSEP Unit No. 2 B 3.8-25 Revision No. 0
Diesel Fuel Oil and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.1 (continued) REQURIEMENTS The 7 day Frequency is adequate to ensure that a sufficient supply of fuel oil is a1.iailable, since low level alarms are provided for the U2 DG fuel oil tank and unit operators would be aware of any large uses of fuel oil au,ia~ tllis pefiod. ~ERT I 3 SR 3.8.3.2 The tests listed in the Diesel Fuel Oil Testing Program (API or Specific Gravity, Cloud Point, Water and Sediment, and Viscosity) are a means of determining whether fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion . If results from these tests are within acceptable limits, the fuel oil is acceptable for use. New fuel oil received for storage in the Unit 1 1-C turbine fuel oil storage tank and subsequently transferred to the Unit 2 DG fuel oil storage tank is verified to meet the limits below prior to adding to the Unit 1 1-C storage tanks either by verifying the integrity of the seal on the tank truck against the certificate of compliance or by testing of the fuel oil on the truck prior to transfer. Additionally, stored fuel in the Unit 1 1-C storage tank and in the Unit 2 DG fuel oil storage tank is tested every 31 days. The sampling methodology, tests, and limits are as follows:
- a. Sampling of three vertical IC Turbine tanks is performed as a single entity by recirculating the tanks and sampling at the Unit 1 transfer pump discharge. Sampling of the remaining vertical Unit 1 tank is performed independently from the bottom drain connection . Sampling of the Unit 2 DG fuel oil storage tank is performed from the discharge from the fuel oil storage tank transfer pump (Ref.3); and
- b. Verify in accordance with applicable ASTM standards that the sample has an API gravity of:::: 28, a Saybolt viscosity at 100°F of
- 32 SUS and s 50 SUS , water and sediment s 0.10%, and cloud points 10°F.
Failure to meet any of the limits except cloud point is cause for rejecting the fuel oil. Cloud point will be managed by the Diesel Fuel Oil Testing Program . (continued) HBRSEP Unit No. 2 B 3.8-36 Revision No. ea
Diesel Fuel Oil and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.3 REQUIREMENTS (continued) This Surveillance ensures that, without the aid of the refill compressor, sufficient air start capacity for each DG is available. The system design requirements provide for a minimum of eight engine start cycles without recharging . The pressure specified in this SR is intended to reflect the lowest value at which the eight starts can be accomplished . The 31 day rrequency takes into account the capacity, capability, redundancy, and diversity of the /\C sources and other indications available in the control room, including alarms, to alert the operator to below aarmal air start press"re. ~RT I 3 SR 3.8.3.4 Microbiological fouling is a major cause of fuel oil degradation . There are numerous bacteria that can grow in fuel oil and cause fouling , but all must have a water environment in order to survive. Removal of water from the Unit 2 DG fuel storage tank once e¥ery 31 days eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling . In addition , it eliminates the potential for water entrainment in the fuel oil during DG operation . Water may come from any of several sources, including condensation , ground water, rain water, and contaminated fuel oil , and from breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. This SR is for preventive maintenance. The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during performance of the Surveillance. ~ - - - - - - - -- ----=! - _INSERT 3 1-- I - - - - - - - - - -- - REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
- 3. CP&L Letter to NRC dated November 20, 1981 , "Quality Assurance Requirements Regarding Diesel Generator Fuel Oil."
HBRSEP Unit No. 2 B 3.8-37 Revision No. G
DC Sources - Operating 8 3.8.4 ACTIONS 8.1 and 8 .2 (continued) required unit conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function . Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery (or battery cell) and maintain the battery (or a battery cell) in a fully charged state. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the initial voltages assumed in the battery sizing calculations and permit a single battery cell to be jumpered out. The 7 day frequency is consistent with manufacturer recommendations and IEEE 450 (Ref. 5) . ~.----'----.
~RT3l SR 3.8.4.2 Visual inspection of the battery cells , cell plates, and battery racks provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance.
The 18 month frequency is based on engineering judgment and operational experience and is sufficient to detect battery and rack 8egra8atiea ea a leag term Basis. [Ns'ERT I 3 SR 3.8.4.3 Visual inspection of intercell, intertier, and terminal connections provide an indication of physical damage or abnormal deterioration that could indicate degraded battery condition . The anticorrosion material is used to help ensure good electrical connections and to reduce terminal deterioration. The visual inspection for corrosion is not intended to require removal of and inspection under each (continued) H8RSEP Unit No. 2 8 3.8-42 Revision No. 0
DC Sources - Operating B 3.8.4 SURVEILLANCE SR 3.8.4.3 (continued) REQUIREMENTS term inal connection. The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR provided visible corrosion is removed during performance of SR 3.8.4.3. The 18 month frequency is based on engineering judgment taking into consideration the likelihood of a change in component or system status. IT:ERT3! SR 3.8.4.4 This SR requires that each battery charger be capable of supplying 300 amps and 125 V for 2!: 4 hours. These current and voltage requ irements are based on the design capacity of the chargers. The battery charger supply is based on normal DC loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state. The minimum required amperes and duration ensures that these requirements can be satisfied . The Surveillance rrequency is acceptable, gii.1en the other administrati*,e controls existing to ensure adequate charger performance during these 18 month intervals. In addition , this rrequency is intended to be ooasisteat witR expeste8 fuel oy,;le lea9tRs. ~ERT I 3 SR 3.8.4 .5 A battery service test is a special test of battery capability, as found , to satisfy the design requirements (battery duty cycle) of the DC electrical power system . The discharge rate and test length should correspond to the design duty cycle requirements. !INSERT 3 !i-----+) This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test. (continued) HBRSEP Unit No. 2 B 3.8-43 Revision No. 29
DC Sources - Operating B 3.8.4 SURVEILLANCE SR 3.8.4.6 (continued) REQUIREMENTS The acceptance criteria for this Surveillance are consistent with IEEE-450 (Ref. 5) . This reference recommends that the battery be replaced if its capacity is below 80% of the manufacturer's rating . A capacity of 80% shows that the battery rate of deterioration is increasing , even if there is ample capacity to meet the load requirements. An acceptance criterion of 80% of rated capacity is applicable to the "A" battery only. An acceptance criterion of 91 % is applicable to the "B" battery since the battery's capacity is not as great. The 5urveillanse Frequensy for this test is normally 60 months. If the battery shows degradation , or if the battery has reashed 85% of its expested life with sapasity < 100% of manufasturer's rating , the 5urveillanse Frequensy is redused to 12 months. Degradation is indisated , assording to IEEE 450 (Ref. 5) , when the battery sapasity drops by more than 10% relative to its average on the previous performanse tests or when it is> 10% below the manufasturer's rating . Hovt'ever, if the battery shows no degradation but has reashed 85% of its expested life, the 5urveillanse Frequensy is only redused to 24 months for batteries that retain sapasity ~ 100% of the manufasturer's ratings. These Frequensies are sonsistent with the resommendations in IEEE 450 (Ref. 5) . ~ This SR is modified by a Note. The reason for the Note is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems . REFERENCES 1. UFSAR Section 3.1.
- 2. UFSAR, Chapter 8.
- 3. UFSAR, Chapter 6.
- 4. UFSAR, Chapter 15.
- 5. IEEE-450- 1995.
HBRSEP Unit No. 2 B 3.8-45 Revision No. ~
Battery Cell Parameters B 3.8.6 BASES ACTIONS A.1, A.2 , and A.3 (continued) considered reasonable. The verification is repeated at 7 day intervals until the parameters are restored to Category A or B limits. This periodic verification is consistent with the normal Frequency of pilot cell Surveillances. Continued operation is only permitted for 31 days before battery cell parameters must be restored to within Category A and B limits. With the consideration that, while battery capacity is degraded , sufficient capacity exists to perform the intended function and to allow time to fully restore the battery cell parameters to normal limits, this time is acceptable prior to declaring the battery inoperable. With one or more batteries with one or more battery cell parameters outside the Category C limit for any connected cell , sufficient capacity to supply the maximum expected load requirement is not assured and the corresponding DC electrical power subsystem must be declared inoperable. Additionally, other potentially extreme conditions, such as not completing the Required Actions of Cond ition A with in th e required Completion Time or average electrolyte temperature of representative cells falling below 67°F are also cause for immediately declaring the associated DC electrical power subsystem inoperable. SURVEILLANCE SR 3.8.6.1 REQUIREMENTS This SR verifies that Category A battery cell parameters are consistent with IEEE-450 (Ref. 3) , which recommends regular battery inspections (at least one per month) including voltage (measured to the nearest 0.01 Volts) , specific gravity, and electrolyte temperature of pilot cells. In addition , if water is added to any pilot cell , the amount must be recorded . Data attained must be compared to the data from the previous SR to detect signs of abuse or deterioration. ,
~
(continued) HBRSEP Unit No. 2 B 3.8-52 Revision No. G
Battery Cell Parameters B 3.8.6 BASES SURVEILLANCE SR 3.8.6.2 REQUIREMENTS (continued) The quarterly inspection of specific gravity and voltage is consistent with
~:e-4.:~ ~~ ~ ln addition , within 24 hours of a battery discharge
< 11 O V or a e overcharge > 150 V, the battery must be demon ed to meet Category B limits. Transients , which may entarily cause battery voltage to drop to s 110 V, do not constitute a battery discharge provided the battery terminal voltage and float current INSERT 3 return to pre-transient values . This inspection is also consistent with IEEE-450 (Ref. 3) , which recommends special inspections following a severe discharge or overcharge, to ensure that no significant degradation of the battery occurs as a consequence of such discharge or overcharge.
If water is added to any battery cell , the amount must be recorded . Data obtained must be compared to the data from the previous SR to detect signs of abuse or deterioration. SR 3.8.6.3 This Surveillance verification that the average temperature of representative cells is ~ 67°F is consistent with a recommendation of IEEE-450 (Ref. 3) , that states that the temperature of electrolytes in representative cells should be determined on a quarterly basis. Data obtained must be compared to the data from the previous SR to detect signs of abuse or deterioration. Lower than normal temperatures act to inhibit or reduce battery capacity. This SR ensures that the operating temperatures remain within an acceptable operating range. This limit is based on manufacturer recommendations.
!INSERT 31--!- )
Table 3.8.6-1 This table delineates the limits on electrolyte level , float voltage, and specific gravity for three different categories. The meaning of each category is discussed below. Category A defines the normal parameter limit for each designated pilot cell in each battery. The cells selected (continued) HBRSEP Unit No. 2 B 3.8-53 Revision No. Q
AC Instrument Bus Sources - Operating B 3.8.7 BASES ACTIONS B.1 and B.2 (continued) 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and associated AC instrument buses energized from the Inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation of the RPS and ESFAS connected to the AC instrument buses. The 7 day F"requency takes into account the redundant capability of the Instrument Bus Sources and other indications available in the control room that alert the operator to inverter malfunolions. [Nsf:RT I 3 SR 3.8.7.2 This surveillance verifies that the required circuit breakers are closed and the associated instrument buses energized from the CVTs. Actual measurement of voltage is not required . Confirmation that the buses are energized by observing status lights, instrument displays, etc., is sufficient to confirm the instrument buses are energized. The 7 day frequency takes into account the redundant capability of the AC instrument bus sources and administrative requirements governing alignment of eleotrioal eq"i~ment. ~s'ERT I 3 REFERENCES 1. UFSAR, Chapter 6.
- 3. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.8-60 Revision No. G
AC Instrument Bus Sources - Shutdown B 3.8.8 BASES ACTIONS A.1, A.2 .1, A.2 .2, A.2.3 , and A.2.4 (continued) The Completion Time of immediately is consistent with the required times for actions requiring prompt attention . The restoration of the required AC Instrument Bus Sources should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a non-preferred source. SURVEILLANCE SR 3.8.8 .1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and required AC instrument buses energized from the inverter and that required circuit breakers are closed and required instrument buses are energized from the CVTs or other sources, as allowed by LCO 3.8.8.b. The verification of proper voltage and frequency output for the inverters ensures that the required power is readily available for the instrumentation connected to the associated AC instrument buses. The 7 day Frequency takes into account the redundant capability of the AC Instrument Bus gources, other indications available in the control room that alert the operator to inverter malfunctions , and administrative requirements governing alignment of electrical equipment. ~INSERT 3! This SR is modified by a Note which states that voltage and frequency measurement is not required for the AC instrument buses supplied from CVTs. For these buses , observing status lights, instrument displays, etc. is sufficient to confirm that the required power is readily available to the AC instrument buses supplied from CVTs REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.8-64 Revision No. e,4e Amendment No. 4QQ
Distribution Systems - Operating B 3.8.9 BASES ACTIONS F.1 and F.2 (continued) If the inoperable distribution subsystem cannot be resto red to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable , based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. With two trains with inoperable distribution subsystems that result in a loss of safety function , adequate core cooling , containment OPERABILITY and other instrument functions for OBA mitigation would be compromised , and immediate plant shutdown in accordance with LCO 3.0.3 is requi red . SURVEILLANCE SR 3.8.9.1 REQUIREMENTS This Surveillance verifies that the required AC , DC, and AC instrument bus electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained , and the appropriate voltage is available to each required bus. The 7 day Frequency takes into account the redundant capability of the AC , DC, and AC instrument bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions. ~ This SR is modified by a Note which states that Voltage measurement is not required for the AC Instrument buses supplied from Constant Voltage Transformers (CVTs) . For these buses confirmation that the buses are energized by observing status lights, instrument displays, etc., is sufficient to confirm the buses are energized . (continued) HBRSEP Unit No. 2 B 3.8-75 Revision No. Q
l Distribution Systems - Operating B 3.8.9 BASES SURVEILLANCE SR 3.8.9.2 and SR 3.8.9.3 REQUIREMENTS (continued) The two breakers associated with each ABT will trip on over current as required to prevent fault from affecting both trains of the AC Distribution System . The 18 month Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions desirable for performing the Surveillance, and is intended to be consistent with mcpected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency. Therefore the Frequency was concluded to be acceptable from a reliability standpoint. ~ - - - - -- -- - - - ----=J ------1_INSERT 4 ,_ REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
- 3. SER for HBRSEP Unit No. 2 Amendment 123, dated Sept. 5, 1989
- 4. Regulatory Guide 1.93, December 1974.
HBRSEP Unit No. 2 B 3.8-76 Revision No. Q
Distribution System - Shutdown B 3.8.10 BASES ACTIONS A.1, A.2.1, A.2.2, A.2 .3, A.2.4, and A.2 .5 (continued) Therefore, Required Action A.2.5 is provided to direct declaring RHR inoperable, which results in taking the appropriate RHR actions. The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power. SURVEILLANCE SR 3.8.10.1 REQUIREMENTS This Surveillance verifies that the AC, DC, and AC instrument bus electrical power distribution subsystems are functioning properly, with all the buses energized . The 7 day Frequency takes into account the capability of the electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions. ~ This SR is modified by Note which states that voltage measurement is not required for the AC Instrument buses supplied from Constant Voltage Transformers (CVTs) . For these buses confirmation that the buses are energized by observing status lights, instrument displays, etc., is sufficient to confirm the buses are energized. REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.8-81 Revision No. ~ Amendment No. 4W
Boron Concentration B 3.9.1 BASES ACTIONS A.3 (continued) the operator should begin boration with the best source available for unit conditions. Once actions have been initiated , they must be continued until the boron concentration is restored . The restoration time depends on the amount of boron that must be injected to reach the requ ired concentration . SURVEILLANCE SR 3.9.1 .1 REQUIREMENTS This SR ensures that the coolant boron concentration in the RCS , the refueling canal , and the refueling cavity is within the COLR lim its. The boron concentration of the coolant in each volume is determined periodically by chemical analysis . A minimum frequency of once every 72 hours is a reasonable amount of time to verify the boron concentration of representative samples. The frequency is based on operating e*perience, which has shown 72 hours to be adequate. ~ INSERT 3 I REFERENCES 1. UFSAR, Section 3.1.
- 2. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.9-4 Revision No. Q,4e Amendment No. 49G
Nuclear Instrumentation B 3.9.2 BASES SURVEILLANCE SR 3.9.2.1 REQUIREMENTS SR 3.9.2.1 is the performance of a CHANNEL CHECK, which is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that the two indication channels should be consistent with core conditions. Changes in fuel loading and core geometry can result in significant differences between source range channels , but each channel should be consistent with its local conditions. The Frequency of 12 hours is consistent with the CH/1.f!.lNEL CHECK FrReq"""GY spesifie~ similarly for tile same iRstF<1meats iR LGO 3.3.1. ~ERT :I 3 S 3.9.2.2 SR 3.9.2 .2 is the performance of a CHANNEL CALIBRATION evefJf 18 months. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the source range neutron flux monitors consists of obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. The CHANNEL CALIBRATION for the PAM source range neutron flux monitors only applies to the portion of the channel applicable to providing visual indication of neutron count rate in the Control Room. T-Re 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage. Operating e*perience has shown these components usually pass the Surveillance when performed at the 18 month Frequency. ~ - - - - - - - - - - - - - - - - - - -----=:i - _lNSERT 3 I,_- - - REFERENCES 1. UFSAR, Section 3.1.
- 2. UFSAR, Section 15.4.6.
HBRSEP Unit No. 2 B 3.9-7a Revision No. 5, 16, 17, 18 Amendment No. 180, 1QO
Containment Penetrations B 3.9.3 BASES (continued) APPLICABILITY for the limitting fuel handling accident. In MODES 1, 2, 3, (continued) and 4, containment penetration requirements are addressed by LCO 3.6.1. In MODES 5 and 6, when movement of irradiated fuel assemblies within containment is not being conducted, the potential for a fuel handling accident does not exist. Additionally, due to radioactive decay, a fuel handling accident involving handling fuel that was not recently irradiated (i.e., fuel that has not occupied part of a critical reactor core within the previous 116 hours) will result in doses that are well within the guideline values specified in 10 CFR 50.67 even without containment closure capability. Therefore, under these conditions no requirements are placed on containment penetration status. ACTIONS If the containment equipment hatch, air lock, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere is not in the required status, including the Containment Ventilation Isolation System not capable of automatic actuation when the containment ventilation valves are open , the unit must be placed in a condition where the isolation function is not needed. This is accomplished by immediately suspending movement of recently irradiated fuel asse.mblies within containment. Performance of these actions shall not preclude completion of movement of a component to a safe position. SURVEILLANCE SR 3.9.3.1 REQUIREMENTS This Surveillance demonstrates that each of the containment penetrations required to be in its closed position is in that position . The Surveillance on the open ventilation valves will demonstrate that the valves are not blocked from closing. Also the Surveillance will demonstrate that each valve operator has motive power, which will ensure that each valve is capable of being closed by an OPERABLE automatic containment ventilation isolation signal. The Surveillance is performed e'1ery 7 days during mo¥ement of recently irradiated fuel assemblies within containment. This Surveillance ensures that a postulated fuel handling (continued) HBRSEP Unit No. 2 B 3.9-11 Revision No. -73
Containment Penetrations B 3.9.3 BASES SURVEILLANCE SR 3.9.3.1 (continued) REQUIREMENTS *
- Accident involving handling recently irradiated fuel that releases fission product radioactivity within the containment will not -result in a significant release of fission product radioactivity to the environment. ~
. -- ~
SR
- 3.9.3,2 This Surveillance demonstrates that each containment ventilation valve actuates to its isolation position' on manual initiation or on an actual or simulated high radiation signal. The 18 month frequency maintains consistency with other similar instrumentation and valve testing requirements. In LCO 3.3.6, the Containment Ventilation Isolation instrumentation requires a CHANNEL CHECK e11ery 12 hours and a COT
- every 92 days to ensure the channel G"P ERABILITY during refueling operations. Every 18 months a CHANNEL* CALIBRATION is performed .
Tne system actuation response tirtie is demonstrated every 18 months, during.. refueling , oh a STAGGERED' TEST BASIS . -SR 3.6.3 .5
-demonstrates th'a t the isolatioh time ofeacti valve\ s in accordance with the lnserv"ice Testing Program requirements. These Surveillances
*, '* *performed during MODE 6 'will ensure*that the valves are capable of
*, closing after*a postulated-'fue1 handlr-ng accident involving handling
\ ;. \ ecehtly irradiated fuel -to limit'a' (elease of fission product radioactivity from the containment. ~
* ~ INSERT 3 !1----- - - - - - - -
REFERENCES 1. UFSAR, Section 15.7.4. HBRSEP Unit No. 2 B 3.9-12 Revision No. ~
RHR and Coolant Circulation - High Water Level B 3.9.4 BASES ACTIONS (continued) If RHR train requirements are not met, actions shall be initiated and continued in order to satisfy RHR train requirements. With the unit in MODE 6 and the refueling water level ~ 23 ft above the top of the reactor vessel flange , corrective actions shall be initiated immediately. A.4 If RHR train requirements are not met, all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere must be closed within 4 hours. With the RHR train requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Closing containment penetrations that are open to the outside atmosphere ensures dose limits are not exceeded . The Completion Time of 4 hours is reasonable, based on the low probability of the coolant boiling in that time. SURVEILLANCE SR 3.9.4.1 REQUIREMENTS This Surveillance requires verification every 12 hours that one train is in operation. Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. The Frequency of 12 hours is sufficient, considering the other indications and alarms available to the operator in the control room for monitoring the RHR System . ~ INSERT 31 REFERENCES 1. UFSAR, Section 5.4.4. HBRSEP Unit No. 2 B 3.9- 16 Revision No. G;-4e Amendment No. 49G
RHR and Coolant Circulation - Low Water Level B 3.9.5 BASES (continued) SURVEILLANCE SR 3.9.5.1 REQUIREMENTS This SR requires verification e11ery 12 hours that one train is in operation. Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. :+Re F'requency of 12 hours is sufficient considering other indications and alarms available to the operator in the control room to monitor Rl9R train
~elformaRGe. [NsERT I 3
SR 3.9.5.2 Verification that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation , if needed , to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pump. The F'requency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating mcperience. ~
----=J
----1_INSERT 31- - - - -
REFERENCES 1. UFSAR, Section 5.4.4. HBRSEP Unit No. 2 B 3.9-20 Revision No. G,4-& Amendment No.-1-QG
Refueling Cavity Water Level B 3.9.6 BASES (continued) SURVEILLANCE SR 3.9.6.1 (continued) REQUIREMENTS The rrequency of 24 hours is based on eng ineering judgment and is considered adequate in view of the large volume of water and the normal procedural controls of valve positions, which make significant unplanned level changes unlikely. ~ REFERENCES 1. UFSAR, Section 15.7.4.
- 2. 10 CFR 50.67.
- 3. Regulatory Guide 1.183.
HBRSEP Unit No. 2 B 3.9-23 Revision No. ~
Containment Purge Filter System B 3.9.7 BASES ACTIONS A.1and A.2 (continued) closed . Closure may be achieved by a closed manual or automatic valve , blind flange , or equivalent method . Equivalent closure methods must be approved and may include use of a material that can provide a temporary atmospheric pressure, ventilation barrier for the penetration during fuel movements. Alternately, Required Action A.2 may be taken to place the unit in a condition in which the LCO does not apply. Required Action A.2 requires immediate suspension of movement of recently irradiated fuel assemblies in containment. Suspension of this activity does not preclude the movement of fuel to a safe position . SURVEILLANCE SR 3.9.7.1 REQUIREMENTS This SR verifies that the relative humidity of the containment atmosphere to be processed by the Containment Purge Filter System is ~ 70%. This ensures that the testing performed to validate the safety analysis assumptions relative to charcoal filter efficiency, bounds actual plant conditions for relative humidity at the inlet of the Containment Purge Filter System charcoal filter. The one hour Frequency is based on engineering judgment considering the likelihood of changes in containment relative A*R'lidily d*Fing Fel*eling **lages. ~ERT I 3 SR 3.9.7.2 This SR verifies that the Containment Purge Filter System is in operation and maintaining containment pressure negative relative to the adjacent auxiliary building areas once every 12 hours. This verification ensures that containment pressure is being maintained negative with respect to the outside atmosphere since the pressure of the auxiliary building areas is normally maintained negative with respect to the outside atmosphere. The Containment Purge Filter (continued) HBRSEP Unit No. 2 B 3.9-26 Revision No. ~
Containment Purge Filter System B 3.9.7 BASES SURVEILLANCE SR 3.9.7.2 (continued) REQUIREMENTS System is assumed to maintain a slight negative pressure in the
- containment, to prevent unfiltered leakage to the outside atmosphere.
The Frequency of 12 hours is sufficient considering other indications ai.ia+lable to the operator to monitor Containment Purge Filter System o~eratioa. s:ERT j 3 SR 3.9.7.3 This SR verifies that the required Containment Purge Filter System filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP) . The VFTP includes testing HEPA filter performance , charcoal adsorber efficiency, system flow rate, and the physical properties of the activated charcoal (general use and following specific operations) . Specific test frequencies and additional information are discussed in detail in the VFTP . REFERENCES 1. UFSAR, Section 6.5.1.
- 2. UFSAR, Section 9.4.3.
- 3. UFSAR, Section 15.7.4 .
- 4. 10 CFR 50.67.
HBRSEP Unit No. 2 B 3.9-27 Revision No. ~ to RNP-RA/18-0015 Page 1 ATTACHMENT 5 License Amendment Request H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP) Docket No. 50-261 Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3) TSTF-425 (NUREG-1431) vs. HBRSEP Cross-Reference to RNP-RA/18-0015 Page 2 Technical Specification Section Title/Surveillance Description* TSTF-425 HBRSEP Definitions 1.1 1.1 Staaaered Test Testing Shutdown Margin (SDM) 3.1.1 3.1.1 Verify SOM within limits 3.1.1 .1 3.1.1.1 Core Reactivity 3.1.2 3.1.2 Verify core reactivity within predicted values ' 3.1.2.1 3.1 .2.1 Rod Group Alignment Limits 3.1.4 3.1.4 Verify inidividual rod positions within aliqnment limit 3.1.4.1 3.1.4.1 Verify rod freedom of movement (trippability) 3.1.4.2 3.1.4.2 Shutdown Bank Insertion Limits 3.1.5 3.1.5 Verify shutdown bank within insertion limits specified in COLR 3.1.5.1 3.1.5.1 Control Bank Insertion Limits 3.1.6 3.1.6 Verify cohtroi bank is within the insertion limits specified in COLR 3.1.6.2 3.1.6.2 Verify sequence and overlap limits specified in COLR 3.1.6.3 3.1.6.3 PHYSICS TESTS Exceptions - MODE 2 3.1.8 3.1.8 Verify RCS lowest loop averaQe temperature 3.1.8.2 3.1.8.2
' Verify thermal power 3.1.8.3 3.1.8.3 Verify SOM within limits specified in COLR 3.1.8.4 3.1.8.4 Heat Flux Hot Channel Factor (FQ(Z)) (CAOC-Fxv Methodology) 3.2.1A ---------
Verify° measured values of F0 (Z) 3.2.1 .1 --------- Verify F\v < FLxv 3.2.1 .2 ---------
- Heat Flux Hot .Channel Factor (FQ(Z)) (RAOC-W(Z) Methodology}
- 3.2.1.B u o ****** **
Verify Fac(Z) is within limit 3.2.1.1 ------- Verify F0 w(Z) within limit 3.2.1.2 --------- Heat Flux Hot Channel Factor (FQ(Z)) (CAOC-W(Z) Methodolog}'.} 3.2.1C 3.2.1 Verify F0 c(Z) is within limit 3.2:1 .1 -~------- Verify F0 w(Z) within limit (NOTE: HBRSEP*uses the nomenclature F0 v(Z), which is equivalent) 3.2.1 .2 3.2.1.1 to RNP-RA/18-0015 Page 3 Nuclear Enthalpy Rise Hot Channel Factor (FN AH) 3.2.2 3.2.2 Verify FN t.H within limits specified in COLR 3.2.2.1 3.2.2.1 AXIAL FLUX DIFFERENCE (AFD) (Constant ~ial Offset Contro.1-(CAOC) Methodology) 3.2.3A 3.2.3 Verify AFD is within limits - - 3.2.3.1 3.2.3.1 Update target flux difference 3.2.3.2 ------ Determine, by measurement, target flux difference 3.2.3.3 3.2.3.3 AXIAL FLUX DIFFERENCE (AFD).(Relaxed Axial OffsetContro"(RAOC) Methodology) 3.2.38 - Verify AFD is within limits 3.2.3.1 --------- QUADRANT POWER TILT RATIO (QPTR) 3.2.4 3.2.4 Verify QPTR is within limit by calculation ,. 3.2.4.1 3.2.4.1 Vedfy :a PTR is within limit using movable incore detectors ' 3.2.4.2 3.2.4.2 Reactor Trip System CRTS) Instrumentation (Reactor Protection System Instrumentation for HBRSEP) 3.3.1 3.3.1 Perform CHANNEL CHECK 3.3.1 .1 3.3.1 .1 Compare calorimetric to power range (i.e.~ N*uclear Instrumentation System) channel output 3.3.1.2 3.3.1.2 Compare results of incore detector measurements to NIS AFD 3.3.1.3 3.3.1.3
;,- *,
- i ;.. '
- Perform T ADOT 3.3.1.4 3.3.1.4 Perform ACTUATION LOGIC TEST ' - -* ,,
- 3.3.1 .5 3.3.1.5 Calibrate excore* channels to agree with incore detector measurements 3.3.1 .6 3.3.1.6
" ** l , ...
Perform COT 3.3.1.7 3.3.1 .7 Perform COT 3.3.1.8 3.3.1.8
~
Perform TADOT 3.3.1.9 3.3.1.9 Perform CHANNEL CALIBRATION - 3.3.1.10 3.3.1.10 Perform CHANNEL CALIBRATION (neutron detectors excluded) 3.3.1.11 3.3.1.11 Perform CHANNEL CALIBRATION (include resistance temperature detector) 3.3.1.12 3.3.1.12 Perform COT 3.3.1 .13 3.3.1.13 Perform T ADOT (verification of setpoint is not required) 3.3.1. 14 3.3.1 .14 Verify. RTS RESPONSE TIME within limits 3.3.1.16 --------- Engineered Safety Feature Actuation System (ESFAS) Instrumentation . 3.3.2 3.3.2 Perform CHANNEL CHECK 3.3.2.1 3.3.2.1 to RNP-RA/18-0015 Page4 Perform ACTUATION LOGIC TEST 3.3.2.2 3.3.2.2 Perform ACTUATION LOGIC TEST (continuit:t check ma:t be excluded) 3.3.2.3 ------- Perform MASTER RELAY TEST 3:3.2.4 3.3.2.3 Perform COT 3.3 .2.5 3.3.2.4 Perform SLAVE RELAY TEST 3.3 .2.6 3.3.2.5 Perform TADOT (verification of relay setpoints not required) 3.3.2.7 --------- Perfor111 TADOT (verification of setpoint not requ ired for manual initiation functions) 3.3.2.8 3.3.2.6 . Perform CHANNEL CALIBRATION 3.3.2.9 3.3.2.7 Verify ESFAS RESPONSE TIMES within limit 3.3.2.10 --------- Post Accident Monitoring (PAM) Instrumentation 3.3.3 3.3.3 Perform CHANNEL CHECK 3.3.3.1 3.3 .3.1 Perform CHANNEL CALIBRATION 3.3.3.2 3.3.3.2 Perform TADOT --------- 3.3.3.3 Remote Sh.utdown System 3.3.4 3.3.4 Perform CHANNEL CHECK 3.3.4.1 3.3.4.1 Verify control circuit and transfer switch is capable of performing function 3.3.4.2 3.3.4.2 Perform CHANNEL CALIBRATION 3.3.4.3 3.3.4.3 Perform TADOT (reactor trip breaker) 3.3.4.4 3.3.4.4 Loss of Power (LOP) Diesel. Generator (DG) Start Instrumentation 3.3.5 3.3.5 Perform CHANNEL CHECK 3.3.5.1 ------- Perform TADOT 3.3.5.2 3.3.5.1 Perform CHANNEL CALIBRATION 3.3.5.3 3.3.5.2 Containment Purge and Exhaust Isolation Instrumentation (Containment Ventilation Isolation Instrumentation for HBRSEP) 3.3.6 3.3.6 . Perform CHANNEL CHECK 3.3.6.1 3.3.6.1 Perform ACTUATION LOGIC TEST 3.3.6.2 3.3.6.2 Perform MASTER RELAY TEST 3.3.6.3 3.3.6.3 Perform ACTUATION LOGIC TEST (only applicable*to actuation log ic of ESFAS instrumentation) 3.3.6.4 --------- Perform MASTER *RELAY TEST *(only applicable to master relays of ESFAS instrumentation) 3.3.6.5 --------
. **.l:-**.
Perform COT 3.3.6.6 3.3.6.4 to RNP-RA/18-0015 Page 5 Perform SLAVE RELAY TEST 3.3.6.7 3.3.6.5 Perform TADOT (verification of setpoint not requ ired) *3.3.6.8 3.3.6.6 Perform CHANNE L CAU BRATION 3.3.6.9 3.3.6.7 Control Room Emergency Filtration System (CREFS) Actuation 'instrumentation 3.3.7 3.3.7 Perform CHANNE L CHECK 3 .3.7.1 3.~.7. 1 Perform COT 3.3.?.2* 3.3.7.2 Perform ACTUATION LOG IC TEST .3.-.3.7.3 3.3.7.3 Perform MASTER RELAY TEST 3'. 3.7.4 3.3.7.4 Perform ACTUATION LOGIC TEST (only ap,plicable to actuation logic-of ES FAS instrumentation) 3.3.7.5 -------- Perform MAS,TER RELAY TEST (on ly applicable to master relays of ESFAS.instrumentation) 3.3.7.6 --------- Perform SLAVE RELAY TEST * - 3.3.7.7 3.3.7.5 Perform T ADOT (verification of setpoint not requ ired) 3.3.7.8 --------- Perform CHANNEL CALIBRATION: 3.3.7.9 3.3.7.6 Fuel Building Air Cleanup System (FBACS) Actuation- Instrumentation 3.3.8 --------- Perform CHANNEL CHECK . - ,. .. *
- 3.3.8.1 -------
Perform COT 3.3.8.2 ------ Perform ACTUATION LOGIC TEST 3.3.8.3 -------- Perform TADOT (verification of setpoint not required) 3.3.8.4 ----- -- Perform CHANNEL CALIBRATION
- 3.3.8.5 ----- --
Boron Dilution Protection System (BDPS) 3.3.9 --------- _ Perform CHANNEL CHECK . i . 3.3,9.1 --------- Perform COT 3.3.9.2 -------- Perform CHANNEL CALIBRATION (neutron detectors excluded) 3.3.9.3 -------- . Auxiliary Feedwater (AFW) System Instrumentation -------- 3.3*.8 Perform CHANNEL CHECK --- - --- 3.3.8.1 Perform COT --------- 3.3.8.2 Perform T ADOT --------- 3.3.8.3 Perform CHANNEL CALIBRATION --------- 3. 3.8.4 RCS Pressure, Temperature, and flow Departure -from Nucleate Boil ing (DNB) Limits 3.4.1 3.4.1 Verify pressurizer pressure is Qreater than or equal to lim it specified in COLR 3.4.1 .1 3.4.1 .1 to RNP-RA/18-0015 Page 6 Verify RCS averaQe temperature is less than or equal to limit specified in COLR 3.4.1.2 3.4.1.2 Verify RCS total flow rate Qreater than or equal to limit specified in COLR 3.4.1.3 3.4.1 .3 Verify by precision heat balance that RCS total flow greater than or equal to limit specified in COLR 3.4.1.4 3.4.1.4 RCS Minimum Temperature for Criticality 3.4;2 3.4.2 Verify RCS average temperature in each loop ~ [541 °F] 3.4.2.1 -------- Verify RCS average temperature in each loop~ 530°F (Only required if Tave alarm is inoperabie and RCS loop Tave < 547°F) --------- 3.4.2.1 RCS Pressure and Temperature (PIT) Limits 3.4.3 3.4.3 Verify RCS pressure, temperature and heatup and cooldown rates are within appropriate limits 3.4.3.1 3.4.3.1 RCS Loops - MODES 1 and 2 3.4.4 3.4.4 Verify each RCS loop is in operation 3.4.4.1 3.4.4.1 RCS L9ops - MODE 3 3.4.5 3.4.5 Verify required RCS loops in operation .. 3.4.5.1 3.4.5.1 Verify steam Qenerator water levels 3.4.5.2 3.4.5.2 Verify Rod Control System not capable of rod withdrawal -------- 3.4.5.3 Verify reactor trio breakers are *ooen --------- 3.4.5.4 Verify lift disconnect switches *fcir control rods not fully withdrawn are open -------- 3.4.5.5 Verify SOM within limits .in COLR
-------- 3.4.5.6 Verify correct breaker aliQnment and power to pump 3.4.5.3 3.4.5.7 RCS Loops - MODE 4 3.4.6 3.4.6 Verify RHR or RCS loop in operation (RHR "train" is use_d for HBRSEP instead of "loop") _ 3.4.6.1 3.4.6.1 Verify steam Qenerator water levels 3.4.6.2 3.4.6.2 Verify correct breaker alignment and power to pump 3.4.6.3 3.4.6.3 RCS Loops - MODE 5, Loops Filled 3.4.7 3.4.7 Verify RHR loop in operation (RHR "train" is used for HBRSEP instead of "loop") 3.4.7.1 3.4.7.1 Verify steam generator secondary side water level 3.4.7.2 3.4.7.2
- Verify correct breaker aliQnment and power to* pump 3.4.7.3 3.4.7.3 RCS Loops - MODE 5, Loops Not" Filled 3.4.8 3._4.8 Verify RH.R loop in' operation (RHR "train" is used for HBRSEP instead of "loop") 3.4.8.1 3.4.8.1 Verify correct breaker alignment and power to pump 3.4 .8.2 3.4.8.2 to RNP-RA/18-0015 Page 7 Pressurizer 3.4.9 3.4.9 Verify pressurizer water level 3.4.9.1 3.4.9.1 Verify*capacity of pressurizer heaters 3.4.9.2 3.4.9.2 Verify required pressurizer heaters capable of being powered from emergency power supply 3.4.9.3 3.4.9.3 Pressurizer Power *o perated Relief Valves (PORVs) 3.4.11 3.4.11 Cycle each block valve
- 3.4.11 .1 3.4.11.1 Cycle each PORV
- 3.4.11 .2 3.4.11.2 Cvcle each solenoid air control vavle and check valve 3.4.11.3 3.4.11.3 Verify accumulators are capable of operating PORVs through a complete cycle -------- 3.4.11.4 Verify PORVs and block valves capable of being powered from emergency power sources 3.4.11.4 ---------
Low Temperature Overpressure Protection (LTOP) System 3.4.12 3.4.12 Verify maximum of one [HPI] pump capable of inlecting into RCS ("HPI" pump is "SI" pump at HBRSEP) 3.4.12.1 3.4.12.1 Verify maximum of one charqinq pump capable of injectinq into RCS 3.4.12.2 --------- Verify no SI pumps capable of injecting into RCS -------- 3.4.12.2 Verify each accumulator is isolated
- 3.4.12.3 3.4.12.3 Verify RHR suction valve is open 3.4.12.4 ------
Verify RCS vent path 3.4.12.5 3.4.12.4 Verify PORV block vaive open for each requ ired PORV 3.4.12.6 3.4.12.5 Verify RHR suction valve is locked open with power removed 3.4.12.7 --------- Perform COT (excludinq actuation) 3.4.12.8 3.4.12.6 Perform CHANNEL CALIBRATION 3.4.12.9 3.4.12.7 RCS Operational LEAKAGE 3.4.13 3.4.13 Verify RCS operational LEAKAGE within limits 3.4.13.1 3.4.13.1 Verify primary to secondary LEAKAGE within limits 3.4.13.2 3.4.13.2 RCS Pressure Isolation Valve (PIV) Leakage 3.4.14 3.4.14 Verify leakage from each RCS PIV 3.4.14.1 3.4.14.1 ~~ RHR interlock functionality (openinq) 3.4 .14.2 3.4. 14.2 Verify RHR interlock functionality (closure) 3.4 .14.3 RCS Lea.k age Detection Instrumentation 3.4.15 3.4.15 Perform CHANNEL CHECK (atmosphere radioactivity monitor) 3.4.15.1 3.4.15.1 to RNP-RA/18-0015 Page 8 Perform COT (atmosphere radioactivity monitor) 3.4.15.2 3.4.15.2 Peform CHANNEL CALIBRATION (sump monitor) 3.4.15.3 3.4.15.3 Perform CHANNEL CALIBRATION (atmosphere radioactivity monitor) 3.4.15.4 3.4.15.4 Perform CHANNEL CALIBRATION (air cooler condensate flow rate monitor) 3.4.15.5 3.4.15.5 RCS Speci(ic Activity 3.4.16 3.4.16 Verify gross specific activity 3.4.16.1 3.4.16.1 Verify DOSE EQUIVALENT 1-131 specific activity 3.4.16.2 3.4.16.2 Determine~ 3.4.16.3 3.4.16.3 RCS Loop Isolation Valves 3.4.17 ---------- Verify each loop isolation valve is open and power is removed. from each loop isolation valve operator 3.4.17.1 -------- Chemical and Volume Control System (CVCS) .. ---------- 3.4.17 Verify seal injection flow to each RCP --------- 3.4.17.1 Verify seal injection flow to each RCP from each Makeup Water Pathway from the RWST -------- 3.4.17.2 RCS Loops - Test Exceptions 3.4.19 ---------- Verify THERMAL POWER <P-7 3.4.19.1 ------- Accumulators 3.5.1 3.5.1 Ver.ify each accumulator isolation valve fully open 3.5.1.1 ------ Verify borated water volume in each accumulator 3.5.1.2 3.5.1.2 Verify nitrogen cover pressure in each accumulator 3.5.1 .3 3.5.1 .3 Verify boron concentration in each accumulator 3.5.1.4 3.5.1.4 Verify power removed from each isolation valve operator 3.p.1.5 3.5.1.5 ECCS - Operating 3.5.2 3.5.2 Verify {listed) valves in proper position with power removed 3.5.2.1 3.5.2.1 Verify valves in flow path in the correct position with power removed 3.5.2.2 3.5.2.2 Verify ECCS pipino full of water 3.5.2.3 ----*---- Verify each ECCS automatic valve actuates to correct position on actual or simulated actuation signal 3.5.2.5 3.5.2.4 Verify each ECCS pump starts automatically on actual or simulated actuation signal 3.5.2.6 3.5.2.5 Verify ECCS throttle valves (!isted) in the correct position 3.5.2.7 ----.----- Visual inspection of ECCS train 3.5.2.8 3.5.2.6 Verify valves in listed position --- - - -- 3.5.2.7 to RNP-RA/18-0015 Page 9 Verify manuaJ valve in locked listed position --- ----- 3.5.2.8 Refueling ,Water Storage .-Tan Jc .{RWST) .3.5.4- 3.5.4 Verify RWST bon;Jted wate_ r temperature 3,5,4.1 3.5.4.1 Verify RWSJ borat~d .water volume 3.5._4.2 3-.5.4.2 Verify RWST boron concentration *- 3.5.4.3 3.5.4.3 Seal-Injection Flow 3.5.5 --------- Verify manual seal. injection valves adjusted.to..proper: flow 3.5.5.1 -------- Boron Injection Tank (BIT) . 3.5.6 --------- Verjfy BIT borated water temperature 3.5.6.1 --------- Verifyi,BIT bqra_ted water volurne* _ 3.5.6.2 --- ----- Verify B!T boron concentration - 3.5.6.3 --- ----- Containment Air Locks . - . _. , ,_ , 3.6.2 3.6.2 Verify one door in the _a~r lock -can bf:ropened.at a time 3.6.2.2 3.6.2.2 Containment Isolation Valves . ' ' .* ' 3.6.3 3.6.3 Verify purge valve [42 inch] closed 3.6.3.1 3.6.3.1 Verify purQe valve r8 inchl closed 3.6.3.2 3.6.3.1 Verify containmentis.olatior, manual valves and blind flanges are closed 3.6.3.3 3.6.3.2 Verify isol;:i_tion times -- , . . ,:*._ ;_: - . . ~--
.. -~ ...
3.6.3.5 ------- Cycle each testa_ble check valve through* one full cycle ** 3:6.3.6 --------- Perform leakage rate testing for containment.purge valves with resi lient seals 3.6.3.7 -------- Verify automatic valve~ actuat~to cerrect position on *an actual or simulated siQnal 3.6.3.8 3.6.3.5 Cycle each testable check valve through one full cycle 3.6.3.9 -------- Verify each containment purge valve blocked to restrict flow 3.6.3.10 3.6.3.6 Containment Pressure . 3.6.4A 3.6.4 Verify containment pressure within limits 3.6.4A.1 3.6.4.1 Containment Air Temperature 3.6,5A 3.6.5 Verify containment average air temperature within limit 3.6.5A.1 3.6.5.1 Containment Spray and Cooling Systems , 3.6.6A 3.6.6 Verify valves in the flow path in correct position 3.6.6A.1 3.6.6.1 Operate each containment cooHnc::i train fan unit ~ 15 minutes 3.6.6A.2 3.6.6.2 to RNP-RA/18-0015 Page 10 Verify coolino water flow rate 3.6.6A.3 3.6.6.3 Verify containment spray valves actuate to their correct position on an actual or simulated signal 3.6.6A.5 3.6.6.5 Verify containment spray pumps start on an actual or simulated sional 3.6.6A.6 3.6.6.6 Verify containment cooling trains start on an actual or simulated signal 3.6.6A.7 3.6.6.7 Spray Additive S}'.stem 3.6.7 3.6.7 Verify vafves in flow path in correct position 3.6.7.1 3.6.7.1 Verify spray additive tank solution volume 3.6.7.2 3.6.7.2 Verify spray additive tank NaOH solution concentration 3.6.7.3 3.6.7.3 Verify containment spray additive tank valves actuate to their correct position on an actual or simulated sional 3.6.7.4 3.6.7.4 Verify spray additive flow from each solution's flow path 3.6.7.5 -------- Isolation Valve Seal Water (IVSW) System --------- 3.6.8 Verify IVSW tank pressure -------- 3.6.8.1 Verify IVSW tank volume ------- 3.6.8.2 Verify each automatic IVSW valve actuates to correct position on actual or simulated acuation sional --------- 3.6.8.4 Verify IVSW dedicated nitrogen bottles will pressurize the IVSW tank ~ 46.2 psig --------- 3.6.8.5 Verify total IVSW seal header flow rate::;; 124.cc/minute --------- 3.6.8.6 Main Steam Isolation Valves (MSIVs) 3.7.2 3.7.2 Verify each MSIV actuates to the isolation position on an actual or simulated actuation signal 3.7.2.2 --------- Main Feedwater _ Isolation Valves (MFIVs) and Main Feedwater Regulation Valves (MFRVs) and Associated Bypass Valves 3.7.3 3.7.3 Verify each MFIV, MFRV and associated bypass valve ac_ tuates to the isolation position on an actual or simulated signal 3.7.3.2 --------- Atmospheric Dump Valves (ADVs) 3.7.4 ---------- Verify one complete cycle of each ADV 3.7.4. 1 --------- Verify one complete cycle of each ADV block valve 3.7.4.2 ------- Auxiliary Feedwater (AFW) System 3.7.5 3.7.4 . Verify valves in the water and steam flow path in their correct position 3.7.5.1 3.7.4.1 Verify developed head of each AFW pump at the flow test point --------- 3.7.4.2 Verify each AFW automatic valve actuates to the correct position on an actual or simulated acuation sional 3.7.5.3 3.7.4.3 Verify each AFW ump starts automatically on an actual or simulated actuation signal 3.7.5.4 3.7.4.4 to RNP-RA/18-0015 Page 11 Verify AFW automatic bus transfer switch ass9ciated with discharge valve V2- 16A operates on actual or simulated SiQnai' '" L ** - * ' - - ' ' ' * - - -
--------- 3.7.4.6 Condensate Storage i"'ank (CST) 3.7.6 3.7.5 Verify CST level ** 3.7.6.1 3.7.5.1 Verify by administrative means OPERABILITY of backup Service Water System (SWS) supply to the AFW System * * --- ----- 3.7.5.2 Component Cooling Water (CCW) System 3.7.7 3.7.6 Verify each CCW valve is in the correct position 3.7.7.1 3.7.6.1 Verify each CCW valve in the flow path actuates to the correct position on an actual or simulated signal 3.7.7.2 ----- ----
Verify each CCW pump starts automatically on an actual or simulated actuation siQnal 3.7.7. 3 3.7.6.2 Service Water System (SWS) 3.7.8 3.7.7 Verify each SWS v~lve is in the correct position ._ - .. 3.7.8.1 3.7.7.1 Verify each SWS valve in the flow path actuates to the correct position on an actual or simulated actuation siQnal *
- 3.7.8.2 3.7.7.2 Verify each SWS pump starts automatically on an actual or simulated actuation signal 3.7.8.3 3.7.7,3 Verify the SWS automatic l )l.is tr.ansfer switch associated with Turbine Bldg. valve V6-16C operates on an actual or simulated signal * * - .) * * --------- 3.7.7.4 Ultimate Heat Sink (UHS) * * * * *- - --, ' 3.7.9 3.7.8 Verify water level of UHS 3.7.9.1 3.7.8.1 Verify averaqe watertemperature of UHS 3.7.9.2 3.7.8.2 Operate each cooli ng tower fan ~* 1$"minutes 3.7.9.3 ---------
Verify each cooling tower fan starts ori actual bisimulated actuation signal 3.7.9.4 --------- Control Room Emergency Filtration System (CREFS) 3.7.10 3.7.9 Operate each CREFS train ~ 15 minutes 3.7.10.1 3.7.9.1 Verify each CREFS train actuates on an actuaior simulated- actuation signal 3.7.10.3 3.7.9.3 Verify one CREFS train can maintain a positive pressure 3.7 .10.4 -------- Control Room Emergency Air Temperature Control System (CREATCS) 3.7.11 3.7.10 Verify each CREATCS train has the capability to remove th~ assumed heat load 3.7.11 .1 3.7.10.1 ECCS Pump Room Exhaust Air Cleanup System (PREACS) 3.7.12 --------- Operate each PREACS train for ~ 1O hours with heaters on or ~ 1*5 -*m inutes for systems without heaters 3.7.12.1 --------- Verify each PREACS train actuates 6n an actual or simulated signal 3.7.12.3 ------ -- to RNP-RA/18-0015 Page 12 Verify one PREACS train can maintain pressure 3.7. 12.4 -------*-- Verify each ECCS PREACS filter bypass damper closed 3.7.12.5 ------- Fuel Building Air Cleanup System (FBACS) 3.7.13 3.7.11 Operate each FBACS train for.! 10 hours with heaters on or.! 15 minutes for systems v1ithout heaters 3.7.13.1 3.7.11 .1 Verify each FBACS train actuates on an actual or simulated actuation siqnal 3.7.13.3 --------- Verify one FBACS train can maintain a pressure 3.7.13.4 3.7.11 .3 Verify each FBACS filter bypass damper can be closed 3.7.13.5 -------- Penetration Room Exhaust Air Cleanup System (PREACS) 3.7.14 --------- Operate each PREACS train for .! 10 hours with heaters on or .! 15 minutes for systems without heaters 3.7.14.1 ----- Verify each PREACS train actuates on an actual or simulated siqnal 3.7.14.3 ------- Verify one PREACS train can maintain pressure 3.7.14.4 --------- Verify each PREACS filter bypass damper can be clos.ed 3.7.14.5 --------- Fuel Storage Pool Water Level 3.7.15 3.7.12 Verify fuel storage 12001 water level '
. ,; 3.7.15.1 3.7.12.1 Fuel Storage Pool Boron Concentration 3.7.16 3.7.13 Verify the fuel storaqe pool boron concentration is within lin:tit 3.7.16.1 3.7.13.1 Secondary Specific Activity 3.7.18 3.7.15 Verify the specific activity of the secondary coolant 3.7.18.1 3.7.15.1 AC Sources - Operating 3.8.1 3.8.1 Verify correct breaker alignment 3.8.1 .1 3.8.1.1 Verify each DG starts from standby conditions 3.8.1.2 3.8.1.2 Verify each DG is synchronized and loaded 3.8.1 .3 3.8.1.3 Verify each day tank contains contains proper fuel quantity . 3.8.1.4 3.8.1.4 Check for and remove *accumulated water from each day tank 3.8.1 .5 3.8.1.5 Verify fuel oil transfer operation {from storage tank to day tank) 3.8.1.6 3.8.1.6 Verify each DG starts from standby conditions in proper t1me : ' 3.8.1 .7 3.8.1.7 Verify transfer of AC power sources (normal to alternate) 3.8.1.8 3.8.1.16 Load rejection test (largest post-accident load) 3.8.1.9 3.8.1.8 Verify DG does not trip and voltaqe is maintained durinq and following load rejection 3.8.1.10 ------
Verify DG performs properly on an actual or simulated loss of offsite power siqnal 3.8.1.11 3.8.1.9 to RNP-RA/18-0015 Page 13 Verify on an a~tual or, si.rnulated ESF actuation each DG auto starts from standby conditions 3.8.1.12 3.8.1.10 Verify each DG's nonGritical tr:1ps are-bypassed 3.8.1.13 3.8.1. 1°1 Verify each, DG operates for oreater than 24 hours 3.8.1.14 3.8.1.12 Verify_QG starts and performs properly within 5.minutes of operating for 2 hours a maximum load 3.8.1.15 3,8.1 .13 Verify DG synchronizes with offsite power while loaded with 'emergency ioads 3.8 ._1.16" --------- Verify an actual or simulated ESF sional overrides a test sional 3.8.1.17 --------- Verify interval between each sequenced load block
- 3.8.1.1'8
- 3.8.1.14 Verify on an act~al or simulated loss of offsite power in Qonjunction with actual or simulated ESF signal the DG performs properly 3.8.1.19 3.8.1.15 Verify when ~tarted simultaneously from standby conditions each DG performs properly 3.8 .1.20 3.8.1.17 Diesel Fuel Oil, Lube Oil, and Starting Air - 3.8.3 3.8.3 Verify each fuel oil storage tank volume (gallons) 3.8.3.1 3.8.3.1 Verify lubricatinq oil inventory 3.8.3.2 --------
Verify each DG air start receiver pressure 3.8.3.4 3.8.3.3 Check for and remove accumu.lated water from each fuel oil storaoe tank 3.8.3.5 3.8.3.4 DC Sources - Operating **- 3.8.4 3.8.4 Verify battery terminal vo_itaoe orea:t edhan or equal to minimum established float voltaoe 3.8.4.1 3.8.4.1 Verify each battery charger suppJi_es' ~-[400) amps at greater than or equal to minimum float voltage for ~ [8] hours - .. - 3.8.4.2 3.8.4.4 Verify battery *capa_oity ' ' . .'. 3.8.4.3 3.8.4.5
-- 3.8.4.6 Verify battery cells, cell_plates and racks show no visual indication of physical damage or abnormal deterioration : C
~ ' ,* ,
--------- 3.8.4.2 Remove visible terminal corrosion, verify, battery .ceU _to cell and terminal connections are clean and tight --------- 3.8.4.3 Battery Parameters 3.8.6 3.8.6 Verify battery float current 3.8.6.1 ---------
Verify each battery pilot cell voltage 3.8.6.2 --------- Verify each_battery connected cell electrolyte level is great~r than or equal to minimum established design limits 3.8.6.3 --------- Verify eitch battery pilot cell temperature is oreater than or equal to minimum established desion limits 3.8.6.4 --------- Verify each battery connected cell voltage 3.8.6.5 3.8.6.2 to RNP-RA/18-0015 Page 14 Verify battery capacity 3.8.6.6 ------ Verify battery cell parameters meet Table 3.8.6-1 Category A limits (limits for each designated pilot cell) --------- 3.8.6.1 Verify battery cell parameters meet Table 3.8.6-1 Category B limits (limits for each connected cell) --------- 3.8.6.2 Verify average electrolyte temperature of representative cells is~ 67°F -------- 3.8.6.3 Inverters - Operating (AC Instrument Bus Sources - Operating for HBRSEP) 3.8.7 3.8.7 Verify correct inverter voltage, frequency and alignment to required AC vital buses 3.8.7.1 3.8.7.1 Verify voltage availability and correct Constant Voltage Transformer (CVT) alignment to AC instrument buses --------- 3.8.7.2 Inverters - Shutdown (AC Instrument Bus Sources - Shutdown for HBRSEP) 3.8.8 3.8.8 Verify correct inverter voltage, frequency and alignment to required AC vital buses 3.8.8.1 3.8.8.1 Distribution Systems - Operating 3.8.9 3.8.9 Verify correct breaker alignments and voltage to AC , DC and AC vital bus electrical power distribution subsystems 3.8.9.1 3.8.9.1 Verify capability of the two molded case circuit breakers for AFW Header Discharge Valve to SIG "A", V2-16A to trip on overcurrent -------- 3.8.9.2 Verify capability of the two molded case circuit breakers for SW System Turbine Bldg . Supply Valve, V6-16C to trip on overcurrent --------- 3.8.9.3 Distribution Systems - Shutdown 3.8.10 3.8.10 Verify correct breaker alignments and voltage to AC, DC and AC vital bus electrical power distribution subsystems 3.8.10.1 3.8.10.1 Boron Concentration 3.9.1 3.9.1 Verify boron concentration within the limit specified in COLR 3.9.1.1 3.9.1.1 Unborated Water Source Isolation Valves 3.9.2 --------- Verify each. valve that isolates unborated water sources is secured in the closed position 3.9.2.1 ------- Nuclear Instrumentation 3.9.3 3.9.2 Perform CHANNl=L CHECK 3.9.3.1 3.9.2.1. . Perform CHANNEL CALIBRATION 3.9.3.2 3.9.2.2 - Containment Penetrations 3.9.4 3.9.3 : Verify each. required containment penetration is in the required status 3.9.4.1 3.9.3.1 Verify each.required containment purge and exhaust valve actu ates to the i~olation po~ition on an actual or simulated signal . . '. 3.9.4.2 3.9.3.2 Residual Heat RemQ.v.at (RHR} and Cpolant Circulation - High Water Level 3.9.5 ~.9.4 to RNP-RA/18-0015 Page 15 Verify one RHR loop is in operation and circulating reactor coolant 3.9.5.1 3.9.4.1 Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level 3.9.6 3.9.5 Verify one RHR loop is in operation and circulating reactor coolant .3.9.6.1 3.9.5.1 Verify. correct breaker .alignment and indi.cated. power avajlable to the required RHR pump that is not in operation - 3.9.6.2 3.9.5.2 Refl:1eling Cavity Water Level 3.9.7 3.9.6 ' Verify refueling cavity water level is ~ 23 ft above the top of reactor vessel flange 3.9.7.1 3.9.6.1 Containment Purge Filter System --------- 3.9.7 Verify relative humidity of containment atmosphere to be processed --------- 3.9.7.1 Verify Containment Purge Filter System is in *operation arid maintaining containment pressure negative relative to adjacent areas _ . ** * .* ' - ----- 3.9.7.2 to RNP-RA/18-0015 Page 1 ATTACHMENT 6 License Amendment Request H.B.* Robinson Steam Electric Plant, Unit t,Jo . .2 (H~R~E~} Docket No. 50-261 _ * . ; Application for Technical Specification Change Regarding Risk-Informed Justification for. the Relocation of Specific Surveillance Frequency Requiremen~s to .a Li~ens~e Controlled Program (Adoption of TSTF-425, Revision 3)
- Proposed* No Significant Hazards Consideration to RNP-RA/18-0015 Page 2 Description of Amendment Request:
This change request involves the adoption of an approved change to the standard technical specifications (STS) for Westinghouse plants (NUREG-1431) , to allow relocation of specific TS surveillance frequencies to a licensee-controlled program . The proposed change is described in Technical Specification Task Force (TSTF) Traveler TSTF-425, Revision 3 (ADAMS Accession No. ML090850642) , related to the Relocation of Surveillance Frequencies to Licensee Control - RITSTF Initiative_5b and is described in the Notice of Availability published in the Federal Register on July 6, 2009 (74 FR 31996). The proposed changes are consistent with Nuclear Regulatory Commission (NRC)-approved Industry/Technical Specifications Task Force (TSTF) Traveler TSTF-425 , Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b." The proposed change relocates surveillance frequencies to a licensee-controlled program , the Surveillance Frequency Control Program . This change is applicable to licensees using probabilistic risk guidelines contained in NRG-approved NEI 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies," (ADAMS Accession No. ML071360456). Basis for proposed no significant hazards consideration: As required by 10 CFR 50.91 (a), the Duke Energy analysis of the issue of no significant hazards consideration is presented below:
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No. The proposed change relocates the specified frequencies for periodic surveillance requirements to licensee control under a new Surveillance Frequency Control Program . Surveillance frequencies are not an initiator to any accident previously evaluated . As a result, the probability of any accident previously evaluated is not significantly increased. The systems and components required by the technical specifications for which the surveillance frequencies are relocated are still required to be operable, meet the acceptance criteria for the surveillance requirements and be capable of performing any mitigation function assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly increased . Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No. No new or different accidents result from utilizing the proposed change. The changes do not involve a physical alteration of the plant (that is, no new or different type of to RNP-RA/18-0015 Page 3 equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated .
- 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No. The design, operation , testing methods and acceptance criteria for systems, structures and components (SSCs) , specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plant licensing basis (including the final safety analysis report and bases to the TS) , since these are not affected by changes to the surveillance frequencies. Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis. To evaluate a change in the relocated surveillance frequency, Duke Energy will perform a probabilistic risk evaluation using the guidance contained in NRC approved Nuclear Energy Institute (NEI) 04-10, Revision 1, in accordance with the TS Surveillance Frequency Control Program . NEI 04-10, Revision 1 methodology provides reasonable acceptance guidelines and methods for evaluating the risk increase of proposed changes to surveillance frequencies consistent with Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk Informed Decisionmaking : Technical Specifications." Therefore, the proposed change does not involve a significant reduction in a margin of safety. Based upon the reasoning presented above, Duke Energy concludes that the requested change does not involve a significant hazards consideration as set forth in 10 CFR 50.92(c) , Issuance of Amendment.
( ~ DUKE Ernest J. Kapopoulos, Jr. H. 8 . Robinson Steam ENERGY. Electric Plant Unit 2 Site Vice President Duke Energy 3581 West Entrance Road Hartsville, SC 29550 0 : 8439511701 F: 843 951 1319 Ernit.Kapopoulos@duke-energy.com Serial: RNP-RA/18-0015 10 CFR 50.90 APR 16 .2018 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 RENEWED LICENSE NO. DPR-23
SUBJECT:
APPLICATION FOR TECHNICAL SPECIFICATIONS CHANGE REGARDING RISK-INFORMED JUSTIFICATION FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAM (ADOPTION OF TSTF-425, REVISION 3) Ladies and Gentlemen: In accordance with the provisions of Title 1O of the Code of Federal Regulations (1 O CFR Part 50.90) , "Application for Amendment of License, Construction Permit, or Early Site Permit," Duke Energy Progress, LLC (Duke Energy) is submitting a request for an amendment to the Technical Specifications (TS) for H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP). The proposed amendment would modify HBRSEP's TS by relocating specific Surveillance Frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specification Initiative 56, Risk-Informed Method for Control of Surveillance Frequencies." Additionally, the change would add a new program, the Surveillance Frequency Control Program, to TS Section 5, Administrative Controls. The changes are consistent with NRG-approved Technical Specification Task Force (TSTF) Improved Standard Technical Specifications (STS) Change Traveler TSTF-425, "Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 5b," Revision 3 (ADAMS Accession No. ML090850642). The Federal Register Notice published on July 6, 2009 (72 FR 31996) announced the availability of this TS improvement. Attachment 1 provides a description of the proposed change, the requested confirmation of applicability and plant-specific verifications. Attachment 2 provides documentation of Probabilistic Risk Assessment (PAA) technical adequacy. Attachment 3 provides the existing TS pages marked up to show the proposed change. Attachment 4 provides the proposed TS
U.S. Nuclear Regulatory Commission RNP-RA/18-0015 Page 2 Bases changes. Attachment 5 provides a TSTF-425 versus HBRSEP TS cross-reference. provides the proposed No Significant Hazards Consideration. There are no regulatory commitments contained in this letter. Duke Energy requests approval of the proposed license amendrT)ent by one year from the :date the application is accepted for NRC review. The amendment will be implemented within 120 days. In accordance with 10 CFR 50.91, "Notice for Public Comment; State Consultation," a copy of this application, with attachments, is being provided to the designated South Carolina Official. If you should have any questions regarding this submittal, please contact Mr. Kevin Ellis, Manager - Regulatory Affairs at 843-951-1329. I decl{ ~un~ ~ ~ty ~?Bry that the foregoing is true and correct. Executed on Ernest J. Kapopoulos, Jr. Site Vice President EJK/jlv Attachments:
- 1. Description and Assessment
- 2. Documentation of PAA Technical Adequacy
- 3. Proposed Technical Specification Page Changes
- 4. Proposed Technical Specification Bases Page Changes
- 5. TSTF-425 (NUREG-1431) vs. HBRSEP Cross-Reference
- 6. Proposed No Significant Hazards Consideration
U.S. Nuclear Regulatory Commission RNP-RA/18-0015 Page 3 cc (with Attachments) : C. Haney, NRC Region II - Regional Administrator J. Rotton, NRC Senior Resident Inspector- RNP D. Galvin , NRR Project Manager - RNP S. E. Jenkins, Chief; Bureau of Radiological Health (SC) A. Wilson , Attorney General (SC)
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RNP-RA/18-0015 Page 1
*I ATTACHMENT 1 License Amenc;lment Requ~st , ..
H.B. Robinson Ste~m l;:lectric Pla~t, Unit No. 2 (HBRSEP)
,
- Dock~t No*. 50-261 Application for Technical Specification.Change Regarding_Risk-lnformed Justification fo r the' Relocation of Specific Surveillance Frequency Requireme'n ts to a Licens~e . ' .
Controlled Program (Adoption of TSTF-425, Revision 3) Description and Assessment *1,
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RNP-RA/18-0015 ') Page2 DESCRIPTION AND ASSESSMENT
1.0 DESCRIPTION
The proposed amendment would modify the H.s ~*Robinson Steam Electric Plant, Unit No. 2 (HBRSEP) Technical Specifications (TS) by r.elocat!ng specific TS Surveillance Frequencies to a licensee-controlled program with the ad.option 9f Technical Specification Task Force (TSTF) - 425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - Risk Informed T~chnical Specjfication Task_Force (RITSTF) Initiative Sb" (Reference 1). Additionally, _the
- 1 a
change *would add new program , the Surve'illi;ince Frequ~ncy Control Program , to TS Section 5, Administrative Controls. . . ' . . . . . . *
- The changes are consistent with NRG-approved lndu.stry/TSTF Standard Technical Specifications (STS) change TSTP-425, Revision 3 (ADAMS. Accession No. ML090850642).
The Federal Register notice published on July 6, 2009 (74 FR 31996) (Reference 2), announced the availability of this TS improvement. 2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Duke Energy Progress, LLC (Duke Energy) has reviewed the NRC staffs Model Safety Evaluation for TSTF-425, Revision 3, dated July 6, 2009. This review included a review of the NRC staffs Model Safety Evaluation, TSTF-425, Revision 3 and the requirements specified in NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies," (ADAMS Accession No. ML071360456) (Reference 3) . The TSTF-425 Traveler and Model Safety Evaluation discuss the applicable regulatory requirements and guidance, including the existing General Design Criteria (GDC) in 10 CFR 50, Appendix A. HBRSEP was not licensed to the GDC currently in 10 CFR 50, Appendix A. The GDC in existence at the time HBRSEP was licensed for operation (July 1970) were contained in Proposed Appendix A to 10 CFR 50, General Design Criteria for Nuclear Power Plants," published in the Federal Register on July 11, 1967. The HBRSEP Updated Final Safety Analysis Report (UFSAR) provides an assessment against the 1967 GDC. Based on the assessment performed and described in the HBRSEP UFSAR, Duke Energy believes that the plant-specific requirements for HBRSEP represent an adequate technical basis for adopting the proposed change. includes Duke Energy's documentation with regard to Probabilistic Risk Assessment (PRA) technical adequacy consistent with the requirements of Regulatory Guide 1.200, Revision 1, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, " (ADAMS Accession No. ML070240001) (Reference 4) , Section 4.2, and describes any PRA models without NRG-endorsed standards, including documentation of the quality characteristics of those models in accordance with Regulatory Guide 1.200. Duke Energy has concluded that the justifications presented in the TSTF proposal and the Model Safety Evaluation prepared by the NRC staff are applicable to HBRSEP and justify this amendment to incorporate the changes to the HBRSEP TS .
RNP-RA/18-0015 Page 3 2.2 Optional Changes and Variations The proposed amendment is consistent with the*STS changes described in TSTF-425, Revisfon 3; however, Duke Energy proposes variations or deviations from TSTF-425, as identified below and includes differing Surveillance numbers. Revised (clean) TS pages are not included in this amendment request given the number of TS pages affected, the straightforward nature of the requested changes and outstanding HBRSEP amendment reque~ts that will impact some of the same TS pages. Providing only the proposed'
- TS ch~nges in Attachment 3 satisfies the requirements of 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," in that the markups fully describe the desired changes. Not including revised TS pages is an administrative deviation from the NRC staff's model application dated July 6, 2009 (74 FR 31996) with no impact on the NRC staff's *model safety evaluation published in the same Federal Register Notice. As a result of this deviation, the contents and numbering of the attachments for this amendment req uest differ from the attachments specified in the NRC staff's TSTF-425 model application .
Next, recognition of the fact that Surveillance Frequencies that have not been changed under the Surveillance Frequency Control Program (SFCP) may not be based 'on operating experience, equipment reliability or plant risk, came after NRC approval of TSTF-425. Therefore, the TSTF and the NRC agreed that the TSTF-425 Bases insert, "The Surveillance Frequency is based on operating experience, equipment reliability, and plants risk and is controlled under the Syrveillance Frequency, Control Program ," should be revised to state, "The ., Surveillance Frequency *is controlled uhder the Surveillance Frequency Cdntrol Program ." The ' existing r's Bases infor~ation' will be 'relocat~d to the' licensee-controlled SFCP. provides a cross-re'fer'ence betweeh*the TSTF-425 (NUREG.!1431) Surveillances and the HBRSEP Surveillances included in this amendment request. Attachment 5 includes a summary description of the referenced TSTF-425 TS Surveillances, which is provided for information purposes only and is not intended!td be.a .verbatim *description of the TS . Surveillances. The cross-reference in Attachment 5 is intended to highlight the following :
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- The Surv~illances included ln TST P.!425 and the correspor1ding HBRSE P Surveillances * *
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- have differing Surveillance nutnbers.' 1* * * * * - * " -
*' The Surveillances .included ,ri:*Tstp:..42s that are not contained in the HBRS EP TS.
1
- The HBRSEP plant:spedfic S'urveillances 'that are not contained in TSTF-425 '*
Surveillances and , therefore, are not included in the TSTF-425 markups. There are markups for some Surveillances contained in TSTF-425 that are not contained in the HBRSEP TS . This is an admin.istra*t \ve deviation from TSTF-425 with no impact on the NRC staff's model safety evaluation datectJu'ly 6, 2009 (14 .FR 31996) . ' For the plant-specific S1,1rveillances in HBRSEP TS that are not jncluded in the NUREG-1431 markup*s provided in TSTF-425, Duke Energy has determined that relocation of these .*: Surveillances is consistent with TSTF-425, Revision 3, and with the NRC staff's model safety evaluation dated July 6, 2009 (74 FR 31996) , including the scope exclusions identified in Section 1.0, "Introduction," of the model safety evaluation. I *
- Changes to the Frequencies for these plant-specific SurveHlances will be controlled under the SFCP. The SFCP provides the necessary administrative controls to require that Surveillances related to testing , calibration and inspection are conducted at a frequency to assure that the
RNP-RA/18-0015 Page4 necessary quality of systems and components is maintained, that facility operation will be within Safety Limit~:and that.the Limiting Conditions for Operation will be met. J ~hanges to Frequencies, in the SFCP will be evalua.ted using the methodology and probabilistic risk guidelines contained in NEI 04-10, Revision 1, "Risk-lnforme9 Technical $pecificatior;,s Initiative .. Sb, Risk-Informed Method for Control of Surveillance Frequencies," (ADAMS Accession No. ML0.7136045.6) , as approved by ~RC letter :d,ated:September 19, 2007 (AD~MS Accession No .. ML072?7,Q267). The NEI 04-10,'Reyisi9n 1 methodol<:lgy includes qualitative considerations, risk,aAalyses, sensitivit~ tstudies and;_bounding analyses; as necessary, .and recommended *
- monitoring qf the performanc~ of sy~tems1 structures c:JJ)d components (SSCs).for which ..
Frequenci~s. are changed ,to assure that reduced testing does not adversely impa_ct the SSCs. In addiJioJil;. the NEJ 04-10, Revision 1 methodol9.gy satisfies ,he five key safety princ_ipJes specified inJ~egulatory Guide 1.177, "An :Approach for Plant-Specific, Risk-1.nformed . Dec.isionr;naking; Tectmical Specifications," dated August 1998 (ADAMS Accession No. ML003740176) (Reference.!;>), relative,to changes in, ~urveillance Frequenci.e s. Therefore,, the proposed reloc:;a_tion of the HBRSEP .plant-spec,ific Surveiilance_Frequencies is *co.n~istent with TSTF-425 and with the NRC staffs model safety evaluation dated July 6, 2009 (74 FR 31996).
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3.0 REGULATORY 1ANA1:-YS1S
\ ,.1 ; ' t *, , , * "I 3.1 . No Significant-Hazards Consideration* *{
l , .. . , * . . t \ .: . * - . * * . Duke ~nergy has'revie~~~ -the p'roposed no ~ig,~ific~~t tiazards considerati~I) (NSHC) . determination pu,blisheq iry \he Feoeral Register.dated July p, 2009 (74 FR .31996). D~ke Energy has concluded t~at *th~ proposed NSH~, determination presented in the Fede,ral Register Notice is applicable to HBRSEP, and is provided as Attachment 6 to this amendment request, whi9h:-,.s 9ti,$fi1;?sJ he.requirerrents.of- 10 CFR 50.~1 (a,), "Notice for,,pu.blic comm~nt; State con$:LJltatiq,:,;'.. ~: ' , , ., ' */.,_ *<*. r ,,, * . ." ,., * .. * **
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A descripti'on of the proposed change and its relationship to applicable regulatory requirements is P.r~>\1i9-eq,_j~,TST:f:*t.4~*5,~~'.(isio~--.3, ..(,f\0AMS A~ce$~ior;t;Nq. ly1L09q_ ~~0642) and the NRC staff's model safety evaluation published in the Notice of Availability dated July Et 2009. Duke Energy h~s~c;<>ncl.l l9ed.t~~t ~~ .relatiqnshiR (?f the) propose~*.change 'to the applicable regulatory requirements-,Rr~_se,ited .in.J~e fe~eral .Regist~rn_oti~~ is ~pplicable to HBRSEP.
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3.3 Precedent The NR~ ha_;..*pre~jgJ~1/~pprov~d ch~nges*,~i.~i1~r\;* th~ 'pr3~os~d change i~ this License . Amend merit Request for other nucle~r *, ! power ' I
- plants including ', .. , .:. ' : J*
but not limited to the following
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- 1. ponald :C. Cook Nuclear Power Plant 1(CNP), .U nit:Nos. 1 and 2: Application dated .
** N*overn~er 1_9, 201~ (ADAM~ Ac~essiofNo:'. ML t$'~~~f.,450) ; NRC Saf~ty Evalu~tion dated Mar.ch,;31 ,, 201,7 (ADAMS Accession NO. ML17045A150).
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The CNP submittal requested approval ,t? relo_cate penod1c Surve1llan~~ Frequencies to . a licensee-controlled program and add a new program (the Surveillance Frequency qw1tr;9I f,rog~am) ._ to ~h~ A9i:ni.nistratiy.e .Cpntrols. s~ptfon of TS i.n accordance with N~C-appr,o\'.ed T,ST~-425. Th~ .H13,R S~P ~mendment reque~t is ~i~ilar to th~ CNP submittal in both.structure and con~ent.
- RNP-RA/18-0015 Page 5
- 2. R. E. Ginna Nuclear Power Plant (µinna): Application dated June 4, 2015 (ADAMS Accession No. ML15166A075); NRC Safety Evaluation dated June 28, 2016 (ADAMS Accession No. ML16125A485).
The Ginna submittal requested approval to relocate periodic Surveillance Frequencies to a licensee-controiled program and .add a r.ew program (the Surveillance Frequency Control Program) to the Administrative Controls section of TS in accordance with NRG-approved TSTF.-425. The HBRSEP amendment request is similar to the Ginna ~ubmittal in both structure arid, content. * * * * * * , * ,*_ * : 3.4 Conclusions
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1 In conclusion, based on the considerations* discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the 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.
4.0 ENVIRONMENTAL CONSIDERATION
Duke Energy has reviewed the environmental consideration included in the NRC staffs model safety evaluation published in the Federal Register on July 6, 2009 (74 FR 31996) . Duke Energy has concluded that the staffs findings presented therein are applicable to HBRSEP, and the determination is hereby incorporated by reference for this amendment request application.
5.0 REFERENCES
- 1. TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," March 18, 2009 (ADAMS Accession No. ML090850642).
- 2. NRC Notice of Availability of Technical Specification Improvement to Relocate Surveillance Frequencies to Licensee Control - Risk-Informed Technical Specification Task Force (RITSTF) Initiative 5b, Technical Specification Task Force - 425, Revision 3, published on July 6, 2009 (74 FR 31996) .
- 3. NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-I nformed Method for Control of Surveillance Frequencies," April 2007 (ADAMS Accession No. ML071360456).
- 4. Regulatory Guide 1.200, Revision 1, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," January 2007 (ADAMS Accession No. ML070240001).
- 5. Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:
Technical Specifications," dated August 1998 (ADAMS Accession No. ML003740176).
RNP-RA/18-0015 ** ; ** i. Page 1 ATTACHMENT 2 License Amendment Request
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H.B.' Robinson Stea~ Electric Plant, Unit No. 2 (Hl;3RSEP)
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- Docket No. 50-261 **
- Application fcjr Techni.cal Specification Change Regarding Risk-Informed justification for the Relocation of Specific Surveillance Frequency Req.uirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)
Documentation of PRA Technical .Ad~guacy
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Page 2 1.0 Overview H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP) will follow the methodology provided in NE! 04-10, Revis.ion 1 (Referenc;;e .1), to develop a risk-informed Surveillance Frequency : Control"Progran:, (SF.CP) for controi of Technical Specification surveillance frequencies. ** Guidance for implementation of a generic Technical Specifications improvement that *
- establishes licensee control of surveillance test frequencies for the majority of Technical Specifications surveillances is provided in NEI 04-:10. Existing specific surveillance'frequencies will be removed from Technical Specifications for the affected specifications and placed under licensee control pursuant to the NEI 04-10 methodology.
I' a The NEI 04-10 methodology uses risk-informed , performance-based approach for establishment of surveillance frequencies an9 is consistent with the philosophy of NRC Regulatory Guide 1.174, Revision 2 (Reference 2) . Probabilistic Risk Assessment (PRA) methods will be used to determine the risk impact of the revised surveillance intervals. PRA technical adequacy has been addressed through NRC Regulatory Guide 1.200, Revision 2 (Reference 3) , which endorses the ASME/ANS PRA standard , RA-Sa-2009 (Reference 4) . External events and shutdown risk impact will be considered ~s de?cribed herein. . This attachment demonstrates the technical adequacy of the HBRSEP PRA model to be used " - as the 'basis for the HBRSEP SFCP, consistent with the requirements of Section 3.3 and , .. Section 4 :2 of Reference 3 as follows :
- Section 2.0 of this attachment addresi es the need for the PRA model to represent the as-built, as-operated plant.
- Section 3.0 of this attachment discusses perm anent plant changes that have an impact on those thi ngs modeled in the PRA but. hav~ not been incorporated in the baseline PRA *
~
1 1 model. : * , * , : I . , i * , 1
- Section 4.0 of this attachrnepf ~eniorist;ates that the ~a,rious technical ~leme~t~-of the . ' .
HBRSEP PRA have been perfor~ed :consistently with tne AS ME/ANS PRA Standard as**-. endorsed in the appendices of R~gulatory Guide 1.200. The.peer review~ that have been condt.J.cted and the resolution of fi9ping ~ f rom those reviews are. included in Tables*
- 1 through 3. Those tables demonstra e that the pieces of the PRA have been*performed .
- in a technically correct manner. ** *
- Section 5.0 of this attachment includes a summary of the methodology that will. be used *.-
to assess the risk under the SFCP.
*
- Section 6.0 of this attachment identifies the key assumptions and approximations *
,;*h ~levant to the. results used in the decision-making process. This section provides asswance that the assumptions and approximations used in t.he development of the P~A are* appropriate.
2.0 Basis to Conclude that the PRA Model Represents the As-Built, As-Operated Plant
' -~ *t * ,. I The HBRSEP PRA Model of Record (MOR) is maintained as a controlled docume t and is updated on*a perjodic basis to represent the as-built, as-operated plant. Duke Energy
RNP-RA/18-0015 Page 3 procedures provide the guidance, requirements and processes for the maintenai1ce, update and upgrade of the PRA: a . . The process includes a review of plant ch'anges, relevant pla'nt proced~res an.d pJarit opefating data as required , through a choseri' freeze date to assess the effe.ct on the PRA model. ,
- b. The .PRA model and controlling documents are revised as necessary tb incorporate ,
those changes determined to impact the model.
- 1 '
- c. The determination of the extent of model changes includes the following : .,
- Acc~pt~~'~ in'.~~~try -~R*A pra:tices, '. gr~Lind 'rules and ass'umptioris coris1stent 'with 1
those empJoyed in the:ASME/ANS PRA Standard .(Reference 4), * \ "' .1 (, J , I w * ,l : 1
*
- Current. industry*.practices, * * .* ** * ' * * - * -
1
* ( NRG' guidarlce (e.g.,'*Refererfces '2 ~*~d-'3j'; *. ;, .. '- , - ' '
- Advances in,PRAtecti'nology and _m~f~odoiogy, and... , ;,*,
1
- Changes in externarhaz'ard'tonditions.' : * '* * . .
**. * ' ... * . -. \* 1:* * .. ' ' ~ ~~ . , ' * * ~ ',
For plarit change*s*of*sm?II 6r*neg'Hgibl~ ir'np~ci..*t~~ _rpqd.~l .~hang_es_.ca11 ~ a,qc,1:1mulated and a single revision is pe'rfo'rmed at ~n i'riterval consisfenfwith* major PRA. reyl~iQns. -\ The-results of each evaluation determine the necessity and timing of incorporation'of a partfoular change into the PRA model. An electronic.tracking .databas~ i~ 1,c1tilizepJo dqcl!meot p.Wi)dinfJ fl1o<jel changes and undates:0 : ' .. , .. , . * . . :' * ' -, , ., .: '-* C' * .*, \.,,I, . .. _*. . * *.: . . - ** .- : . ,.. f'"" ' ,, ., ** .'* .' ( ! ;_. ._ .. I
- 2.1 HBRSEP PRA Model History .. ,.
. .1' 1 . *1 ... *~ .t. ** '. : * ':" * \ * . *1 ~" *le.. : *:;*\*~ ~('1 ~ ::..,,. : ~ : .. *.tt '~ ,. ,: - . \.. . .
In ~Spense,to>the ,otigiiiar Generic t.ett'er *as-2eW fhe ~992 t ntfi~iduar'PY~'.n't' *E~~rJi~ation.(I PE) 1 was developed to address the risk from internal initiating events including internal flooding. In 1995, the scope was expanded and the Individual Plant Exa~ination 9.f Ext~rnal Events (I PEEE) *wasr?ireatedto ad~re~s,t~e. ris~ *_ of-~~!~~r~ :~J~r.!ftr:n!~rh'ci( firrs \.~i~h.W-inds and tornadosr externat floods' a111d transp9rfat1on ah_g:ne~rbY:fata~t_y"ac~1~e_r,~s. T,he HBRSEP PRA model hasrutldergo1:1e*numerbus upttafes an'd-'revie~ 'since tne 6rig_ ina'l_dev~lopment to maintairfa r;epresentati"Oi"t'-Of ,t he as..:buift, 'a s:.o,per~\~t1 :p1ahti l~ hisi:io~!;~'. to improvementS; in PRA technology *cll'ld,state:..of...the!-art mettiod6logies.; ttielfdlldwing J~t~sen.fs surnmarie,s of the HBRSEP PRA MOR updates. * ' '" * * * *
.,,T 1{, * .* ~-) ~:- '
- 1i . I *~:.J, *.*.. ., , '" * ' .
0
- \* ,. J' Internal Events*Model1History!,. ... . 1 l -, . ,.
t*- . ** I MOR 2010 addressed Findings and Observations (F&Os) from the 2010 RG 1.200 Peer Revi~w and the changes ,madeldurJng that mddel lipdale' have bee~*.-carried through the current model of record.~.The 201CH~G 1-.200 Peer Revi.e w*is the pee(re'view ofrecord*for internal events* (excludt11g ioter.oal floadin*g,*.which was asses'sed at*a*later date):***MOR '2.010 'also 'in~luded updated modeling of the Human Reliability Analysis (HRA) , updated data *and updated success criteria documentation. t
- I(I t; ", 1: ~ " . ! : .,*'° J,..1~ I',, t 1
MOR 2012 again updated modeling of the HRA, added d?\~ and updated success criteria. An additional change-as part of this'PRA; model'tJpdale *was tb 'tfie Le_ vet ?/LE.Rf' .?n?lysis, which in conjunction with the; b:evel 1 updates.r resultea in1updated 'LERF values and i'n'sights.
RNP-RA/18-00 15 Page4 MOR 2015 included the "C" motor driven Auxiliary Feedwater pump and its diesel.generator, added new shutdown seals to the model and incorporated other PRA model improvements consistent with plant 'design and operation . A new post-initiator HRA was also performed as part of MOR 2015. ' . Several open findings associated with the HBRSEP internal events PRA model were reviewed and closed in August 2017 using the process documented in Appendix X to NEI 05-04, NEI 07-12 and NEI 12-13, "Close-out of-Facts and Observations" (F&Os) as *acc-epted by NRC in the ,
- letter dated May .3, 2017 (ADAMS Accession No. ML17079A427). The results of this review have been documented and are available for NRC audit. The remaining open.finding s that have not been resolved are listed in Table 1. , ** ..
Internal Flooding Model History The initial HBRSEP internal flooding PRA model was released in June 2015 ahd was*based on*' the MOR 2015 internal events model update highlighted above. ~hortly ~fter th~ internal flooding model was released , a full 7scope internal flooding peer review on the HBRSEP model was held and the final peer review report was released in August 2015. The internal. flood ing
. I model was subsequently revised to incorporate the F&O resolutions and shortly following the
- I final peer review report, Revision 1 of the HBRSEP internal flooding PRA model *was released .
Several open findings from the HBRSEP internal flooding PRA model were reviewed and closed , in August 2017 using the process documented in Appendix X to NEI 05-04, NEI 07-12 and NEI 12-13, "Close-out of Facts and Observations" (F&Os) as accepted by NRC in the l_etter dated May 3, 20*1i (ADAMS Accession No. ML17079A427) . The results of this review have been , -* documented and are available for NRC audit. The remaining open find ings that have not' been resolved are listed in Table 2. * * : ;. ' *., "*
. : I**: ** .,:*
Fire PRA Model History ; .** *:. ; ,, ,. I .,. ,,,*,
- A full scope fire peer review of the HBRSEP Fire PRA mo-defl 'w as *performed in 201'3th~t is .
considered the peer review of record f6r 'all technical .elements except for the F ire Scenario Selection (FSS) technical element. Following the fu !'scope peer.review, ch~;1nges *and updates were made to the Fire PRA model that were ,su~~tantial enou9,h to.. warrant a_follow~up _peer * *. review. A partial scope' fire peerreview was performed (also in 201 3) and the scope *of this peer review was limited to the FSS technical element. ' * * * *
- i Several open findings from the HBRSEP Fire PRA.niodel were reviewed and dosed in 'August 2017 using the process documented in Appendix X to NEI 05-04,.NEI 07-12 and NEI 12-13, *
"Close-out of Facts and Observations" {F&Os) as accepted by NRC*in the letter d ated May 3, 2017 (ADAMS Accession No. ML17079A427). The results of this review have been documented and are available for NRC audit. The remaining open fi ndings that have not been resolved are listed in Table 3. *
- J.
3.0* Identification of Permanent Plant Changes Not Incorporated in the PRA Model
; .., ' * " ~ I .*1,* ,,J ** s The current HBRSEP Model of Record (MOR 2015) is being used for current applications. All ,.
permanent plant modifications and Engineering Changes (ECs) that have been implemented since MOR 2015 have been reviewed as part of Duke Energy PRA model maintenance procedures. There are currently no identified permanent plant modifications that have a significant impact on the PRA that have not been incorporated into the MOR.
RNP-RA/18-0015 Page 5 4.0 Conformance with ASME/ANS PRA Standard The following sections describe the conformance and capability of the HBRSEP PRA against the ASME/ANS PRA Standard. 4.1 Internal Events and Internal Flooding PRA In 2010, an industry peer review of ttie HBRSEP internal events PRA model (excluding internal flooding , which was assessed at atlater date) was performed in accord'ance with NEI 05-04. The model was evaluated. qgainst ASME PRA Standard ASME/ANS RA-S-a-2009 and Regulatory Guide 1.200, Revision 1. All findings from the 2010 peer review have ,been resolved . Several of the findings have been closed using the process d9cum~n,~-ed.in ,Appendix , X to NEI 05-04, NEI 07-12 and NEI 12-13, "Close-out of Facts and Observations" (F&Os) . The six findings from the 2010 peer . review that still h.*..ave. not. peen closed qfe. listed .... .in Table ... 1. In 20 ~5., ~n industry p~ef reVi!3~ of ,th.~ .-H BRSEP'_ int~rn~J floodin"g ~RA rri'g~e,i wa~} ~1qrrne9 in accord ante. with _t,U; I 05-04. T.h~ .mqde1*,w~s .~v~lua\e9 against .(1.SM,E PRh Standar d *. . ASME(A_r;JS RA-Sa-2009 ar;id_Regul~t?ry Guide 1.2p9J =~-~~isio_r:i ,2- ;J\11 fi~~l~~~_frprf). the 2015 peer re~1e_w.,hav~vbe~n .resol~~d . ~~v~r~I o( the find_1n9f h~ve been:cfo~eg ys)ng the:process documented .in Appendix X to NEI 05-04, NEI 07-12 and NEI 12-13, "Close-out of Facts and Ob~~rv_atjo~~,, (F~Os) . .Th~. fo~r f_jndings.from t)1e 201.? p~er_,r;ev.i~V.: ~ha,t s til\ hA_::e,not been closed ..~~e .hsted 1n Ta~le~2, *,:) ,:_ . ; ,* . .,-, 1
- r**<'--:* * ., ....-:~ .* "'* *:. *1 '. . .-.*.. . ,
Tables *1.'a~d 2 pro~i.?,e;,a c~_ ~ pi~ti _li~fRf~{the _. Q~~~~fi~~iing~ tr~~:*th~)nt~~,n~! ~~in~.s a~d- . internal flo?din__g p~~c r7¥Je.~~ ari~ cJ d1sp9sitiop f9r ;~ ch. fi~d1 _ ng to pet~rmi_ n e ,Y1f.h et~r J~e find ing has any sig*nificant impacf on the Risk Informed Technical Specification Task Fqrc! (RITSTF) Initiative Sb application . * " ** -- *
*i~
- 1
.i ** _; , '"*.~I ,
- In reviewing the HBRSEP risk informed License Amendment Request (LAR) for implementation of NFPA_~Q§ 1it~1¥ J~Rc; ,~ia.ff..e\{~l_uate.9 _ t q~ q.y 9Hty 10!~~:ia_t~rMt:ev.e nts f.?.~/.t.0-m9d_el u~eq to support d~~$rlC?eP.1e.n_t ,oJ1t~~.fir..e_gff\ T,he,_<;>~je~tiv~.~ f1t~ q~ 9J\ty re,vi~w ~;;is. "to. d_eterflJ_ine whet"h~r,tl;)_r.;R!~~t"J.~U?~cj,fic.P_R.f. \~~~d ~j~ e.'l(.~lua,il')g .!tl~ ;P.U~R9,~~ Lf.\~ .i.s.of .sufficierit scope, level of detail,.~ ~Gh,,fclj¢.~.I ~qequ}~9Y f9 f1th_~1~PPlig~ti<?P.:/L J ha,r.f!SY.lts, o_f tl:le t;.JRC _-s taff quality 1* .
- review_ar:~1dQ9y,~.~~~ 1in t~~ H~R,SEFf\NFP,f\~.0§, §af~_ty..pv~l14c1tion f.qr-tran$ition to .a risk- ..
informed, performance-based fire protection program1~D1 .M..RiAPq~ssi~n No: ri,11 1..1.633?'A264). The staff concluded that the licensee has demonstrated that the HBRSEP internal events PRA model is._tec~11ical,.ly-~deq~~te.J?,s~pport.th~ Ni::~~ 89~ (isk ,c,~lc;:4latiqn necessary.for, the
- license amend men( ,) Nhile,tll~ partic~ar, ewf!J.u.atio_n.was ;not 1~p~citic to -~h~ R ITSTF lp itiative Sb
- application ,. it fu~n.er.A~i:nonstrate~ th~.te<;:_hni_p~l .9 geq~acy-qf"the inJer.nal events PRA model. , ..
.. ~* - . .. .* f , ' * . . : . ;' ~ *, ..J * ~' ' .._ t:* ~ : C ;:;_ ,.:* .f. ,: \*.,. , - . "
Based _on th~ ,resylts, (?f tt;i~ peer r~view!p an.d r~5?lu!i.o rs1. .t l;l~ . ~BRSEP internal events and internal flooding PRA models meet the requirements of the ASME/ANS PRA Standar d as clarified by Regulatory Guide 1.200, at an appropriate capability category to support the HBRSEP_~ fCP ~,I he J:-l~RSE~ internal events.al)q ,inter11alj lo~dir,g PRA models '!Viii be 1:tsed in accordance with NEI 04-10 to assess proposed surveillance frequency changes under the SFCP::.. . *,1. ....
* ,r RNP-RA/18-0015 Page6 4.2 Fire PRA The HBRSEP fire PRA was developed using the guidance *1n NUREG/CR-$850 in suppo~ of the NFPA 805 fire protection program . The fire PRA is built upon the internal events PRA which was modified to capture the effects of fire . In 2013, a full scope industry peer review was performed on the fire PRA using NEI 07-12, Fire Probabilistic Risk Assessment (FPRA) Peer Review Guidelines. The model was evaluated against the ASME/ANS RA-Sa-2009 PRA .
Standard, as clarified by Regulatory Guide 1.200, Revi_sion 2 . Also in 2013, a partial scope,peer review was performed on the* Fire Scenario Selection (FSS) technical element. Several findi,ngs from the peer reviews have been closed . using* lhe process documented in Appendix X .. to NEIl '. ',: 05-04, NEI 07-12 and NEI 12-13, "Close-out of Facts and Observation.s" .(F&Os) . HolJl.'.ever, a total of six findings from the two 2013 peer reviews have not been dosed to~date.
- Table 3 provides a complete list of all the open findings from the fire peer reviews and a *"
disposition for each finding to determine whether the finding has any significant impact on the Risk Informed Technic?tl Specification Task F:orce (RITSTF) lnitiati')(e Sb application . The six findings*that are still ope_ rY and their.assoclate,d resolutions were* includ~d i*~ the HBRSEP NFPA 80.5 t:AR. The* results of the NRC staff quality review.' of the Fire PRA are a documented *in 'ttie HBRSEP N.FPA 805 Safety Evaluation for transitiofl to ri~k-informed , performanc*e-based *fire protection program\ The_qu~lity review concl~l°ded that th.e techni~a,I " adequacy and quality of the HBBSEP 'P'.R A i~ *suffici~nt to sup'p~rt risk-info[med changes t9 .the
' " *
- J ' " I~
- NFPA 805 fire protection program . *~
Based on the results of the aforementioned peer reviews and the [esolution the HBRSEP fire . PRA meets the requirements*ot°the.ASME/ANS PRA Stahdard as clarified .by Regiiatory Guide ' 1.200, Revision 2, at an appropriate capability category to support.th~ H6RSEf:. SFCP: Th~.fir~ .: PRA will be used in 'accordance _with_NEI 04-10 to assess proposed surveillance frecfuency .. ." , changes under'th'e SFCP. . ' . . *. . 4.3 External Events The NEI 04-10, Revision *1 methodolo-gy allows fdr surveillance frequency change ,evaluations to be performed in the absence of quantifiable PRA models tor *a11 exter_nal hazards, ' For those cases where the surveiilance frequency cannot be modeled in the plant PRA (or where a_ particular PRA model does not exist for a given hazard group), a qualitatiye or bounding analysis* is performed to provide justification for the acceptability of the proposed-test interyal change. Currently, HBRSEP does ilot have high winds, external flooding or seismic PRA models that have been evaluate~ agc!inst the ASME/ANS Standard, as clarified by Re~ulatory Guide 1.200, Revision 2. The followi ng discusses the overall external hazards analysis methodology at HBRSEP. *
- The general ;
approach used to *develop the
- external* r events PRA *at HBRSEP is a$ follo~s:
I , ~ * , , ,
- 1.
- Identify all natural and man-made credible external events that may aff~ct } he site' .using many reference sources. * * * ' *
- 2. A screening analysis was conducted using *defined bounding criteria in order to select those events that may require further review.
RNP-RN18-0015 Page 7
- 3. A scoping analysis was performed on the remaining non-screened events to determine those that warranted a detailed site and plant-specific analysis.
This approach is consistent with that previously submitted to the NRC in the Individual Pla,-,t Exarri-iri~tiori of Ext~rn'al Events (IPEEE). . 4.4 Shutdown Risk HBRSEP *operates under a sh_utdown risk manag.ement program to support implementation pf *
- NUMARC 91-06. The shutdown ris.k mi?nc!gement,implementing procec;lure provides guidelines ,
for outa'ge risk management which focuses on proper planning, conservative de.cisioi')-making, . maintaining defense-in-depth _and c6r,itr9lling key safety functions. HBRSEP will use .the shutdown risf manage.rnent prograrr proc;:edures to assess shutdown risk ,for proposed *. surveillance frequency changes. 4.5 Conclusions on External Events and Shutdown Risk I * ~ r* <. External hazards screenings have been performed for HBRSEP to support requirements of the IPEEE. NEI 04-10 allows for proposed surveillance frequency change .ev~luations to use .. hazard screening in the absence of .external hazards P.RA models. In *cases where these , methodolo~ies are not apprOp(iat_e for:~ surveilla'nce fr_equency ch~nge eVfll.Uation , 9ther qualitative o~ bo.unding analysis will be .utilized to provide justification for the .accept,abiljty of the proposed surveillanc_e frequen.cy c~ange. HB~$~P w(II ~Qllow Jhe NEI 04-1 O gu,idance to. . assess external events *and shutdown risk associated with potential..surv~illar;1ce frequency changes. * * " * ** ' *
~~ u_
1 5.0 . M~l.thodo~*OQ~JQ sed to Af~~ss_~Y"¥~,,l~nc~ Fr_ ~~~enc>'*Ch,ang~s Existfn~l R~~.~' ~ n-~_rgy P.E.O~~dures ,~eHve4 fr,9,~ \~~ Ng,i' q1)0:*~~i~a,~F:~ iili.b~ the SFCP *anti-the surveitlarfce test *interval {~hi) evaluation process. The tc;>.llo"Ying steps .will be use.cl,to govern used to assess proposed changes within the HBRSEP program. * *
- Each STI revision will be reviewed to determine whether there are any commitments mfd-~ to.me. ~.RC ~~at1,r:n,~y,p_r10,~.i.~~t.. c.~ar;i~.ir;ig t ~~ in,~yr.y..c;i.1,.. lf.~~~r~ are no rela~ed cornrq ~m~pt~\ 9-r.~e. p~rti~u!a( .qomm1fPl~~f~f:J:~Y} j~,c~~0ge~. us~r:,g a comm1tmen! .
- c~~XJ_S,~pt~~e~~ b~~~d .. ~.n...r'J~~"~~dersE!f;l,~.~}~Pce:J~tn.}~~aJ~pt1on of th~ STI rev1s1on w1l\))f0.C~~~ :,. ,If_~.~?l:Q[lltJJJem e~1~t~ ~Qf;1i-t~!3.,,C ~m.~tll]ept_~bang~ p,ro,qes~ c;jqes ~O!
permit t~~ q~~P,~r,-*, \~e~ :!~~' S~! rev_1~.1~0.,.w~11... ~~~- P~. 'ITTR~~r11.ente? *. Only, afteu~ce1v1ag , for,~al NRE:'3P8r.~y~l,tq ;e~a.n.Q~ .the ;C(?,OJITl)trn~r:il ~1lt ~r,..§J..I, revJ~1qn pr~ceed. , .
,-* i . -..;.i,!~,.-* ..., I"' ... ~ 4 .... *,,I . . **:;"., ,~** :' :** * '. 1: *(1 *\~,1: t':"Rt.. *) ."1 :**' - .-:* ' ' *
- Sy~tems en9.i9e¢r!~S,ey~I\J?~19ns_~n~ gl!qntitati_v~ ~~sess1;11en~s from available PRA models will be developed for each proposed STI revision. The HBRSEP internal e.vents;
- internal flooding and fire PRA models will be used to assess whether an SSC is affected by tt,e propq~ed~S"'[I change'. In c;;alculq~ing $.$C,fai lure .r~te_s, .if. ~e breakdown between the standby"time-dependent failure rate.and the demand-related failure rate probability for affected SSCs is uaknown, then the .totaJ tailure,prqbability will be assumed to be
. time-related to bbtain the maximum test-limited risk condition. The total and cumulative effects on Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) will be ass:ssed and ~umulative risk wi,11 b~ tr~c.k,ed :
RNP-RA/18-0015 Page 8
- If an SSC being assessed is not modeled in the PRA, th~n an appropriate*qualitative or bounding risk analysis will be performed for the SSC. Duke Energy procedures derived from NEI guidelines will be used to determine i.f the qualitative analysis is sufficient
- Hazard screening performed for the IPEEE will be used to assess external events considerations for potential STf revisions. The HBRSEP shutdown risk management program for *implementation of NUMARC 91-06 will be used to assess the shutdown risk.
- The results of each STI assessment will be documented and presented to an Expert Panel, referred to as the ~ntegrated Decision~making Panel (IDP) '. The IDP will normally be the same panel used for Maintenance Rule implementation but with the addition *of specialists with experience in surveillance testing and system or component reliability If the IDP approves the STI revision, the change will be documented and implemented, ahd will be available for audit by the NRC. If the IDP does not approve the STI revision, the surveillance frequency is left unchanged. *
- Performance monitoring will be conducted as recommended by th~ IDP. In some cases,
*~o additional monitoring may be necessary beyond that *already .cqnducted under the Maintenance Rule. Performance monitoring helps to _c9'nfirm th-flt no failure mechanisms ,
related to the revised STI become important enoug:i, to:al,t~r tt,e inform~tion provided for the justification of the interval change. Second, performance monitoring ensures, to the extent practicable, that adequate component capability (i.e., margin) exists relative to the design basis conditions so component operating characteristics, over time, do not result . in reaching a point of insufficient margin before the next scheduled test.
* ,The IDP is responsible for periodic review. of performance monitoring results. If it is determined that the time interval between successive performances of a surveillance t~st is. a factor in the unsatisfactory performances of the surveillance, the IDP will reset th~ STI to the previously acceptable test interval. . .
6.0 Key Assumptions and A"pproxirnations 1.1:-- A list of potential contributors to the uncertainty in the PRA were compiled . Tf1e list below in represents the modeling assumption'~ and uncertainties that are considered to have the greatest impact on the HBRSEP PRA results if different reasonable alternativ.e ,assumptions are utilized. 1 * * * *:-; i Key ' . Assumptions and,Sources of Ur:,certainty in the HBRSEP . l?RA I
- Uncertainty Evaluation RITSTF Initiative 5b LAR Impact 1 Reactor The HBRSEP PRA model uses the The approach utilized-for modeling Coolant Pump WOG 2000 RCP seal failure model, RGP. seal LOCA frequencies is (RCP) Seal and it assumes RCP seal leakage consistent with industry practice Failure every time both Seal Injection and based on the current-state of .
Thermal Barrier cooling are lost. knowledge: Sensitivity studies will be This is an Industry consensus conducted in accordance with NEI model. For risk applications this is 04-10 guidance to determine if other one of the most important areas of considerations might lead to impacts uncertainty. on surveillance extensions. The
RNP-RA/18-0015 Page 9 1 Key Assumptions ~nd Sources of lJncert~inty in the HBRSEP PRA *
- Uncertainty Evaluation RITSTF Initiative Sb LAR Impact assess,ment of the uncertainties, therefore, is appropriately included in
-' this risk.:informed application.
2 Loss of Off-* LOOP initiati~g events have been The approath utilized for modeling Site Power shown to be important contributors the LOOP frequencies ijnd the (LOOP) to CDF due to the potential for_ * .~- recovery proqabilities is' consistent
* ' . I ' .Frequencies station blackout and the reliance of; with *industry practice.,Sensitivity L
- 11 many frontlin'e s*ystems on 'Ac _. , studies will be conducted in .
power. The LOOP initiator was accordance with NEI b4-1 O guidance separated into plant, grid, to determine if other consider.ations switchyard ,. and weqther in<;luced, , . might lead.l o im~-~_ cts on ~µ,~ eillance LOOPs, which allowed the. mode.I to :extensions. The*as~essmeht of the apply recove~ c;tctiqns to the ,higJ;ler.1
- uncertainties', thereto~~. is ,* , .
*~ : t *, I 'trequer'l'cy events (i.e., plant anc!. . *' appropriately-induaed ir:, this.risk-
*switchyard). HB~SEP used. generic 1. informed* applicat.ion. . '. ..
industry' data'to calcu'late LOOP '" .,, -* \ . ' . ,, . .~
,, ,'. 'I I ' *, j ' I ' l ,~ \ ') ( '1 f requenc,_es.-.. . ,, ' . *J'. / ' ,* ,, ' ., ... ' ,, **r,':* . .
3 Fire Modeling The HBRS~P' Fire 'P RA (~PRA) .** !;,'. **updat~d , .NRC-approved FPRA model complies with the . ,, - . : ~~c~rologies tWm be *incorporated in _, NU~EiG/GR.:6~50 meth()dolo,~y_,tt(~t,, tp~Hi?F,S6P FPRA model as they
, .. , )nCll!ldes *unceftainti.~s fro_m _t~~ ~' .*. ,;. J:>ec9111e;a~ailable in accorda'fice with
, ,., ' iQherent*randoniri'ess :in 'eler,ri_$,r,W r.:;* : th~..Ji1,9.r.m at*P.RA* majnten~hce and
... that comprise the FPRA r'tiode(' ahd' "' Lipdate (MU) procedures. Sensitivity from the state of knowledge in ._ .. * ;i .~lHAifi~ t~1i!libe..:eonducted*ih' *'
these elements as the FPRA ~ .. accordance with NEI 04-10 guidance technol_ogy cont.inu~s. tp .T.v;..~Jye._ . *u .;~: *;-t,9:fi~Je..rmioe j ~ 0ther consicl'era~ions
.. . _..- *::; ._These *1n?lud'e the tre'.. ,~~!t'?~ (" i, :,: r. .1g,19~1t ),~ 9_<;i tw1 mpacts on ~urve1llance
..* ! . fr.~uenc1es,, h~atTele.a~e_r~teG, ~rf:;!t\t ,~e~xt~(l,~l~n~,: J.:he assess~ent of the .
, . *:,' ., ,-gr0.wth. turves,: fire* sl:lppresslon uncerta1nt1es, therefore, 1s
- failure probabilities, severity appropriately addressed by the factor~. ~.nd po~t-.initia\or hUIT!~n: .. .,: *::,§en$iti~ity;studies required by this failure* event' probabilities. While the risk-i~torrned application.
appr.o~~~~s ys~~ \i;t the HBRSEP ,, ., .-- ,,~-. :; FPRA *are NRC-approved * ,, , ... ,..... methodologies;: they are still ., ? *: *. ..
' *- constraine<;i by the relatively 'limited***: . :*, . " .
.. ' dat~ on fire .events- at Nuclear ** , ,,
~ow.er Plants. , , 1 ':
; :, * * *
- J ,-
RNP-RA/18-0015 Page 10 7.0 Conclusions on PRA Technical Adequacy ' The HBRSEP PRA is sufficiently robust and suitable for use.in risk-informed applications such as the SFCP. The peer reviews that have been conducted *and the resolution of findings from those reviews demonstrate that the pieces of the PRA have been performed in a technically correct manner. The assumptions and approximations used in development of the PRfi.; haye also been reviewed* and are appropriate for their application . Duke Energy procedures are in place for controlling and updating the models, when appropriate, .and for ensuring that the , model represents the as-built, as-operated plant. Therefore, the conclusion is that the fiBRSEP PRA model is acceptable to be used as the basis for risk-informed applications including RITSTF Initiative Sb. . 8.0 References
- 1. NEI 04-10, Risk-lnfonned Technical Specifications Initiative 5b, Risk-Informed Method i for Control of SuNeillance Frequencies ," Revision 1, April 2007. '
- 2. Regulatory Guide 1.174, An Approach for Using ProbaQilistic Risk Assessment in Risk.:,'
lnfonned Decisions on Plant-Specific Changes to the Licensing *aasis," Revision 2, u.s.** Nuclear Regulatory Commission , March 2011 . . :
- 3. Regulatory Guide 1.200, An Approach for Detennining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Ac(ivities, Revision 2, U.S. '
Nuclear Regulatory Commission, March 2009. _.; I
- 4. AS ME/ANS RA-Sa-2009, Standard for Level 1/Lar_ge.Early Reloase Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications-, Addendum A to .
RA-S-2008, ASME, New York, NY, American Nuc)ear Socie.ty,1..a Grange Park, Illinois, February 2009. " ~* .. ' , . .
*;. i ...
* :.:.: 1' '*
*i i I
./
' ' ~ '
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RNP-RA/18-001S Page 11 Table 1: Disposition and Resolution oJ Open Internal Events_Peer Review Findings
) -
Finding Supporting Capability . - - ._., *> ~ _- Qescriptioh Disposition for RITSTF lnjtiatiye Sb Number Requirement(s) Category (CC) *-- AS-AS-3 AS-AS 1/11/111 HBRSEP,2-F/PSA-0043, Section 4.8, An Induced SGTR model, bas.e<:i on AS-83 ConsequeniJal , Pressure-fnduced .,- the guidance in NU~EG~:1570, "Risk Internal SGTR not coosidered . "Conseq*uential Assessment of Severe Accident-Events tube ruptures due to high primary-tq- Induced Steam Generator Tube secondc:fry differential pressures (e:g., - Rupture," USNRC, March 1998, has due to secon9ary line breaks or A TWS been developed and js included in the events) are**not explicitly considered in .. PRA. Therefore; the impact of the model. :Secondary line breaks can *induced SGTR is c;:onsidered for the result in' a primary-to-secondary* RITSTF Initiative Sb ~pplie:ati'on. different1i3l:pressure equivalent to ~CS * .. pressure." * -
- '. ' C\
- ."', (
RNP-RA/18-0015 Page 12 Finding Supporting Capability Description Disposition for RITSTF Initiative 5b Number Requirement(s) Category (CC) DA-E2-1 DA-E2 1/11/111 The PRA documentation does not Development and discussion of the show the probabilities or basis for the occurrences represented by the basic Internal probabilities for the following basic events cited in the F&O may be found Events events (note that the basic events are in the Westinghouse Owner's Group assigned probabilities in the fault tree): document "WOG Risk-Informed ATWS
#ACRDMF (control rod fails due to Assessment and Licensing
. mechanical binding), #CRDMF (insufficient rod insertion), #RPS Implementation Process":(VVCAP-15831-P) which is cited in the (failure of reactor trip) , EAMSAC HBRSEP2 Success Criteria calculation I ' (AMSAC failure), ESFAS (ESFAS (RNP-F/PSA-0075). Two of the events fails) , CCVENT (performing CV purge), cited in this F&O are included as part of and GINRDOORSL (personnel hatch the Level 2 analysis (RNP-F/PSA-0046,
' door gasket). No evidence was found RNP-F/PSA-0047). This is a
. that these basic event values are not documentation issue only and is not a appropriate. technical issue. Therefore, it has no
.. impaclon the RITSTF. ~nitiative Sb i ' .
I * .. application . . ,, . .
~. ,
*; I *. ~
- lo _, * ,- i
- j. -*
I '
. - ~ ~:
RNP-RA/18-0015 Page 13 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) LE-E1-1 LE-E1 1/11/111 The system level data are documented The latest revision of RNP-F/PSA-0047 in the Level 1 analysis and some Level (Revision 2) uses Section 8.3 to Internal 2-specific parameters are documented discuss at length the analysis used to Events in Attachment 2 of RNP-F/PSA-0047. produce the Level 2 values that are The basis for some of the values was summarized in Table 8-36. Literature subjective (e.g. , see Table 8-10) and references, MAAP runs, human others are based primarily on the IPE reliability analysis, and the use of submittal and supporting MAAP runs engineering judgement were applied to for the Level 2 analysis (e.g., Table 8- build the Level 2 values. This finding 35). Although it is understood that the determined that the SR LE-E1 is met, approach for estimating probabilities for but is left open asking to improve the some Level 2 parameters is soft, using documentation of sources and IPE results without additional traceability, as well as add to the
- --* --- jl.fstiflcaliori may not be as realistic as summary table a column briefly stating req ~ired for a CC 11 classification . the val.uas source or method of
,,c.::: :,>,*.1, .. ; determinat.ion . However, with the
- ; :. 'L , :.* '. .., r J :., ... _ calculatiort.disCJ.1ssin9 ,how each value,.
v ..:'< f' .,;*.:;<.:: ; ,,, . *, * ,:* .. . f .. '..has been r~aljs,tic-aUy qetermined and
! s::q ~ i ,i,., , ,,...,,_-,0 *. - 1* ,": ,.-, ,, :*,,. 1 :* . ,documented in Section 8.3,-th_e , 'i.., *' - ...
. *~* ;;:- ** -_-: ;.': . ! .: -:1 u:t.," , ; .. .. :.resulting PfantE:>amageStates -are
; ,**,-:ii, ?::,:* (Y' " - , c. __ credible find accurately support the lj_'.3 .P,,J:: , -.* : , , ! , *1 .. PRAmoqel'5,results.Therefore, this l , k *C::fi ;~ _e< '.<, , *\ .. , .. , , s .. documentation concern *has no effect
- ***' " : :, ,: Ji* , . ,. ,, on the RITSTF Initiative 5b application.
- \* / --: *:: .* *r,lr , _,;~~ -:, *. *,;. * *:
* (~:-:::* 1~ * :.1.. \. :.., , { , * * ,: I. i: ;, I ; '!i i
., I.
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.' ' -~
RNP-RA/18-0015 Page 14 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) LE-DS-1 LE-05 Not Met Based on a review of a number of
- 1) In response to this finding, the calculation files, SGTR event tree, and assumed number of SG PORV/SRV Internal fault tree for #RW, it appears that a cycles on the ruptured S/G ~as .
Events realistic secondary side isolation increased from 10 to 40. This value 1s capability analysis is performed. considered reasonable and is within the However, there are a number of range of cycles described in section important issues that their resolutions 2.3.3 of NUREG-1570. As such, this may impact this conclusion . These portion of the F&O is considered issues include addressed and has no impact the RITSTF Initiative Sb application . a) A justification for the assumed number of cycles for the PO RVs on the
- 2) A sensitivity study has been faulted SG (which is 10) is not performed to assess the impact of provided . Also , it seems t~at onl~ 'fail to adding a Human Failure Event (HFE) to close' of one SRV is considered in the the model for isolating the ruptured SG.
fault tree. The HFE was developed and dependency between it and the other b) Additionally, it appears that C?perator HFEs in the model has been assessed. action to isolate the faulted SG 1s not The s-ensitivity study revealed a included as a potential contributor to reduction in the*system importances the secondary side isolation failure (Fussell-Vesely (F-V) and Risk probability. Given that in the current Achievement Worth _(RAW)) for the model modeled systems of 1% to 4% for CDF. The majority of the systems saw a less
- 1) fail to isolate probability is d~mi_nated than 0.5% reduction in importance for by the probability of a PORV sticking speti; and * *- *..,.,
- LERF. The exceptions to this being the "1. : f ~ ;.,. !
- Engineered $ afeguards Actuation
RNP-RA/18-0015 Attachment 2 Page 15 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) LE-05-1 2) the SGTR IE is one of the highest System , which saw a slight increase in (Con~in_u~d) G9n!ri_ p_uJQr§ toJhe LERF figure of merit, importanca.(4% Jor E-V and 1% for it is important to ensure that the above RAW), a,:id the*C-Qntainment {~elation app~rent-issues are fully resolved. system, which ~aw a slight incre.ase in
- . *. ~,J~ t z: "1 *: .:':I!'.:~ : t *~ -*, ....- ... ' - ~ 1\
impoftanee (3% for .both F-V and
, ) * ' ,;!'. ,,-... , .( ( 1: 1f * ;' 1C' ,* ;,_.1 1_. .* ,::,_,
R/\W) .. $in~~ -the .ed.dition of the HFE t,as ~ rn inimalimpa~
! . _* , .~
, i . " ; * * ~ .. - .,
or:, . n,e .PRA ,moqel .results, the impact
! *~ ' ); on the RITSTf= Initiative Sb application J*
. ., - ,,,. ..:~ , 1.; .-.. . ,, 1, (__* :~*.) ** . . . . . ._ ... ;i*: i$ .miAirnal 9s well , and the differences i ~ ::* ., . i :,,, ...
,j _; : ~: .... . ..... ... 1..
ar~ .cQns.ic:t.ered .to be acceptable.
- V l . r
- _\ * "i - ;*'-.;. . .. - f j
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RNP-RA/18-0015 Page 16 Finding Supporting Capability Description Disposition for RITSTF Initiative 5b Number Requirement(s) Category (CC) LE-C4-1 LE-C4 I The accident sequences are based on A sensitivity study has been performed generic references and on plant to assess the impact of adding a Internal specific MAAP analysis. Important Human Failure Event (HFE) to the Events mitigation actions in significant accident model for isolating the ruptured SG . progression sequences, such as SG The HFE was developed and isolation for SGTR are not modeled . dependency between it and the other Evidence of technical justification for HFEs in the model has been assessed . demonstrating the feasibility of The sensitivity study revealed a mitigating actions was not provided. reduction in the system importances Scrubbing is discussed for release (Fussell-Vesely (F-V) and Risk categories in RNP2-F/PSA-0048 and Achievement Worth (RAW)) for the brTef -ratforiale is provided-wtien it is . *modeled systems of 1% to 4% for CDF . credited. Inclusion of beneficial failures ..The majority of the systems saw a less was not observed . -than 0.5% reduction in importance for LERF. The exceptions to this being the Engineered Safeguards Actuati on System (ESFAS) , which saw a slight increase in importance (4% for F-V and 1% for RAW) , and the Containment
*Isolation system , which saw a slight
' increase in importance (3% for both F-V and RAW) . Since the addition of the HfE has a minimal impact on the PRA model results, the impact on the
- ' RIJSTF Initiative Sb application is
' minimal as well, and the differences are considered to be acceptable.
RNP-RA/18-0015 Attachment 2 Page 17 Finding Supporting Capabil ity Description Disposition for RITSTF Initiative 5b Number Requirement(s) Category (CC) LE-C4-1 Level 2 operator actions were (Continued) assessed in more detail using industry-standard methodologies via the EPRI HRA calculator,-ir,icluding assessment i of feasibil ity due to post-accident .. env*ronmental conditions. The SI I System Engineer and the HBRSEP2 MOV Program engineer were consulted I to determine .the *maxjmum differential pressure against which the RWST OutletM0Vs-.(SJ-864A and .B) could be manually,clc::>sed during an ISLOCA . event and it was-determined that their I closure is feas~.bl~. Based on the more d~tailed .assessment of these Level 2 HFEs, th[s portion of the F&O has been
; ;**1:_; 'L: r . *: ,.. ,,. r,. - addressed in the RRA ar:id .does not
" ,**}**'! .-.... ,, .. ... ,*
' . ' " impact.the RITSTF:..l nitiative Sb ..
I I ; ... ; : ,*;~ ;_ ':'. '; * ') .;I
! .. - ..," T"*.._ .aoolication .
"i '--, > 1 i.
'. "* 'f,f*J '1.)* *_ ... ! ',, ***:* *,.' *.. , *'-*.**
- l( ' ~~ \ * ' ,
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RNP-RA/18-0015 Page 18 Finding Supporting Capability Description Disposition for RITSTF Initiative 5b Number Requirement(s) Category (CC) QU-D4-1 QU-D4 11/!I I RNP-F/PSA-0077 Section 3.4, Similar With Capability Category II - Ill for QU-Plant Review, Table 7 shows a D4 not met, the results from the Model Internal *comparison of Robinson CDF and of Record are still valid and Events LERF values to Turkey Point and have been compared to two similar Beaver Valley. Plant systems plants with their final results being differences. are compared . However, within an order of magnitude of each the comparison is inadequate and , other. Robinson PRA alsQ contains
. sources of specific differences (e.g ., documentation that compares the LOCA contribution) are not identified.
plants in terms of system and plant capability differences. As i 'I l._; -:, * .. .. J ,I ~* recommended by the finding , Beaver
' .... ._ . ~-*
-:_ \. .*- \ . ' } .-
Valley's CDF contributions we.re .
- .. . .'~ . . ,, .,
compared to that of Robinson's. LOCA,
'I I I SGTR, and Loss of Service Water contributions to CDF are nea*rly the same between the two plants, noting that the overall CDF values are_within 1E-6 of. each other. Steam Generator
' ' Tube Rupture, Internal Flood , and Loss of Offsite Power cqntributions to LERF have similar ratios for both plants.
Other contributions, such as a reactor trip and loss of f~edwater, were more different between the two plants, but not enough to warrant any concern of
. the validity of Robinson's model.
Therefore, this documentation concern
- ,. I "' -, **
of comparing models has no effect on
. the RITSTF lnit:e!ive Sb aoo:ication .
. . -*} . i: .*
RNP-RA/18-0015 Page 19 Table 2: Disposition and Resolution of Open Internal Flood Peer Review Findings Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Require_ment(~) (?~teg~_ry_(C~) . _ _ ___ ___ ____ _ ___ .. __ ___ **-** ,* .. _ .. _ _-;- . . . . __
- ~-
IFEV-A7-1 IFEV-A7 1/11 *Human-induced flood events are
- considered as potential flood sources The,sen$itiv1ty study perf~rrned Was *;:,
Internal .but all such events are screened with ove-rly qor,seryativ.e and a.ttemp_ te"cf to - Flood potentially non-conservative screening . ap' p ly.:ai\..iridu~try );iuL man indUC~. d, failurEr _e~e~i s .Q~_~ per pipir.1g . .. . *
- r he following issues were identified: f r~uen.cy. This led to a largE!ly ov~r (a) Of the 160 generic human-induced .conservative..value. H*un;ian induced event identified as significant flqo~liiig ev~rit.s. a*r~ not ri~k "sigr,i~cant operational events involving foYfhi.s appli~~tion .as. ori the whole inadvertent or accidental release of h~'maci induc~~ flo_odir,g ev~nts i_n ,the
~ignificant quantities of process lndusJry h~ve larg~ly bt:eri occLfrrinQ .
medium outside the plant containment !ess often . This. evi.dent. by analyzir:,g structure can be defined for the the industry_q,ata 6n maintenance-industry, only 50 were included as inauce.d floc;>dJng, events which spans related to human errors in maintenance a tirneffame from 1971 to 2011. The resulting in flooding. It is not clear that Va. s t rrtajority
* ,\ * ** * ., ,, I..
of.the event$. occurred in the other 110 events were properly th~__197,0p aqd 1980s _with !?ig_nificantly"
~creened out (e.g. , is spurious fire fewer ev~nt~.occur'ring in ~he 1990s suppression operation considered and 2000,s. This tr~nd can be I * +, ?, attrµJuted.to fewer infant mortality
\11.ai~.!.e~ ~~t t I ,.__ , _ . .
~<"A*n , .-. ...
* -'* t .: * *.-' '
* : . '* .- ,. i
- i )( .... * ....... ,.,, .;.. . . 1* **- * : * ** ;* issues as .the _plants age and ..
(b~'J~~:~r;,~ntt ~ _ ~(e 11e~~LTlr-~- only__oy im~roved 'maintenance practices.
?~r~,~~i~~~ -~Y$t~-~ *-w,tr/i~~ . _ ;, .- ThW~f9re, riot i_nclOqil:lg) fi~m - . .
1d~nJ1!feaf1o_n Qf,s ize,* dU!pt1on 1 _cause, ~l?e~!ri9~II)'. _in ,t_t,e l,f P~A model would etd: 'ttfaifwould allo'w'these 'events to be not qffect results in a manner that us~o tb re"pr~~~nt-~-p~cific,flood - y.,ouicf'i mpact the . ' ~- . . '
'. sc~~aHas-*'
- l * .. .. ,- * *-* .. *.
0 RIT.STF Initiative 5. b application . t I '. 1
't-L ~,'\j .._-* *a* ~- ' i ,~1 ~** :..,. ,.'* \'- ;, *- '
-- .. * ... ~ .... ~ ,. ... "' * **..:. - ~ -< * - -
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RNP-RA/18-0015 Page 20 Finding Supporting Capability Description Disposition for RITSTF Initiative 5b Number Requirement(s) Category (CC) IFEV-A7-1 (c) The frequencies were apportioned (continued) by linear pipe length per flood area, but it is not clear that human induced flood frequency is proportional to pipe length. Sp~cific~lly, ~u_cb. flg_qds in fire -* *- Protection systems is likely to be
- inadvertent actuation of fi re* systems, which can only occur in areas-with * -
- sprinkler systems .
(d) -Human-induced flood frequencies are sereened out if they are considered I small contributors, i.e., less that the total system* flood frequency based*on random p1pe b reak frequencies. Since
.' 'this could double the freq uencies, it*is not clear that screening is appropriate.
Subsuming (adding t he frequencies *
- and modeling with bounding impacts)
, would be more appropriate. "
,I *
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RNP-RA/18-0015 Page 21 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) IFEV-A7-1 (e) For Human-induced floods with (continued) frequencies larger than the corresponding system's random pipe break frequency, all the floods were screened out qualitatively, with justification such as "at-power maintenance is not expected in this internal flood zone, and consequentially, human errors in _ . rnaLIJ~~_n§JlC:~.r~~J,J lting in flooding in this ..*
~nternal flood zone are not postulated".
H*owe\ter; these e'Vents;apparently
.occurreel -iri ;t~ generfc database. **
- U-nless-Robrn's6n*t3ah identify' ttesign or operafional,diffefences*that make"-the generiorctata n*o t,applicable, ,the.generic tlattfshourcl-t,e)use: At ,1east, for the h,ost:impGriarii!ti"Ufnal'l-inaubed *flood '
events {-h~flle'stff.reqtiencie§.-* systems wiU'i-ttle-'gfeatesfr1sk~impact), such events:sf'10Uld 1oe*:ex-plic:itty m:odeted .. lvith the corresponding flood mitigation 13ttioh!{ cfi-solateHhe flood (expected to be,more-reliable than 'for random*pipe breaR'events}! {Tt-iis F&O or4ginated * - from.SRIFEV1.AY~ * , :. *
. :..-- ,; ) t\ l ... -. ., ,..
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RNP-RA/18-0015 Page 22 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) IFSN-A12-1 IFSN-A12 1/11/111 Flood area screening is performed in It is acknowledged that the HBRSEP2 Section 5.0. The qualitative screening documented process for internal Internal process is described in Figure 11. The flooding area screening is lacking in Flood flood events are potentially modeled detail. Based on the description of the with an assumed reactor trip (manual finding and the recommended or automatic) where this may be overly resolution this is a documentation conservative. Also, it is not clear how issue that may be addressed by the screening criteria define a flood calculation revision to better detail event that would not require an and clarify the process of screening.
- - .. ... .. _ immediate plant shutdown. This may This supporting requi~ement ~a~
' be especially true for spray events assessed as being MET. Although a where the flood can be managed better presentation for the screening without tripping the plant. process of internal flooding areas at I
HBRSEP2 would more clearly satisfy the requirements of IFSN-A12 there jis , negligible impact on the quantified
- values for CDF or LERF and therefore .
, no impact on the RITSTF Initiative Sb application .* -
~ '"' ..
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RNP-RA/18-0015 Page 23 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) IFSN-A8-1 IFSN-A8 Use of EPRI door failure criteria of 1ft / Door failure height was evaluated and 3ft may not be appropriate depending found to be acceptable for the current Internal on the actual door attributes and IFPRA. The current IFPRA Flood flooding scenario. assumes that the majority of the components would fail at or around 1 ft to 3 ft, which are the current door failure heights used. As this was the failure height used varying the minimum door failure height to something greater than 1 foot or 3 feet would not impact the IFPRA in a meaningful manner. Therefore this .
- open F&O *is not expected to impact the risK results. *,. - "*' .
. The*,flood propagation-and estimated i door heig ht'failure**effects of this- open
' , F&Q.are min1mal' onmodelihg' results
,an8'lh'erefore will have no' impatt-or:i the* ~ua'ntifi~d*values with regard to
. -* .*, ' .. tlie RITSTF Initiative 5b appiication :
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RNP-RA/18-0015 Page 24 Finding Supporting Capability Description Disposition for RITSTF Initiative 5b Number Requirement(s) Category (CC) IFSN-AB-2 IFSN-A8 I Flood propagation via door gaps is Flow under door gaps was evaluated assumed to be minimal and handled by for applicable flood areas. Door gaps Internal the floor drain system. The potential for exist in a select number of flood areas Flood propagation via door gap flows should b!,Jt theseflqod area~ are not risk be addressed -in ttie flooding scenarios. significant with the exception of one flood area. This flood area is adjacent to other areas that are of limited floor area and the scenario fails equipment a low critical height. Therefore flow underneath door gaps would be limited due to the limiting ability for the flood to develop any sort of significant hydrostatic head. Crediting flow underneath door gaps would increase
, the time that operators would be able to potentially isolate the scenario.
Therefore as it is currently modeled, scenarios for this flood area are conservative but modeled in manner
; .. (. '. .~ .. consistent with CC II IFPRA modeling.
- The timing effects of this open F&O is
. . minima*1on modeling results and
. ~* . therefore will have no impact on the
..' quantified values with regard to the
. RITSTF Initiative Sb application .
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RNP-RA/18-0015 Page 25 Table 3: Disposition and Resolution of Open Fire Peer Review Findings Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) CS-C1-01 CS-C1 Not Met There is no notebook encompassing This is a documentation only issue. Task 3 (Cable Selection) making Fire review and update difficult. There are Cable selection and circuit analysis numerous change packages, and a data ~rEE d~yeloped_Jmd maintairi~d .
- dafabas-e {FSSPMD) which is *a :by the Fire Protection/NSCA team at repository for the cable routing ,Hf3RSEP2, Th*s data isthen
- information; however, there is not a , -r.eferenced:.as ~nputs to -the
- single document which compiles the *Component; Se1eotion*and -
tasks performed, procedures followed : Quantification FPRAcalculatibr:is.
- or guidelines employed. 1-his*proGess *an.d ~associated results are easity reviewable, *has'been peer reviewed multiple times for-our other siteS-and*foundio be acceptable.
There is no requitemeRt to have a separ-ate 'PRA notebook. However, adding references -to current '*- -- documentation* regarding circuit an'alysis-peffbrmance (ex. prd'cedure) would *provide.the*necessary documentation linkage between the proces's and ttie end .results (FSSPMD) : - ' There,1s no impact on the.RITSTF *
,. .. }
.. -
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RNP-RA/18-001S Page 26 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) FQ-F1-01 FQ-F1 1/11/111 The contents of the elements of This is a documentation only issue. applicable SRs of Part 2 were Fire addressed in the FQ and associated The HBRSEP2 Fire PRA was documents; however, no explicit developed using the Internal Events connections were established in the PRA as an input. Therefore, the
. *------ d_ ocuments to associate with the "back- "back-references" associated with -
.references" requirements LE-G2, LE- requ irements LE-G2, LEG4 ~nd LE~
G4 and LE-GS GS are considered to be met. j I ~_. There is no impact on .the RI.T STF i .' ~ - ' Initiative* Sb application . *
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RNP-RA/18-0015 Page 27 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) FSS-D7-01 FSS-D7 Not Met There is a failure to meet the Category Recent review of calculations and I requirement of having systems data support the following: Fire installed and maintained in accordance with applicable codes and standards.
- As shown in the NFPA 805 code The Main Turbine Lube Oil Deluge compliance evaluations, the credited system must be replaced to account for suppression and detection systems system deficiencies identified in NCR- are installed and maintained in 425437 where a simultaneous accordance with applicable codes and actuation of the Turbine Lube Oil standards.
suppression system , along with the mezzanine and ground level sprinkler
- Based on preliminary NFPA systems, could place a higher system monitoring and maintenance rule data demand on the water supply than can unavailability and unreliability of be provided by a single fire pump. This significant suppression and detection was not identified, nor is a comparison systems are green, indicating no provided in the Fire PRA of all installed operational issues of concern or detection and suppression systems vs. outlier behavior on those systems.
the corresponding Code Compliance This insight is further supported by a calculation . Review plant-specific separate study of suppression and
-*-, lnforrnation,_and ens.u re thatthe use.oL detection -systems which show 1
generic data from NUREG/CR-6850 is minfrrial failures for these systems reasonable for use in the HBRSEP2 ov~r the past few years. . '
. Fire PRA. :
- "? - ')!.;~* 1- ;-- *~~ ;_.
- Therefore, there is no impact on the RITSTF Initiative Sb application.
~
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- RNP-RA/18-0015 Page 28 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC)
FSS-D7-03 FSS-D7 Not Met Evidence needs to be provided to Recent review of calculations and support that credited data support the following : Fire detection/suppressions systems are installed and maintained in accordance
- As shown in the NFPA 805 code with applicable codes and standards. compliance evaluations, the credited System health report for period 02- suppression and detection systems 2013 for systems are installed and maintained in 6185/6181/6175/6195/6205/6180 notes accordance with applicable codes and that age, obsolescence and standards.
replacement part procurement is an issue for multiple fire protection
- Based on preliminary NFPA systems. This system health report also monitoring and maintenance rule data notes that "There are LTA Ms budgeted unavailability and unreliability of for 2014 and 2015 which study and significant suppression and detection replace the detection, CO2, and Halon systems are green, indicating no Systems." This report suggests that operational issues of concern or sp me of theJire protection syst~.rns at outlier betiavior on those systems.
HBRSEP2 may be experiencing outlier This insight is further supported by a
*behavior relative to system , separate study of suppression and unava*ilabiHty and may not be in a fully detection systems which show opera b1e 'state during plant operation minimal failures for these systems over the past few years.
- . Therefore, there is no impact on the RITSTF Initiative Sb application .
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RNP-RA/18-0015 Page 29 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) FS5-E1-01 FSS-E1 1/11/111 Section 4.3 of Calculation No. P2217- This is a documentation only issue. 2100-00, Fire Scenario Data, RNP- No issues are identified with the Fire F/PSA-0079, Revision 0, dated modeling parameters that were used. January 2013 contains information Therefore there is no impact on the about fire modeling parameters that RITSTF lnitiafive Sb application. __ _ ----*-* --~~r~ !:!_~e_d_.JjoweyerJ S~ctiqn 4.4 through 4.7 should be completed because they are missing information about other relevant fire modeling parameters. Sections 4.3 through 4.7 stilt:make reference-to databases for-the'..paramet~rs used 'in the ,fire * ,i modeling... i:hese parameters should be added to_t-Ae repmt * *,~., ' *,. I ';l *J.; J : *,* ~; ** , : *; * ,1 ,.,
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RNP-RA/18-0015 Page 30 Finding Supporting Capability Description Disposition for RITSTF Initiative Sb Number Requirement(s) Category (CC) FS5-E3-01 FSS-E3 I No statistical representation of HBRSEP2 used the HRRs and uncertainty intervals (e.g., NUREG/CR- applied them using the guidance Fire 6850 Table E-1 or G-1 for HRR, Tables found in NUREG/CR- 6850. As E-2 through E-9 for severity factor) is NUREG/CR-6850 is the consensus documented for the mean values of methodology, a detailed uncertainty parameter estimates used for fire analysis on these parameters is not modeling the significant fire scenarios. needed and does not add to the credibility of the results. The majority of applied values are based on the 98th and 75th percentile fir~s from NUREG/CR- 6850, and the ZOls are applied conservatively. It is not believed that reducing these values would allow the use of reduced impacts for the applications being pursued. Although no change has yet been made that would improve the Capability Category assessments; HBRSEP2 considers the risk res ults from the Fire PRA to be creditable for this application because documenting the statistical representation of uncertainty intervals will not change the quantified risk metrics. There is no impact on the RITSTF Initiative 5b aoolication . to RNP-RA/18-0015 ATIApHMENT3
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~li~ense Ariiendmeh_t Request, H.B, Robin~on Ste~nj' Electric Pla1(' Unit No. "2 (HBRSE,P) _.
.Docket No. 50:261
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Application for Technicaf Spe~ifjcation 'Ctiange Regarding Risk-lnfonned Justification for the Relocation .~f Spe~_ifi~ Suryeill~nce Frequ~n~y Requirements to a Lic~nsee Controlted Pr_ ogram,{Adopti-on, Q, TSTF-:425, Re'vi$,i on 3) '* . *
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Proposed Technical s*pecification- )
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Robinson Technical Specification Inserts for TSTF-425, Revision 3 Insert 1 In accordance with the Surveillance Frequency Control Program Insert 2 5.5.18 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.
- a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.
- b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.
- c. The provisions of Surveillance Requirements 3.0.2 and 3.0. 3 are applicable to the Frequencies established in the Surveillance Frequency Control Program .
Definitions 1.1 1.1 Definitions SHUTDOWN MARGIN a. All rod cluster control assemblies (RCCAs) are (continued) * ':
- fully ins'erted except for the single RCCA of highest reactivity worth , which is assumed to be fully withdrawn .
W ith any RCCA not capable of being fully inserted , the reactivitY, worth of the RCCA must be accounted for in the determination of SOM ; and - *
- b. , In MODES 1 and 2, tt,ie fuel arid moderator
_., te~peratur7? are changed .to the 547°F . . SLAVE RELAY TEST A SLAVE RELAY TEST shall con.sist of e*nergizlng each sla.v~ r.elay and verifyin~ the OPER_A BILITY of each slave relay. The SLAVE RELAY TEST shall include, as a t.' minimum , a continuity ch'eick' of' associated .testable actuation devices. * ; :: ,-. -
- STAGGERED ,lEST BASIS *..:* ,A S:PAGGERfiDTEST 8.A.SIS 1shall'c0nsist of the testing of
* , 11: . *, , ; , . . .one. of:the sys.tems, s.uesystems, chann~ls, or other
*, .. c;lesjgnated. po_ mpononts.~d.ur.ing t_hQ int.orval specified by the Surveillance rrequency, so that all systems, subsystems,
*
- _, ,. . , ... ;
- 1, , .J ~- .~cl~fil~,l.s ~o_r,othE\)f, ~es_ ig2atf?p_.c.9 ~p9r9nts are .tested during
, .* . .*, .. , .. . .. -_ . .() _Surv,eil[,Hipe Frqql,lqncy jot9rv~ls, where fl is the total
' -1 , .,.,, .: .. t. .: .. - tiu'fr1b6r..of syst~ms,' s*uiJ'syslei°fnE( 16 ti1nnels, or other designated components in the assodrateid' function .
THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant. TRIP ACTUATING DEVICE A T ADOT shall consist of operating the trip OPERATIONAL TEST actuating device and verifying the OPERABILITY of (TADOT) required alarm , interlock, display, and trip functions . The T ADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the required accuracy. HBRSEP Unit No. 2 1.1-5 Amendment No. ~
SOM 3.1.1 3.1 REACTIVITY CONTROL SYSTEMS 3.1 .1 SHUTDOWN MARGIN (SOM) LCO 3.1.1 SOM shall be within the limits provided in the COLR. APPLICABILITY: MODE 2 with kett < 1.0, MODES 3, 4 , and 5. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. SOM not within limit. A.1 Initiate boration to 15 minutes restore SOM to within limit. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify SOM is within the limits provided in the COLR INSERT 1 HBRSEP Unit No. 2 3.1-1 Amendment No. 47e
Core Reactivity 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 -----------------------------N OT E----------------------------- T he predicted reactivity values may be adjusted (normalized) to correspond to the measured core reactivity prior to exceeding a fuel burnup of 60 effective full power days (EFPD) after each fuel loading . Verify measured core reactivity is within +/- 1% .llk/k of Once prior to predicted values. entering MODE 1 after each refueling
--------NOTE--------
0 n ly required after 60 EFPD i" INSERT 1 HBRSEP Unit No. 2 3.1-3 Amendment No. 47e
Rod Group Alignment Limits 3.1.4 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time of Condition B not met. D. More than one rod not D.1.1 Verify SOM is within 1 hour within alignment limit. the limits provided in the COLR. OR D.1.2 Initiate boration to 1 hour restore required SOM to within limit. AND D.2 Be in MODE 3. 6 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify individual rod positions within 12 hours alignment limit. ~.-IN_S_E_R_T_1_, AND Once withi hours and every 4 hours thereafter when the rod position deviation monitor is inoperable (continued) HBRSEP Unit No. 2 3.1-8 Amendment No. 47e
Rod Group Alignment Lim its 3.1.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.2 Verify rod freedom of movement (trippability) Q2 days by moving each rod not fully inserted in the
~
core 2: 10 steps in either direction.
!INSERT 1 I SR 3.1.4.3 Verify rod drop time of each rod , from the Prior to reactor criticality after fully withdrawn position , is ~ 1.8 seconds each removal of the reactor from the beginning of decay of stationary head gripper coil voltage to dashpot entry, with :
- a. T avg 2: 540°F ; and
- b. All reactor coolant pumps operating .
HBRSEP Unit No. 2 3.1-9 Amendment No. 4-+e
Shutdown Bank Insertion Limits 3.1.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify each shutdown bank is within the limits specified in the COLR. INSERT 1 HBRSEP Unit No. 2 3.1-11 Amendment No. 4+e
Control Bank Insertion Limits 3.1.6 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE . .. . FEQUENCY SR 3.1 .6.2 Verify each control bank insertion is within the limits specified in the COLR. Once wit and --4...JC.l~~ thereafter when the rod insertion limit monitor is inoperable SR 3.1.6.3 Verify sequence and overlap limits specified in the 12 hours COLR are met for control banks not fully withdrawn from the core. pri;'ERT 1 I HBRSEP Unit No. 2 3.1-14 Amendment No. 4+e
PHYSICS TESTS Exceptions - MODE 2
- 3. 1.8 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME C. RCS lowest loop average C. 1 Restore RCS lowest 15 minutes temperature not within loop average limit. temperature to within limit.
D. Required Action and D.1 Be in MODE 3. 15 minutes associated Completion Time of Condition C not met. SURVEILLANCE REQUIREMENTS
,SURVEILLANCE FREQUENCY SR 3.1.8.1 Perform a CHANNEL OPERATIONAL TEST on Within 7 days prior power range and intermediate range channels per to initiation of SR 3.3.1.7, SR 3.3.1.8, and Table 3.3.1-1. PHYSICS TESTS SR 3.1.8.2 Verify the RCS lowest loop average temperature is 2!53.0°F.
SR 3.1.8.3 Verify THERMAL POWER is~ 5% RTP . SR 3.1.8.4 Verify SOM is within the limits provided in the COLR. 24 hours HBRSEP Unit No. 2 3.1-21 Amendment No. 47e
F0 (Z) 3.2 .1 SURVEILLANCE REQUIREMENTS
.---------------------------------------------N OT E-----------------------------------------------------------
0 u ring power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved , at which a power distribution map is obtained . SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify F~(Z) is within limit. Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 12 hours after achieving equilibrium conditions after exceeding , by
~ 10% RTP, the THERMAL POWER at which F~(Z) was last verified
!INSERT 1 HBRSEP Unit No. 2 3.2-3 Amendment No. 476
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 -----------------------------N OT E-------------------------------- 1f F~ H is within limits and measurements indicate that F~H is increasing with exposure then :
- a. Increase F6 (Z) by a factor of 1.02 and reverify F6 (Z) is within limits; or
- b. Perform SR 3.2 .1.1 and SR 3.2 .3.3 once per 7 EFPD until two successive measurements indicate F~H is not increasing.
Verify F~H is within limits specified in the COLR. Once after each refueling prior to THERMAL POWER exceeding 75% RTP 31 EF"PD +-(--IINSERT 1 thereafter HBRSEP Unit No. 2 3.2-6 Amendment No. 4+e
AFD 3.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify AFD is within limits for each OPERABLE ?days ~ excore channel. SR 3.2 .3.2 --------------------------NOTE------------------------------- Ass um e logged values of AFD exist during the preceding time interval.
-----NOTE------
Verify AFD is within limits and log AFD for each Only required to be OPERABLE excore channel. performed if AFD monitor alarm is inoperable Once within 15 minutes and every 15 minutes thereafter when THERMAL POWER
~ 90% RTP or 0.9 APL, whichever is less AND Once within 1 hour and every 1 hour thereafter when THERMAL POWER
< 90% RTP or 0.9 APL, whichever is less (continued)
HBRSEP Unit No. 2 3.2-10 Amendment No. 4+e
AFD 3.2.3 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.2.3.3 --------------------------------NOTE------------------------------
- 1. The initial target flux difference after each refueling may be determined from design predictions.
- 2. The target flux difference shall be determined in conjunction with the measurement of F 0 (Z) in accordance with SR 3.2.1.1.
Determine, by measurement, the target flux Once within difference of each OPERABLE excore channel. 31 EFPD after each refueling 31 ErPD thereafter INSERT 1 HBRSEP Unit No. 2 3.2-11 Amendment No. 47e
QPTR 3.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.4.1 ---------------------------N()TES--------------------------------
- 1. With input from one Power Range Neutron Flux channel inoperable and THERMAL P()WER < 75% RTP, the remaining three power range channels can be used for calculating QPTR.
- 2. SR 3.2.4.2 may be performed in lieu of this Surveillance.
Verify QPTR is within limit by calculation . 7 days INSERT 1 hours an 'eveflf 12 hours thereafter with the QPTR alarm inoperable. SR 3.2.4.2 ----------------------------N ()TE-------------------------------- Not required to be performed until 12 hours after input from one or more Power Range Neutron Flux channels are inoperable with THERMAL P()WER
;:;: 75% RTP .
Verify QPTR is within limit using the movable incore ()nee within detectors. 12 hours fil:!Q 12 hours~pNSERT 1 thereafter
- HBRSEP Unit No. 2 3.2-14 Amendment No. 47e
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS
N OT E-----------------------------------------------------------
Refer to Table 3.3.1-1 to determine which SRs apply for each RPS Function . SURVEILLANCE FREQUENCY SR 3.3.1.1 Perform CHANNEL CHECK. SR 3.3.1 .2 -----------------------------NOTES------------------------------
- 1. Adjust NIS channel if absolute difference is
> 2% .
- 2. Not required te be performed until 12 hours after THERMAL POWER is~ 15% RTP.
Compare results of calorimetric heat balance 24 hours calculation to Nuclear Instrumentation System (NIS) channel output. im:sERT 1 SR 3.3.1.3 -------------------NOTES-------------------
- 1. Adjust NIS channel if absolute difference is
~3%.
- 2. ' Not required to be performed until 36 hours after THERMAL POWER is~ 15% RTP.
Compare results of the incore detector 31 effective full measurements to NIS AFD . po1.+.<er days (EFPD) < !INSERT 1 (continued) HBRSEP Unit No. 2 3.3-8 Amendment No. 47e
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.1.4 ---------------------------NOTE---------------------------------- T his Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service. Perform TADOT. 31 days on a STAGGERED~ TEST BASIS SR 3.3.1.5 ----------------------------NOTE--------------------------------- Not required to be performed for the logic inputs from Source Range Neutron Flux detector prior to entering MODE 3 from MODE 2 until 4 hours after entry into MODE 3. Perform ACTUATION LOGIC TEST. 31 days on a Sl;AGGEREDtjlNSERT 1 TEST BASIS SR 3.3.1.6 --- .------------------------NOTE--------------------------------- N ot required to be performed until 24 hours after THERMAL POWER is~ 50% RTP. Calibrate, excore channels to agree with incore Q2 EFPD < ~INSERT 1 detector measurements. SR 3.3.1.7 -----------------------------NOTE-------------------------------- N ot required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 4 hours after entry into MODE 3. Perform COT. 92 days ~<--;JINSERT 1 (continued) HBRSEP Unit No. 2 3.3-9 Amendment No. 416
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.1.8 -----------------------------NOTE-------------------------------- T his Surveillance shall include verification that interlocks P-6 and P-10 are in their requ ired state for existing unit conditions. Perform COT. -----NOTE----- Only required when not the Frequency specified in the performed within Surveillance Frequency Control -----,.r_::: ~ pre11ious Q2 days Program Prior to reactor startup Four hours after reducing power below P-1 O for power and intermediate instrumentation Four hours after reducing power below P-6 for source range instrumentation Every Q2 days r thereafter ~,£..._-,4INSERT 1 (continued) HBRSEP Unit No. 2 3.3-10 Amendment No. 4+e
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.1.9 ------------------------------NOTE------------------------------- Ve rification of setpoint is not required . Perform TADOT. Q2days ~ SR 3.3.1.10 -----...-------------------------NOTE------------------------------ T his Surveillance shall include verification that the time constants are adjusted to the prescribed values where applicable. Perform CHANNEL CALIBRATION . 18 months tjNSERT 1 SR 3.3.1.11 -------------------------------NOTE------------------------------ Neutron detectors are excluded from CHANNEL CALIBRATION. Perform CHANNEL CALIBRATION . 18months ~ SR 3.3.1.12 -------------------------------NOTE------------------------------
. This Surveillance shall include verification that the electronic dynamic compensation time constants are set at the required values, and verification of RTD response time constants.
Perform CHANNEL CALIBRATION . 18months ~ SR 3.3.1.13 Perform COT. 18months ~ (continued) HBRSEP Unit No. 2 3.3-11 Amendment No. 4-7e
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.1 .14 ------------------------------NOTE------------------------------ Ve ri fi cation of setpoint is not required . Perform TADOT. 18months ~ SR 3.3.1.15 ------------------------------NOTE------------------------------ -------NOTE-------- Verification of setpoint is not required . Only required when not performed within previous 31 days Perform TADOT. Prior to reactor startup HBRSEP Unit No. 2 3.3-12 Amendment No. 4+e
ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS
NOTES-------------------------------------------------------------
- 1. Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function .
- 2. When a channel or train is placed in an inoperable status solely for the performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours provided the redundant train is OPERABLE.
SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK. 12 hours ~ -{INS ERT 1 SR 3.3.2.2 Perform ACTUATION LOGIC TEST . 31 days on a S+,A,GGeReQ t j NSERT 1
+ eS+ BASIS SR 3.3.2.3 Perform MASTER RELAY TEST. 18 months ( 11 NSERT 1 SR 3.3.2.4 Perform COT. Q2 days < IINS ERT 1 I SR 3.3.2.5 Perform SLAVE RELAY TEST . 18 months < 11 NSERT 1 SR 3.3.2.6 ---------------------------NOTE-----------------------------
Verification of setpoint not required for manual initiation functions. Perform TADOT. 18 months < 11 NSERT 1 SR 3.3.2.7 Perform CHANNEL CALIBRATION . 18 months IN HBRSEP Unit No. 2 3.3-24 Amendment No. 47e
PAM Instrumentation 3.3.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME G. As required by Required G.1 Initiate action in Immediately Action E.1 and referenced accordance with in Table 3.3.3-1. Specification 5.6.6 . SURVEILLANCE REQUIREMENTS
NOTE-----------------------------------------------------------
SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3 .3-1 ; except Functions 9, 22 , 23 , and 24. SR 3.3.3.3 applies only to Functions 9, 22, 23 , and 24 . SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required instrumentation channel that is normally energized . SR 3.3.3.2 ----------------------------N OT E------------------------------- 18months~ Ne utro n detectors are excluded from CHANNEL CALIBRATION . Perform CHANNEL CALIBRATION . SR 3.3.3.3 ----------------------------NOTE------------------------------ Ve rifi cation of setpoint not required . 18 months ~NSERT 1 Perform T ADOT. HBRSEP Unit No. 2 3.3-31 Amendment No. ~
Remote Shutdown System 3.3.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.4.1 Perform CHANNEL CHECK for each required 31 days ~<:___.i:;.PN"'S~E-R_T_1__, instrumentation channel that is normally energized. SR 3.3.4.2 Verify each required control circuit and transfer 18 months~ switch is capable of performing the intended function. SR 3.3.4.3 ----------------------------N()TE--------------------------------- Neutron detectors are excluded from CHANNEL CALIBRATl()N . Perform CHANNEL CALIBRATl()N for each required 18 months +-<-...,..jlNSERT 1 instrumentation channel. SR 3.3.4.4 Perform TAD()T of the reactor trip 18 months < jiNSERT 1 breaker open/closed indication. HBRSEP Unit No. 2 3.3-34 Amendment No. 47e
LOP DG Start Instrumentation 3.3.5 ACTIONS CONTINUED (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and 0 .1 Enter applicable Immediately associated Completion Condition(s) and Time not met. Required Action(s) for the associated DG made inoperable by LOP DG start instrumentation. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 -----------------------------NOTE----------------------------- Ve rifi cation of setpoint not required . Perform TADOT . 18months ~ SR 3.3.5.2 Perform CHANNEL CALIBRATION with Trip 18months~ Setpoints as follows:
- a. Loss of voltage Trip Setpoint of 328 V +/- 10%
with a time delay of ::S:1 second (at zero voltage) .
- b. Degraded voltage Trip Setpoint of 430 V +/- 4 V with a time delay of 10 +/- 0.5 seconds.
HBRSEP Unit No. 2 3.3-36 Amendment No. 47e
Containment Ventilation Isolation Instrumentation 3.3.6 SURVEILLANCE REQUIREMENTS
N()TE--------------------------------------------------------------
Refer to Table 3.3.6-1 to determine which SRs apply for each Containment Ventilation Isolation Function. SURVEILLANCE FREQUENCY SR 3.3.6.1 Perform CHANNEL CHECK. 1~ RSl:IFS NSE SR 3.3.6.2 Perform ACTUATl()N L()GIC TEST. 31 days en a STAGGEREDt j l NSERT 1 TEST BASIS SR 3.3.6.3 Perform MASTER RELAY TEST. 18 mentl=ls IN SR 3.3.6.4 Perform C()T. Q~ days INSE SR 3.3.6.5 Perform SLAVE RELAY TEST. 18 mentl=ls INS SR 3.3.6.6 ----------------------------N ()TE------------------- ,------------ Verification of setpoint is not required . Perform TAD()T. 18 mentl=ls IN SR 3.3.6.7 Perform CHANNEL CALIBRATl()N . 18 mentl=ls INS HBRSEP Unit No. 2 3.3-38 Amendment No. 4+e
CREFS Actuation Instrumentation 3.3.7 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time for Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours D. Required Action and D.1 Suspend movement of Immediately associated Completion irradiated fuel Time for Condition A or B assemblies. not met during movement of irradiated fuel assemblies. SURVEILLANCE REQUIREMENTS
NOTE--------------------------------------------------------
Refer to Table 3.3.7-1 to determine which SRs apply for each CREFS Actuation Function . SURVEILLANCE FREQUENCY SR 3.3.7.1 Perform CHANNEL CHECK. 12 hours ~(---+!INSERT 1 SR 3.3.7.2 Perform COT. SR 3.3 .7.3 Perform ACTUATION LOGIC TEST. 31 days on a STAGGERED ~ TEST BASIS (continued) HBRSEP Unit No. 2 3.3-41 Amendment No. 17e 195
CREFS Actuation Instrumentation 3.3.7 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.7.4 Perform MASTER RELAY CHECK. 18 months ~ SR 3.3.7.5 Perform SLAVE RELAY TEST . 18 months tjlNSERT 1 I . SR 3.3.7.6 Perform CHANNEL CALIBRATION . 18 months ~INSERT 1 HBRSEP Unit No. 2 3.3-42 . Amendment No. 47e
*Auxiliary Feedwater (AFW) System Instrumentation 3.3.8 SURVEILLANCE REQUIREMENTS
. ------------------- .-----*-----N.OTE-- . ---------- , --- .---- .-- .-----------------------------. -
Refer to Table 3.3.8-1 to determine which SRs apply fQr each AFW Function. SURVEILLANCE FREQUENCY SR 3.3.8.1 Perform .CHANNEL CHECK. 12hours ~ SR 3.3.8.2 Perform COT. Q2 days ~!INSERT 1 SR 3.3.8.3 ----------------------------NOTE- * * ----* ------- * '---- *--------- For Function 5, the TADOT shall include injection of a simulated or actual signal to verify channel OPERABILITY,. 7
---------------------- * ' ' - - . - - - - - - -* - -- - - - - - - i _.,. __ *- - - - - * - - * .. - - - -
Perform TADOT.
=-
SR 3.3.8.4 Perform CHANNEL CALIBRATION . 18months ~ HBRSEP Unit No. 2 3.3-46 Amendment No. 476
RCS Pressure, Temperature, and Flow DNB Limits 3.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1 .1 Verify pressurizer pressure is greater than or equal to INSERT 1 the limit specified in the COLR. SR 3.4.1.2 Verify RCS average temperature is less than or equal 42:oours INSERT 1 to the limit specified in the COLR. 6 SR 3.4.1.3 Verify RCS total flow rate is~ 97.3 x 10 lbm/hr and 42:oours INSERT 1 greater than or equal to the limit specified in the COLR. SR 3.4.1.4 ---------~----~-~------NOTE~----------~------------------- Not required to be performed until 24 hours after
~ 90% RTP.
Verify by precision heat balance that RCS total flow 48menths INSERT 1 6 rate is~ 97.3 x 10 lbm/hr and greater than or equal to the limit specified in the COLR. HBRSEP Unit No. 2 3.4-2 Amendment No. ~
RCS Minimum Temperature for Criticality 3.4 .2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.2.1 Verify RCS T avg in each loop~ 530°F . --------NOTE-------- 0 n ly required if low T avg alarm not reset and any RCS loop T avg
< 543°F .
d0 R:iinutes .,., ~ thereafter ~ HBRSEP Unit No. 2 3.4-4 Amendment No. 47e
RCS PIT Limits 3.4.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. -------------NOTE-------------- C.1 Initiate action to restore Immediately Required Action C.2 shall parameter(s) to within be completed whenever limits. this Condition is entered.
----------------------------------- AND Requirements of LCO not C.2 Determine RCS is Prior to entering met any time in other than acceptable for MODE4 MODE 1, 2, 3, or 4. continued operation.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 --------------------------------NOTE------------------------------ 0 nly required to be performed during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing . Verify RCS pressure, RCS temperature, and RCS JO minutes ~ heatup and cooldown rates are within the limits specified in Figures 3.4.3-1 and 3.4.3-2. HBRSEP Unit No. 2 3.4-6 Amendment No. 47e
RCS Loops - MODES 1 and 2 3.4.4 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.4 RCS Loops - MODES 1 and 2 LCO 3.4.4 Three RCS loops shall be OPERABLE and in operation . APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of LCO not A.1 Be in MODE 3. 6 hours met. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.4.1 Verify each RCS loop is in operation . 12hours ~ HBRSEP Unit No. 2 3.4-9 Amendment No. 4-+e
RCS Loops - MODE 3 3.4.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify required RCS loops are in operation . 12 hours ~l!NSERT 1 SR 3.4.5.2 Verify steam generator secondary side water levels 12hours ~ are ~ 16% for required RCS loops. SR 3.4.5.3 -----------------------------NOTE-------------------------------- 0 n ly required to be met if LCO 3.4.5.a is required to be met. Verify the Rod Control System is not capable of rod 12hours ~ withdrawal. SR 3.4.5.4 ------* ----------- *---------NOTE--------------------------------- 0 n ly required to be met if LCO 3.4.5.b is required to be met. Verify the reactor trip breakers are open . SR 3.4 .5.5 ----------------------------NOTE---------------------------------- 0 nIy required to be met if LCO 3.4 .5.c is required to be met. Verify the lift disconnect switches for all control rods 12hours~ not fully withdrawn are open . (continued) HBRSEP Unit No. 2 3.4-12 Amendment No. 479
RCS Loops - MODE 3 3.4.5 SURVELLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4.5.6 ------------------------------NOTE------------------------------- Only required to be met if LCO 3.4.5.d is required to be met. Verify SOM is within required limits specified in the COLR. SR 3.4.5.7 Verify correct breaker alignment and indicated power 7 days ~ are available to the required pump that is not in operation . HBRSEP Unit No. 2 3.4-13 Amendment No. 47e
RCS Loops - MODE 4 3.4.6 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. One required loop or B.1 Be in MODE 5. 24 hours train inoperable. AND One required RHR train OPERABLE. C. Two required loops or C. 1 Suspend operations that Immediately trains inoperable. would cause introduction into the OR RCS , coolant with boron concentration less than Required loop or train not requ ired to meet SOM in operation. of LCO 3.1.1. AND Immediately C.2 Initiate action to restore one loop or train to OPERABLE status and operation . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one RHR train or RCS loop is in operation . 12 hours ~ SR 3.4.6.2 Verify SG secondary side water levels are~ 16% for 12 hours ~ required RCS loops. SR 3.4.6.3 Verify correct breaker alignment and indicated power 7 days ~ are available to the requ ired pump that is not in operation . HBRSEP Unit No. 2 3.4-15 Amendment No. 17e 1QO
RCS Loops - MODE 5, Loops Filled 3.4 .7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR train inoperable. A.1 Initiate action to restore Immediately a second RHR train to AND OPERABLE status. Required SG secondary OR side water level not within limits. A.2 Initiate action to restore Immediately required SG secondary side water level to within limits. B. Required RHR trains B.1 Suspend operations that Immediately inoperable. would cause introduction into the OR RCS, coolant with boron concentration less than No RHR train in operation . required to meet SOM of LCO 3.1.1. AND B.2 Initiate action to restore Immediately one RHR train to OPERABLE status and operation . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify one RHR train is in operation . 12hours ~ SR 3.4.7.2 Verify SG secondary side water level is ~ 16% in 12hours ~ required SG. (continued) HBRSEP Unit No. 2 3.4-17 Amendment No. 17e,1QO
RCS Loops - MODE 5, Loops Filled 3.4.7 SURVELLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4.7.3 Verify correct breaker alignment and indicated power 7 days ~ are available to the requi red RHR pump that is not in operation . HBRSEP Unit No. 2 3.4-18 Amendment No. 47e
RCS Loops - MODE 5, Loops Not Filled 3.4.8 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required RHR trains B.1 Suspend operations that Immediately inoperable. would cause introduction into the RCS , coolant with boron concentration less than No RHR train in operation . required to meet SOM of LCO 3.1.1. B.2 Initiate action to restore Immediately one RHR train to OPERABLE status and operation . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR train is in operation . 12 hours~ SR 3.4.8.2 Verify correct breaker alignment and indicated power 7 days ~ are available to the required RHR pump that is not in operation . HBRSEP Unit No. 2 3.4-20 Amendment No. 17e 190
Pressurizer 3.4.9 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 6 hours associated Completion Time of Condition B or C AND not met. D.2 Be in MODE 4. 12 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 Verify pressurizer water level is within limits. 12hours ~ SR 3.4.9.2 Verify capacity of required pressurizer heaters is 18month~
~ 125 kW.
SR 3.4.9.3 Verify required pressurizer heaters are capable of being powered from an emergency power supply. HBRSEP Unit No. 2 3.4-22 Amendment No. 47e
Pressurizer PORVs 3.4.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME F. (continued) F.2 Restore one block valve 2 hours to OPERABLE status. AND F.3 Restore remaining 72 hours block valve to OPERABLE status. G. Required Action and G.1 Be in MODE 3. 6 hours associated Completion Time of Condition F not met. AND G.2 Be in MODE 4. 12 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 -----------------------------NOTE------------------------------- Not required to be met with block valve closed in accordance with the Required Action of Condition B or E. Perform a complete cycle of each block valve. Q2days ~ (continued) HBRSEP Unit No. 2 3.4-27 Amendment No. 476
Pressurizer PORVs 3.4.11 SURVEILLANVE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4 .11.2 ------------------------------NOTE----------------------------- N ot required to be performed until 12 hours after entry into MODE 3. Perform a complete cycle of each PORV. 18months~ SR 3.4.11 .3 Perform a complete cycle of each solenoid 18 months~ air control valve and check valve on the nitrogen " ~ accumulators in PORV control systems. SR 3.4.11.4 Verify accumulators are capable of operating PORVs 18 months~ through a complete cycle. HBRSEP Unit No. 2 3.4-28 Amendment No. 47e
LTOP System 3.4.12 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME G. Two required PORVs G.1 Depressurize RCS and 8 hours inoperable. establish RCS vent of
<! 4.4 square inches.
Required Action and associated Completion Time of Condition A, B, D, E, or F not met. OR LTOP System inoperable for any reason other than Condition A, B, C, D, E, or F. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 --------------------------------NOTE------------------------------ 0 n ly required to be met when all RCS c'old leg temperatures <! 175°F and requirements of LCO 3.4.12.b not met. Verify a maximum of one SI pump is capable of 12hours ~ injecting into the RCS . (continued) HBRSEP Unit No. 2 3.4-32 Amendment No. 47e
LTOP System 3.4.12 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.4.12.2 ------------------------------NOTE------------------------------- 0 n ly required to be met when any RCS cold leg temperature < 175°F and requirements of LCO 3.4.12.b not met. Verify no SI pumps capable of injecting into the RCS . 12 hours ~ SR 3.4.12.3 Verify each accumulator isolation valve is closed and 12 hours ~ deenergized. SR 3.4.12.4 ------------------------------NOTE------------------------------- 0 nIy required to be met when complying with LCO 3.4.12.b. Verify RCS vent ~ 4.4 square inches open . 12 hours for unlocke n vent valve(s)
!INSERT 1 AND 31 days for locked open vent valve(s)
SR 3.4.12.5 Verify PORV block valve is open for each required 72 hours +-(--jlNSERT 1 PORV. . (continued) HBRSEP Unit No. 2 3.4-33 Amendment No. 7e
LTOP System 3.4.12 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4.12.6 ---------------------------- NOT E----------------------------- Not required to be performed until 12 hours after decreasing RCS cold leg temperature to~ 350°F. Perform a COT on each required PORV, excluding 31 days INSERT 1 actuation. SR 3.4.12.7 Perform CHANNEL CALIBRATION for each required 18 months ~ PORV actuation channel. HBRSEP Unit No. 2 3.4-34 Amendment No. ~
RCS Operational LEAKAGE 3.4.13 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.13.1 ------------------------------NOTES-----------------------------
- 1. Not required to be performed until 12 hours after establishment of steady state operation.
- 2. Not applicable to primary to secondary LEAKAGE.
Verify RCS operational LEAKAGE is within limits by 72 hours INSERT 1 performance of RCS water inventory balance. SR 3.4.13.2 ---------------- *------------NOTE-------------------------------- Not required to be performed until 12 hours after establishment of steady state operation . Verify primary to secondary LEAKAGE is~ 75 72 hours INSERT 1 gallons per day through any one SG. HBRSEP Unit No. 2 3.4-36 Amendment No. 242-
RCS PIVs 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1 --------------------------------NOTES---------------------------
- 1. Not required to be performed in MODES 3 and 4.
- 2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.
- 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.
Verify leakage from each RCS PIV is less than or In accordance with equal to an equivalent of 5 gpm at an RCS pressure the Inservice
<?: 2235 psig , and verify the margin between the Testing Program results of the previous leak rate test and the 5 gpm and 18 months~
limit has not been reduced by <?: 50% for valves with leakage rates > 1.0 gpm. AND Prior to entering MODE2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months (continued) HBRSEP Unit No. 2 3.4-39 Amendment No. 4-7e
RCS PIVs 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1 (continued) Within 24 hours following valve actuation due to automatic or manual action or flow through the valve SR 3.4.14.2 Verify RHR System interlock prevents the valves 18 months tjlNSERT 1 from being opened with a simulated or actual RCS pressure signal> 474 psig . I
. ,\'
HBRSEP Unit No. 2 3.4-40 Amendment No. 176 , 182
RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued) CONDITION REQIRED ACTION COMPLETION TIME D. Required containment D.1 Restore required 30 days atmosphere radioactivity containment atmosphere monitor inoperable. radioactivity monitor to OPERABLE status. AND OR Required containment fan cooler condensate flow rate D.2 Restore required 30 days monitor inoperable. containment fan cooler condensate flow rate monitor to OPERABLE status. E. Required Action and E.1 Be in MODE 3. 6 hours associated Completion Time not met. AND E.2 Be in MODE 5. 36 hours F. All required monitors F.1 Enter LCO 3.0.3. Immediately inoperable. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of the required 12hours ~ containment atmosphere radioactivity monitor. (continued) HBRSEP Unit No. 2 3.4-43 Amendment No. 47e
RCS Leakage Detection Instrumentation 3.4.15 SURVELLANCE REQUIREMENTS (continued) SURVELLANCE FREQUENCY SR 3.4.15.2 Perform COT of the required containment atmosphere 92 days ~ radioactivity monitor. SR 3.4.15.3 Perform CHANNEL CALIBRATION of the required 18 months ~ containment sump monitor. SR 3.4.15.4 Perform CHANNEL CALIBRATION of the required 18 months~ containment atmosphere radioactivity monitor. SR 3.4.15.5 Perform CHANNEL CALIBRATION of the required 18 months ~ containment fan cooler condensate flow rate monitor. HBRSEP Unit No. 2 3.4-44 Amendment No. 47e
RCS Specific Activity 3.4.16 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C. 1 Be in MODE 3 with 6 hours associated Completion Tavg < 500 ° F. Time of Condition A not met. OR DOSE EQUIVALENT 1-131
> 60 µCi/gm .
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.16.1 Verify reactor coolant gross specific ?days ~ activity s 100/E µCi/gm . SR 3.4.16.2 -----------------------------NOTE-------------------------------- 0 nly required to be performed in MODE 1. Verify reactor coolant DOSE EQUIVALENT 1-131 14days ~ specific activity s 0.25 µCi/gm . AND Between 2 and 6 hours after a THERMAL POWER change of;:: 15% RTP within a 1 hour period (continued) HBRSEP Unit No. 2 3.4-46 Amendment No. 2 RCS Specific Activity 3.4.16 SURVELLANCE REQUIREMENTS continued SURVELLANCE FREQUENCY SR 3.4.16.3 ----------------------------N OT E--------------------------------- N ot required to be performed until 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for ~ 48 hours. Determine E from a sample taken in MODE 1 after a 184 days ~ minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for ~ 48 hours. HBRSEP Unit No. 2 3.4-47 Amendment No. 47e
eves 3.4.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify seal injection flow of 2: 6 gpm to each RCP. 12 hours ~ SR 3.4.17.2 Verify seal injection flow of 2: 6 gpm to each RCP 18 months tjlNSERT 1 from each Makeup Water Pathway from the RWST . SR 3.4.17.3 For Makeup Water Pathways from the RWST to be In accordance with OPERABLE, SR 3.5.4.2 is applicable. SR 3.5.4.2 HBRSEP Unit No. 2 3.4-51 Amendment No. 47e
Accumulators 3.5.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 .Se in MODE 3. 6 hours associated Completion Time of Condition A or B AND not met. D.2 Reduce pressurizer 12 hours pressure to s 1000 psig . E. Two or more E.1 Enter LCO 3.0.3. Immediately accumulators inoperable. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify each accumulator isolation valve is fully open. Once prior to removing power from the valve operator SR 3.5.1.2 Verify borated water volume in each accumulator is ~ Re\:lfS ~
~ 825 ft and s 841 ft .
3 3 SR 3.5.1 .3 Verify nitrogen cover pressure in each accumulator is ~ Re\:lfS ~
~ 600 psig ands 660 psig.
(continued) HBRSEP Unit No. 2 3.5-2 Amendment No. 4-7&
Accumulators 3.5.1 SURVEILLANCE REQUIREMENRTS continued SURVELLANCE FREQUENCY SR 3.5.1.4 Verify boron concentration in each accumulator is 31days ~
;:: 1950 ppm and :s; 2400 ppm.
AND
-----NOTE------
Only required to be performed for affected accumulators Once within 6 hours after each solution volume increase of ;:: 70 gallons that is not the result of addition from the
.refueling water storage tank SR 3.5.1.5 Verify control power is removed from each 31 days ~!INSERT 1 I accumulator i?olation valve operator.
HBRSEP Unit No. 2 3.5-3 Amendment No.-1-+e
ECCS - Operating 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) 8 .2 Remove control power or air 24 hours to valve. C. Required Action and C. 1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 4. 12 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify the following valves are in the 12hours ~ listed position with control power to the valve operator removed . Number Position Function Sl-862 A&B Open Low Head Safety Injection (LHSI) Sl-863 A&B Closed LHSI Sl-864 A&B Open LHSI , High Head Safety Injection (HHSI) Sl-866 A&B Closed HHSI Sl-878 A&B Open HHSI SR 3.5.2.2 Verify each ECCS manual , power operated , and 31days ~ automatic valve in the flow path , that is not locked, sealed , or otherwise secured in position , is in the correct position . (continued) HBRSEP Unit No. 2 3.5-5 Amendment No. 47e
ECCS - Operating 3.5.2 SUREILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify each ECCS pump's developed head at the test In accordance with flow point is greater than or equal to the required the lnservice developed head. Testing Program SR 3.5.2.4 Verify each ECCS automatic valve in the flow path 18 ffiORths ~ that is not locked , sealed , or otherwise secured in position , actuates to the correct position on an actual or simulated actuation signal. SR 3.5.2.5 Verify each ECCS pump starts automatically on an 18 A=Jonths ~!INSERT 1 I actual or simulated actuation signal. SR 3.5.2.6 Verify, by visual inspection, the ECCS train 18 A=Jonths INSERT 1 containment sump suction inlet is not restricted by debris and the suction inlet trash strainers show no evidence of structural distress or abnormal corrosion. (continued) HBRSEP Unit No. 2 3.5-6 Amendment No.--2-1-a
ECCS - Operating 3.5.2 SURVEILLANCE FREQUENCY SR 3.5.2.7 Verify the following valves in the listed position: Number Position Function FCV-605 Closed/Motive RHR Air Isolated HCV-758 Closed/Motive RHR Air Isolated SR 3.5.2.8 Verify the following manual valve is locked in the Q2days ~ listed position
- Number Position Function RHR-764 Locked Open LHSI HBRSEP Unit No. 2 3.5-7 Amendment No. 47e
RWST 3.5.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.4 .1 ---------------------------NOTE------- *--- .---------------------- n 0 ly required .to be performed when ambient 1 air temperature is .< 45°F or> 100~F.
---------------------------------- *---------- *---------- I--------- ,---
Verify RWST borated water temperature is 2!: 45°F ands 100°F. SR 3.5.4.2 . . . , Verify RWST borated water volume *is 2!: 300,000 7days ~
*..ga)lons.
SR 3.5.4.3. Verify RWST bors>n C(?ncentration is 2!: 1950 ppm arid 7 days ~ s 2400 ppm . HBRSEP Unit No. 2 3.5-11 Amendment No. 47e
Containment Air Lock 3.6.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1 ---------------------------NOTES---------------------------------
- 1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.
- 2. Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.
Perform required air lock leakage rate testing in In accordance with accordance with the Containment Leakage Rate the Containment Testing Program . Leakage Rate Testing Program . SR 3.6.2.2 Verify only .one door in the air lock can be 24 months +-<--1PNSERT 1 j opened at a time. HBRSEP Unit No. 2 3.6-6 Amendment No. ~
Containment Isolation Valves 3.6.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 6 hours associated Completion Time not met. AND OR D.2 Be in MODE 5. 36 hours 42 inch penetration (Supply qr Exhaust) purge valves open and 6 inch penetration (pressure or vacuum relief) valves open simultaneously. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1 ---------------------------NOTE--------------------------------- T he 42 inch and 6 inch valves may not be open simultaneously. Verify each 42 inch purge supply and exhaust valve 31 days and each 6 inch pressure and vacuum relief valve is closed , except when the valves are open for safety related reasons, or for tests or Surveillances that require the valves to be open. IINJRT1 I (continued) HBRSEP Unit No. 2 3.6-10 Amendment No. 476
Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS continued SR 3.6.3.2 --------------------------N()TE----------------------------------- Valves and blind flanges in high radiation areas may be verified by use of administrative controls . Verify each containment isolation manual valve and a1 days for blind flange that is located outside containment and contai ent not locked , sealed or otherwise secured and required isolatio manual to be closed during accident conditions is closed, valves (e cept except for containment isolation valves that are open Penetratio under administrative controls. Pressurizat, n System valv with a diamete
$ 3/8 inch) and blind flanges INSERT 1 Penetration Pressurization System valves with a diameter
$ 3/8 inch SR 3.6.3.3 -----------------------N ()TE--------------------------------------
Va Ives and blind flanges in high radiation areas may be verified by use of administrative means. Verify each containment isolation manual valve and Prior to entering blind flange that is located inside containment and M()DE 4 from not locked , sealed or otherwise secured and required M()DE 5 if not to be closed during accident conditions is closed , performed within except for containment isolation valves that are open the previous under administrative controls. 92 days (continued) HBRSEP Unit No. 2 3.6-11 Amendment No. 47e
Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.3.4 Verify the isolation time of each automatic power In accordance operated containment isolation valve is within limits. with the Inservice Testing Program SR 3.6.3.5 Verify each automatic containment isolation valve 18months ~ that is not locked , sealed or otherwise secured in position , actuates to the isolation position on an actual or simulated actuation signal. SR 3.6.3.6 Verify each 42 inch inboard containment purge valve 18months ~ is blocked to restrict the valve from opening > 70°. HBRSEP Unit No. 2 3.6-12 Amendment No. 4+e
Containment Pressure 3.6.4 3.6 CONTAINMENT SYSTEMS 3.6.4 Containment Pressure LCO 3.6.4 Containment pressure shall be~ -0 .8 psig and :s; +1 .0 psig . ,APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment pressure not A.1 Restore containment 1 hour within limits. pressure to within limits. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1 Verify containment pressure is within limits. 12 hours +-(----1jlNSERT 1 I HBRSEP Unit No. 2 3.6-13 Amendment No. 47e
Containment Air Temperature 3.6.5 3.6 CONTAINMENT SYSTEMS 3.6.5 Containment Air Temperature LCO 3.6.5 Containment average air'temperature shall be :s 120°F. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment average air A.1 Restore containment 8 hours temperature not within average air temperature limit. to within limit. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 Verify containment average air temperature is within 24 hours ~ limit. HBRSEP Unit No. 2 3.6-14 Amendment No. 4+e
Containment Spray and Cooling Systems 3.6.6 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Two containment cooling D.1 Restore one 72 hours trains inoperable. containment cooling train to OPERABLE status. E. Required Action and E.1 Be in MODE 3. 6 hours associated Completion Time of Condition C or D AND not met. E.2 Be in MODE 5. 36 hours F. Two containment spray F.1 Enter LCO 3.0.3. Immediately trains inoperable. OR Any combination of three or more trains inoperable. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power 31 days ~ operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position. (continued) HBRSEP Unit No. 2 3.6-16 Amendment No. 47e
Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.6.2 Operate each containment cooling train fan unit for
;:: 15 minutes.
31 days < IINS ERT 1 SR 3.6.6.3 Verify cooling water flow rate to each cooling unit is 31 days ( IINS ERT 1
;:: 750 gpm.
SR 3.6.6.4 Verify each containment spray pump's developed In accordance with head at the flow test point is greater than or equal to the lnservice the required developed head . Testing Program SR 3.6.6.5 Verify each automatic containment spray valve in the 1ij FReRtRS IN flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal. . SR 3.6.6.6 Verify each containment spray pump starts 1ij FR9RtRS IN automatically on an actual or simulated actuation signal. SR 3.6.6.7 Verify each containment cooling train starts 1ij FReRtRS INS automatically on an actual or simulated actuation signal. SR 3.6.6.8 Verify each spray nozzle is unobstructed . Following activities which could result in nozzle blockage HBRSEP Unit No. 2 3.6-17 Amendment No. 176 194
Spray Additive System 3.6.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.7.1 Verify each spray additive manual , power operated ,
- 31 days ~
and automatic valve in the flow path that is not locked , sealed , or otherwise secured in position is in the correct position . SR 3.6.7.2 Verify spray additive tank solution volume is 184 days ~
~ 2505 gal.
SR 3.6.7.3 Verify spray additive tank NaOH solution 184 days ~ concentration is ~ 30% by weight. SR 3.6.7.4 Verify each spray additive automatic valve in the flow 18 months ~ path that is not locked , sealed , or otherwise secured in position , actuates to the correct position on an actual or simulated actuation signal. HBRSEP Unit No. 2 3.6-19 Amendment No. 47e
Isolation Valve Seal Water System 3.6.8 3.6 CONTAINMENT SYSTEMS 3.6.8 Isolation Valve Seal Water (IVSW) System LCO 3.6.8 The IVSW System shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. IVSW system A.1 Restore IVSW system to 72 hours inoperable. OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not AND met. B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.8.1 Verify IVSW tank pressure is ~ 46.2 psig. 12hours ~ SR 3.6.8.2 Verify the IVSW tank volume is ~ 85 gallons. 31days ~ (continued) HBRSEP Unit No. 2 3.6-20 Amendment No. ~
Isolation Valve Seal Water System 3.6.8 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.8.3 Verify the opening time of each air operated In accordance with header injection valve is within limits. the Inservice Testing Program SR 3.6.8.4 Verify each automatic valve in the IVSW System 18A1onths ~ actuates to the correct position on an actual or simulated actuation signal. SR 3.6.8.5 Verify the IVSW dedicated nitrogen bottles will 18Alonths ~ pressurize the IVSW tank to~ 46.2 psig . SR 3.6.8.6 Verify total IVSW seal header flow rate is 1*8 AlORths ~
- 124 cc/minute HBRSEP Unit No. 2 3.6-21 Amendment No. ~
AFW System 3.7.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each AFW manual, power operated, and 31days ~ automatic valve in each water flow path , and in the steam supply flow path to the steam driven AFW pump, that is not locked , sealed , or otherwise secured in position, is in the correct position. SR 3.7.4.2 ----------------------------NOTE--------------------------------- Not required to be performed for the steam driven AFW pump until 24 hours after ~ 1000 psig in the steam generator. Verify the developed head of each AFW pump at the 31 days on a flow test point is greater than or equal to the required STAGGERED ~ developed head. TEST B,<\SIS SR 3.7.4 .3 ----------------------------NOTE--------------------------------- Not applicable in MODE 4 when steam generator is being used for heat removal. Verify each AFW automatic valve that is not locked, 18R1onths ~ sealed , or otherwise secured in position , actuates to the correct position on an actual or simulated actuation signal. (continued) HBRSEP Unit No. 2 3.7-12 Amendment No. 4+e
AFW System 3.7.4 SURFEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.7.4.4 -------------------------NOTES----------------------------------
- 1. Not required to be performed for the steam driven AFW pump until 24 hours after ~ 1000 psig in the steam generator.
- 2. Not applicable in MODE 4 when steam generator is being used for heat removal.
Verify each AFW pump starts automatically on an 18months ~ actual or simulated actuation signal. SR 3.7.4.5 -----------------------*--NOTE------------------------------------ Not required to be performed for the steam driven AFW pump until prior to entering MODE 1. Verify proper alignment of the required Prior to entering AFW flow paths by verifying flow from the MODE 2, condensate storage tank to each steam generator. whenever unit has been in MODE 5 or 6 for> 30 days SR 3.7.4.6 Verify the AFW automatic bus transfer switch 18months ~ associated with discharge valve V2-16A operates automatically on an actual or simulated actuation signal. HBRSEP Unit No. 2 3.7-13 Amendment No. 4-+e
CST 3.7.5 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. SWS supply to AFW C.1 Be in MODE 3. 6 hours system inoperable. C.2 Be in MODE 4 , without 18 hours reliance on steam generator for heat removal. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 Verify the CST level is~ 35,000 gal. 12hours ~ SR 3.7.5.2 Verify by administrative means OPERABILITY of d1days ~ backup SWS supply to the AFW System . HBRSEP Unit No. 2 3.7-15 Amendment No. 47e
CCW System 3.7.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7 .6.1 -------------------------------NOTE------------------------------- 1so Iat ion of CCW flow to individual components does not render the CCW System inoperable. Verify each required CCW manual, power operated , 31 days ~ and automatic valve in the flow path servicing safety related equipment, that is not locked , sealed , or otherwise secured in position , is in the correct position . SR 3.7.6.2 Verify each required CCW pump starts automatically 18 months ~NSERT 1 on an actual or simulated LOP DG Start undervoltage signal. HBRSEP Unit No. 2 3.7-17 Amendment No. 17e 18e I
sws 3.7.7 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Two Turbine Building loop C. 1 Close and deactivate 2 hours isolation valves inoperable. one inoperable Turbine Building loop isolation valve. D. Required Actions and D.1 Be in MODE 3. 6 hours associated Completion Times of Conditions A, B, AND or C not met. D.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.7.1 --------------------------NOTE----------------------------------- 1so Iati on of SWS flow to individual components does not render the SWS inoperable. Verify each SWS manual , power operated , and automatic valve in the flow path servicing safety related equipment, that is not locked , sealed , or otherwise secured in position , is in the correct position . SR 3.7.7.2 Verify each SWS automatic valve in the flow path 18 months ~ that is not locked , sealed , or otherwise secured in position , actuates to the correct position on an actual or simulated actuation signal. (continued) HBRSEP Unit No. 2 3.7-19 Amendment No. 47e
sws 3.7.7 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.7.7.3 Verify each SWS pump and SWS booster pump 18months ~ starts automatically on an actual or simulated actuation signal. SR 3.7.7.4 Verify the SWS automatic bus transfer switch 18months ~ associated with Turbine Building loop isolation valve V6-16C operates automatically on an actual or simulated actuation signal. HBRSEP Unit No. 2 3.7-20 Amendment No. 476
UHS 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Ultimate Heat Sink (UHS) LCO 3.7.8 The UHS shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Service water A.1 Verify required cooling 1 hour temperature not within capacity maintained . limit. AND Once per 12 hours thereafter AND A.2 Verify service water Once per hour temperature is :-=: ; 99°F. B. Required Action and 8 .1 Be in MODE 3. 6 hours associated Completion Time not met. AND OR 8.2 Be in MODE 5. 36 hours UHS inoperable for reasons other than Condition A. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 Verify water level of UHS is:::: 218 ft mean sea level. 24 hours ~ HBRSEP Unit No. 2 3.7-21 Amendment No. 494-
UHS 3.7.8 SURVEILLANCE REQUIREMENTS continued SR 3.7.8.2 Verify service water temperature is~ 97°F. 24hours ~ HBRSEP Unit No. 2 3.7-21a Amendment No. 494
CREFS 3.7.9 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME H Required Action and H. Be in MODE 3. 6 hours associated Completion Time of Condition G not AND met in MODE 1, 2, 3, or 4. H.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Operate each CREFS train for~ 15 minutes. 31 days ~ SR 3.7.9 .2 Perform required CREFS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). VFTP SR 3.7.9.3 Verify each CREFS train actuates on an actual or 18 months ~ simulated actuation signal. SR 3.7.9.4 Perform required CRE maintenance and testing in In accordance with accordance with the CRE Habitability Program . the CRE Habitability Program HBRSEP Unit No. 2 3.7-24 Amendment No. ~
CREATC 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Verify each CREA TC WCCU train has the capability 18 months ~ to remove the assumed heat load . HBRSEP Unit No. 2 3.7-27 Amendment No. 4+e
FBACS 3.7.11
- 3. 7 PLANT SYSTEMS 3.7.11 Fuel Building Air Cleanup System (FBACS)
LCO 3.7.11 The FBACS shall be OPERABLE and operating. APPLICABILITY: During movement of irradiated fuel assemblies in the fuel building . ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. The FBACS inoperable A.1 Suspend movement of Immediately during movement of irradiated fuel irradiated fuel assemblies assemblies in the fuel in the fuel building . building. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Operate the FBACS for 2: 15 continuous minutes with 31 days ~ the heaters operating automatically. SR 3.7.11 .2 Perform required FBACS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP) . the VFTP (continued) HBRSEP Unit No. 2 3.7-28 Amendment No. ~
FBACS 3.7.11 SURVEILLANCE REQUIREMENTS continued SR 3.7.11 .3 ---------------------------NOTE------ -------' --' . __ -- . ----- ,, --- . Not required to be met when the only movement of irradiated fuel is movement of fhe spent fuel 'shipping cask containing irradiated fuel. Verify the FBACS can maintain a negative pressure 18months _~ with respect to atmospheric .pressure.
*;.
- I ',. 1 I t , .*
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,' l HBRSEP Unit No. 2 3.7-29 Amendment No. 4+e
Fuel Storage Pool Water Level 3.7.12 3.7 PLANT SYSTEMS 3.7.12 Fuel Storage Pool Water Level LCO 3.7.12 The fuel storage pool water level shall be~ 21 ft over the top of irradiated fuel assemblies seated in the storage racks. APPLICABILITY: During movement of irradiated fuel assemblies in the fuel storage pool. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool water A.1 -----------NOTE------------- level not within limit. LCO 3.0.3 is not applicable. Suspend movement of Immediately irradiated fuel assemblies in the fuel storage pool. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 Verify the fuel storage pool water level is ~ 21 ft ?days ~ above the top of the irradiated fuel assemblies seated in the storage racks. HNRSEP Unit No. 2 3.7-30 Amendment No. 4-7e
Fuel Storage Pool Boron Concentration 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Fuel Storage Pool Boron Concentration LCO 3.7 .13 The fuel storage pool boron concentration shall be ;:: 1500 ppm. APPLICABILITY: At all times. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool boron -----------------NO TE-------------------- concentration not within LCO 3.0.3 is not applicable. limit. A.1 Suspend movement of Immediately fuel assemblies in the fuel storage pool. A.2 Initiate action to restore Immediately fuel storage pool boron concentration to within limit. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Verify the fuel storage pool boron concentration is 7 days -(--<!INSERT 1 I within limit. HBRSEP Unit No. 2 3.7-31 Amendment No. 4Q8
Secondary Specific Activity 3.7.15 3.7 PLANT SYSTEMS 3.7.15 Secondary Specific Activity LCO 3.7.15 The specific activity of the secondary coolant shall be~ 0.10 µCi/gm DOSE EQUIVALENT 1-131 . APPLICABILITY: MODES 1, 2, 3, and 4 . ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Specific activity not within A.1 Be in MODE 3. 6 hours limit. AND A .2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.15.1 Verify the specific activity of the secondary coolant is 31 days -<-.. .!INSERT 1 I
~ 0.10 µCi/gm DOSE EQUIVALENT 1-131.
HBRSEP Unit No. 2 3.7-33 Amendment No. 476
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated +Elays -<--!INSERT 1 l power availability for the offsite circuit. SR 3.8.1 .2 -------------------------NOTES--------------------------------
- 1. Performance of SR 3.8.1 .7 satisfies this SR.
- 2. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading .
- 3. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. When modified start
. procedures are not used , the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.
Verify each DG starts from standby conditions and 31 days ( . !INSERT 1 l achieves steady state voltage:::: 467 V ands; 493 V, and frequency:::: 58.8 Hz and s; 61.2 Hz. (continued) HBRSEP Unit No. 2 3.8-4 Amendment No. 4+e
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.3 -----------------------------N OTES------------------------------
- 1. DG loadings may include gradual loading as recommended by the manufacturer.
- 2. Momentary transients outside the load range do not invalidate this test.
- 3. This Surveillance shall be conducted on only one DG at a time.
- 4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.
- 5. During periods when a diesel generator is being operated for testing purposes , its protective trip~ need not be bypassed after the diesel generator has properly assumed the load on its bus.
. Verify each DG is synchronized and loaded and 31 days +-(-------11!NSERT 1 I operates for ~ 60 minutes at a load ~ 2350 kW and
~ 2500 kW.
SR 3.8.1.4 Verify each day tank contains~ 140 gallons of fuel oil. 31 days +-(--11!NSERT 1 I SR 3.8.1 .5 Check for and remove accumulated water from each 31 days ~<-~!INSERT 1 I day tank. (continued) HBRSEP Unit No. 2 3.8-5 Amendment No. 4+e
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1 .6 Verify the fuel oil transfer system operates to 31 days ~<---1jlNSERT 1 I automatically transfer fuel oil from storage tank to the day tank, SR 3.8.1.7 --------------------------NOTES-------------------------------- AII DG starts may be preceded by an engine prelube period . Verify each DG starts from standby condition and 184 days ~ achieves in s 1O seconds , voltage ~ 467 V and frequency ~ 58.8 Hz, and after steady state conditions are reached , maintains voltage~ 467 V ands 493 V and frequency ~ 58 .8 Hz and s 61.2 Hz. SR 3.8.1.8 ---------------------------N OTES-------------------------------
- 1. This Surveillance shall not be performed in MODE 1 or 2.
- 2. If performed with the DG synchronized with offsite power, it shall be performed at a power factors 0.9.
Ve'rify each DG rejects a load greater than or equal to 18 months ~ its associated single largest post-accident load and does not trip on overspeed. * (continued) HBRSEP Unit No. 2 3.8-6 Amendment No. 47e
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1 .9 ----------------------------N OTES------------------------------
- 1. All DG starts may be preceded by an engine prelube period.
- 2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
- 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
Verify on an actual or simulated loss of offsite power 18months ~ signal:
- a. De-energization of emergency buses; b Load shedding from emergency buses;
- c. DG auto-starts from standby condition and:
- 1. energizes permanently connected lo.ads in :s; 10 seconds,
- 2. energizes auto-connected shutdown loads through automatic load sequencer,
- 3. maintains steady state voltage 2!: 467 V and :s; 493 V,
- 4. maintains steady state frequency 2!: 58.8 Hz and :s; 61 .2 Hz, and
- 5. supplies permanently connected and auto-connected shutdown loads for 2!: 5 minutes.
(continued) HBRSEP Unit No. 2 3.8-7 Amendment No. 47e
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1 .10 ---------------------------NOTES------------------------------- 1 All DG starts may be preceded by prelube period .
- 2. This Surveillance shall not be performed in MODE 1 or 2.
- 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
- Verify on an actual or simulated Engineered Safety Feature (ESF) actuation signal each DG auto-starts from standby condition and:
- a. In :5 10 seconds after auto-start achieves voltage~ 467 V, and after steady state conditions are reached, maintains voltage
~ 467 V and :5 493 V;
- b. In :5 1O seconds after auto-start achieves frequency ~ 58.8 Hz, and after steady state conditions are reached, maintains frequency
~ 58.8 Hz and :5 61 .2 Hz; *
- c. Operates for ~ 5 minutes;
- d. Permanently connected loads remain energized from the offsite power system; and
- e. Emergency loads are energized through the automatic load sequencer from the offsite power system.
(continued) HBRSEP Unit No. 2 3.8-8 Amendment No. 4+e
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1 .11 Verify each DG's automatic trips are bypassed except engine overspeed . 24months ~ SR 3.8.1.12 ---------------------------NOTES--------------------------------
- 1. Momentary transients outside the load and power factor ranges do not invalidate this test.
- 2. This Surveillance shall not be performed in MODE 1 or 2.
- 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
Verify .each DG operating at a power factors 0.9 18months ~ operates for ~ 24 hours:
- a. For~ 1.75 hours loaded~ 2650 kW and s 2750 kW; and
- b. For the remaining hours of the test loaded
~ 2400 kW and s 2500 kW.
(continued) HBRSEP Unit No. 2 3.8-9 Amendment No. ~
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.13 -------------------------------NOTES----------------------------
- 1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated ~ 2 hours loaded ~ 2400 kW and
~ 2500 kW.
Momentary transients outside of load range do not invalidate this test.
- 2. All DG starts may be preceded by an engine prelube period .
Verify each DG starts and achieves, in ~ 1O seconds, 18 months ~ voltage~ 467 V, and frequency~ 58.8 Hz, and after steady state conditions are reached , maintains voltage~ 467 V and~ 493 V and frequency~ 58.8 Hz and~ 61 .2 Hz. SR 3.8.1 .14 * ' ----------------------------NOTE-------------------------------- This Surveillance shall not be performed in MODE 1, 2, 3, or 4. Verify actuation of each sequenced load block is 18months ~ within+/- 0.5 seconds of design setpoint for each emergency load sequencer. (continued) HBRSEP Unit No. 2 3.8-10 Amendment No. 47e
AC Sources-Operating 3.8 .1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1 .15 ---------------------------NOTES--------------------------------
- 1. All DG starts may be preceded by an engine prelube period.
- 2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
- 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
Verify on an actual or simulated loss of offsite power 18 months ~ signal in conjunction with an actual or simulated ESF actuation signal:
- a. De-energization of emergency buses;
- b. Load shedding from emergency buses; and
- c. DG auto-starts from standby condition and :
- 1. energizes permanently connected loads in
- 5 10 seconds,
- 2. energizes auto-connected emergency loads through load sequencer,
- 3. achieves steady state voltage 2: 467 V and
- 5 493 V,
- 4. achieves steady state frequency 2: 58.8 Hz and
- 5 61.2 Hz, and (continued)
HBRSEP Unit No. 2 3.8-11 Amendment No. 4+e
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.15 (continued)
- 5. supplies permanently connected and auto connected emergency loads for ;:: 5 minutes.
SR 3.8.1.16 -------------------------NOTE------------------------------------
- 1. This Surveillance shall not be performed in MODE 1 or 2.
- 2. SR 3.8.1.16 is not required to be met if 4.160 kV bus 2 and 480 V Emergency Bus 1 power supply is from the start up transformer.
Verify automatic transfer capability of the 4.160kV bus 18 months ~ 2 and the 480V Emergency bus 1 loads from the Unit auxiliary transformer to the start up transformer. SR 3.8.1 .17 ------------------------NOTE------------------------------------- A II DG starts *may be preceded by an engine *prelube period . Verify when started simultaneously from standby 10 years ~ condition, each DG achieves, in s 10 seconds, voltage
;:: 467 V and frequency ;:: 58.8 Hz, and after steady state conditions are reached, maintains voltage 2!
467 V ands 493 V and frequency;:: 58'.8 Hz and S61 .2Hz. HBRSEP Unit No. 2 3.8-12 Amendment No. 4+e
Diesel Fuel Oil , and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify 2! 19,000 gallons of diesel fuel oil available to ?days ~ the DGs from the Unit 2 DG fuel oil storage tank 2! 34,000 gallons available to the DGs from the combination of the Unit 1 IC turbine fuel oil storage tanks and the Unit 2 DG fuel oil storage tank. SR 3.8.3.2 Verify fuel oil properties of stored fuel oil are tested in In accordance with accordance with , and maintained within the limits of, the Diesel Fuel Oil the Diesel Fuel Oil Testing Program . Testing Program SR 3.8.3.3 Verify each DG air start receiver pressure is 31days ~ 2! 210 psig . SR 3.8.3.4 Check for and remove accumulated water from each a~~ays *~ fuel oil storage tank. HBRSEP Unit No. 2 3.8-18 Amendment No. 4+e
DC Sources-Operating
~
3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One DC electrical power A.1 Restore DC electrical 2 hours subsystem inoperable. power subsystem to OPERABLE status. B.* Required Action and B.1 Be in MODE 3. 6 hours Associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is~ 125.7 Von float 7days ~ charge . (continued) HBRSEP Unit No. 2 3.8-19 Amendment No.47e
DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.4.2 Verify battery cells, cell plates, and racks show no 18 months ~ visual indication of physical damage or abnormal deterioration that could degrade battery performance. SR 3.8.4.3 Remove visible terminal corrosion, verify battery cell to 18 months ~ cell and terminal connections are clean and tight, and are coated with anti-corrosion material. SR 3.8.4.4 Verify each battery charger supplies ~ 300 amps at 18 months ~
~ 125 V for~ 4 hours.
SR 3.8.4.5 -----------------------NOTES----------------------------------
- 1. The modified performance discharge test in SR 3.8.4.6 may be performed in lieu of the service test in SR 3.8.4.5.
- 2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
Verify battery capacity is adequate to supply, and 18months ~ maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test. (continued) HBRSEP Unit No. 2 3.8-20 Amendment No. ~
DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.4.6 ---------------------------NOTE---------------------------------- This Surveillance shall not be performed in MODE 1, 2, 3, or 4. Verify battery capacity is ~ 80% for the "A" Battery and 60months ~ 91 % for the "B" battery of the manufacturer's rating when subjected to a performance discharge test or a AND modified performance discharge test. 1 12 moaths~:~nSERT I battery shows degradation or has reached 85% of expected life with capacity
< 100% of manufacturer's rating .
AND lNSERT 1 j 24 months when
.. battery has reached 85% of expected life with capacity
~ 100% of manufacturer's rating .
HBRSEP Unit No. 2 3.8-21 Amendment No. ~
I Battery Cell Parameters I 3.8.6 ACTIONS (continued) I CONDITION REQUIRED ACTION COMPLETION TIME
- 8. Required Action and 8 .1 Declare associated Immediately associated Completion battery inoperable.
Time of Condition A not met. One or more batteries with average electrolyte temperature of the representative cells
< 67°F.
OR One or more batteries with one or more battery cell parameters not within Category C values. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 Verify battery cell parameters meet Table 3.8.6-1 7 days -(-jlNSERT 1 I Category A limits. (continued) H8RSEP Unit No. 2 3.8-25 Amendment No. 47e
Battery Cell Parameters 3.8.6 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.6.2 Verify battery cell parameters meet Table 3.8.6-1 Q2 days ~(-1jlNSERT 1 l Category B lirnits. Once within 24 hours after a battery discharge
< 110 V Once within 24 hours after a battery overcharge
> 150V SR 3.8.6.3 Verify average electrolyte temperature of Q2days ~
representative cells is~ 67°F. HBRSEP Unit No. 2 3.8-26 Amendment No. 4+e
NO CHANGE ON THIS PAGE - PROVIDED FOR Battery Cell Parameters INFORMATION ONLY 3.8.6 Table 3.8.6-1 (page 1 of 1) Battery Cell Parameters Requirements CATEGORY A: CATEGORY C: LIMITS FOR EACH CATEGORY B: ALLOWABLE LIMITS DESIGNATED PILOT LIMITS FOR EACH FOR EACH PARAMETER CELL CONNECTED CELL CONNECTED CELL Electrolyte Level > Minimum level > Minimum level Above top of plates, indication mark, and indication mark, and and not overflowing
- 5 % inch above :s; % inch above maximum level maximum level indication mark(a) indication mark(a)
Float Voltage ~ 2.13 V ~ 2.13 V > 2.07 V Specific Gravity(b)(c) ~ 1.200 ~ 1.195 Not more than 0.020 below average of all AND connected cells Average of all AND connected cells
> 1.205 Average of all connected cells
~ 1.195 (a) It is acceptable for the electrolyte level to temporarily increase above the specified maximum during equalizing charges provided it is not overflowing.
(b) Corrected for electrolyte temperature and level. Level correction is not required , however, when battery charging current is < 2 amps while on float charge. (c) A battery charging current of< 2 amps when on float charge is acceptable for meeting specific gravity limits following a battery recharge, for a maximum of 7 days. When charging current is used to satisfy specific gravity requirements, specific gravity of each connected cell shall be measured prior to expiration of the 7 day allowance. HBRSEP Unit No. 2 3.8-27 Amendment No. 176
AC Instrument Bus Sources-Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct inverter voltage, frequency , and 7 days ~ alignment to required AC instrument buses. SR 3.8.7.2 Verify voltage availability and correct CVT alignment 7 days ~!INSERT 1 I to required AC instrument buses. HBRSEP Unit No. 2 3.8-29 Amendment No. 479
AC Instrument Buses-Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SOM or boron concentration . A.2.4 Initiate action to restore Immediately AC instrument bus sources to OPERABLE status . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 ----------------------------NOTE--------------------------------- Actual voltage and frequency measurement is not required for AC instrument buses supplied from CVTs. Verify correct inverter voltage, frequency , and 7days ~ alignments to required AC instrument buses. HBRSEP Unit No. 2 3.8-31 Amendment No. 176,190
Distribution Systems-Operating 3.8.9 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME G. Two trains with inoperable G.1 .Enter LCO 3.0.3. Immediately distribution subsystems that result in a loss of safety function . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 ---------------------------NOTE---------------------------------- A ct ua I voltage measurement is not required for the AC vital buses supplied from the constant voltage transformers. Verify correct breaker alignments and voltage to AC , 7 days ~
- DC , and AC instrument bus electrical power distribution subsystems.
SR 3.8.9.2 Verify capability of the two molded case circuit breakers for AFW Header Discharge Valve to SIG "A", V2-16A to trip on overcurrent. SR 3.8.9.3 Verify capability of the two molded case circuit 18months ~ breakers for Service Water System Turbine Building Supply Valve (emergency supply) , V6-16C to trip on overcurrent. HBRSEP Unit No. 2 3.8-34 Amendment No. 47e
Distribution Systems-Shutdown 3.8.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SOM or boron concentration . AND A.2.4 Initiate actions to restore Immediately required AC , DC , and AC instrument bus electrical power distribution subsystems to OPERABLE status . AND A.2.5 Declare associated Immediately required residual heat removal subsystem(s) inoperable and not in operation . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 ---------------------------NOTE---------------------------------- A ct uaI voltage measurement is not required for the AC vital buses supplied from constant voltage transformers. Verify correct breaker alignments and voltage to ?days ~ required AC, DC , and AC instrument bus electrical power distribution subsystems. HBRSEP Unit No. 2 3.8-36 Amendment No. 176,190
Boron Concentration 3.9.1 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 Boron concentrations of the Reactor Coolant System , the refueling canal , and the refueling cavity shall be maintained within the limit specified in the COLR. APPLICABILITY: MODE 6. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Boron concentration not A.1 Suspend CORE Immediately within limit. ALTERATIONS . A.2 Suspend positive Immediately reactivity additions. A.3 Initiate action to restore Immediately boron concentration to within limit. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1 .1 Verify boron concentration is within the limit specified 72 hours +-(---1!1NSERT 1 I in COLR. HBRSEP Unit No. 2 3.9-1 Amendment No. 47e
Nuclear Instrumentation 3.9.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.2.1 Perform CHANNEL CHECK. SR 3.9.2.2 ----------------------N()TE-------------------------------------- Neutron detectors are excluded from CHANNEL CALIBRATl()N. Perform CHANNEL CALIBRATl()N. 18months ~ HBRSEP Unit No. 2 3.9-3a Amendment No. 17e,180,1QO I
Containment Penetrations 3.9.3 SURVEILLANCE REQUIREMENTS SURVEIL LANCE FREQUENCY SR 3.9.3.1 Verify each required containment penetration is in the 7 days ~ required status. SR 3.9.3.2 Verify each required containment ventilation valve 18 months ~ actuates to the isolation position on an actual or simulated actuation signal. HBRSEP Unit No. 2 3.9-5 Amendment No. 47e
RHR and Coolant Circulation-High Water Level 3.9.4 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Initiate action to satisfy Immediately RHR train requirements . AND A.4 Close all containment 4 hours penetrations providing direct access from containment atmosphere to outside atmosphere. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.4.1 Verify one RHR train is in operation . HBRSEP Unit No. 2 3.9-7 Amendment No. 17e,190
RHR and Coolant Circulation-Low Water Level 3.9.5 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2 Initiate action to restore Immediately one RHR train to operation . AND B.3 Close all containment 4 hours penetrations providing direct access from containment ~ atmosphere to outside atmosphere. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR train is in operation . 12hours ~ SR 3.9.5 .2 Verify correct breaker alignment and indicated power 7 days ~<----l!INSERT 1 l available to the required RHR pump that is riot in operation . HBRSEP Unit No. 2 3.9-9 Amendment No. 4+e
Refueling Cavity Water Level 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Refueling Cavity Water Level LCO 3.9.6 Refueling cavity water level shall be maintained ;:: 23 ft above the top of reactor vessel flange. APPLICABILITY: During movement of irradiated fuel assemblies within containment. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Refueling cavity water level A. 1 Suspend movement of Immediately not within limit. irradiated fuel assemblies within containment. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify refueling cavity water level is ;:: 23 ft above the 24 hours ~ top of reactor vessel flange. HBRSEP Unit No. 2 3.9-10 Amendment No. 17e 195
Containment Purge Filter System 3.9.7 SURVEILLANCE REQUIREMETS SURVEILLANCE FREQUENCY SR 3.9.7.1 Verify relative humidity of containment atmosphere to 4--RGYF ~ be processed by the Containment Purge Filter System is s 70%. SR 3.9.7.2 Verify the Containment Purge Filter System is in 12 hours ~!INSERT 1 I operation and maintaining containment pressure negative relative to the adjacent auxiliary building areas. SR 3.9 .7.3 Perform required Containment Purge Filter System In accordance with filter testing in accordance with the Ventilation Filter the VFTP Testing Program (VFTP) . HBRSEP Unit No. 2 3.9-12 Amendment No. 47e
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.17 Control Room Envelope Habitability Program (continued)
' ' ~ .' .
- a. The definition of the CRE and the CRE boundary.
- b. Requirements for maintaining the CRE boundary in its design condition ,
including configuration* control and preve.l'!tive, mainte~al")_ae: C. Requirements for: (i). determining the :unfiltered*air ri nleakage past the
.CRE boundary into .the CRE ~n accordance with th_e testing methods and c1t the frequencies spec(fied in St3ctions ..C.1 _~nd C.?: 9f Reg1,.1latory Guide 1.197, "Demonstratin*g Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0. The following excepti9ri i's takeh ki Sections C.1 and
. C.2* of Regulatory Guide 1.197, Revision* O:
- 1. Unfiltered air inleakage testing shall include*the ability to deviate from the test methodology of ASTM-E7 41. These exceptions shall be documented in the.test report.
- d. Measurement, at d~sig!lated loqations,, of the CRE pressure relative to external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFS , operating at the flow rate required*oy thef VFTP 1 at a frequency of 18 months on a STAGGERED
*if.ESt BASIS*. The re*sults shall be trended and used' as part of the assessment of the CRE boundary. ,* * *
- e. The quantitative limits on unfiltered air inleakage into the CRE . These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.
The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences. For hazardous chemicals, inleakage rates shall be less than assumed in the licensing bases.
- f. The provisions of SR 3.0.2 are applicable to the frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by
~---~
INSERT 2 paragraphs c and d, respectively. HBRSEP 5.0-22a Amendment No. -z4 Robinson Technical Specification Inserts for TSTF-425, Revision 3 Insert 1 In accordance with the Surveillance Frequency Control Program Insert 2 5.5.18 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.
- a. The Surveillance Frequency Control Program shall contain a list of FreqCJencies of those Surveillance Requirements for which the Frequency is controlled by the program .
- b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies, " Revision 1.
- c. The .provisions of Surveillance Requirement~ 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program .
to RNP-RA/18-0015
. . A ITACHMENT'*4
. s*
- License Amendment Request H.B. Robinson Steam *E lectric Plant, UnitNo. 2 (HBRSEP)
Docket No. 50-261 Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of.Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)
- Proposed Technical Specification Bases Page Changes
Robinson Technical Specification Bases Inserts for TSTF-425, Revision 3 Insert 3 The Surveillance F/eqyency is. contrpllep under the Surveillance Frequef1Cy C.ontrol Program. 1.,,.,, Insert 4
, * *. * ' .. ' *, . 1 1 > **
- l ,,. ' / * * * *. 'r . *, ,. , \ . . : . *' ,
The SurveUlc!nce freqµe~cie~i~r~ ,conyolled upder. ~he ?Urv~,il_lanee1 Frequer;:i,cy .C~>ntrql Program. *; : ; ,,.. *** ;:> '
SOM B 3.1.1 BASES SURVEILLANCE SR 3.1 .1.1 (continued) REQUIREMENTS
- c. RCS average temperature;
- d. Fuel burnup based on previous critical boron concentration;
- e. Xenon concentration ;
- f. Samarium concentration ; and
- g. Isothermal temperature coefficient (ITC).
Using the ITC accounts for Doppler reactivity in this calculation because the reactor is subcritical , and the fuel temperature will be changing at the same rate as the RCS.
+he Frequency of 24 hours is based on the generally slow change in required boron concentration and the low probability of an accident
!INSERT 3 i-1--->~ occurring without the required SOM . +his allows time for the operator to collect the required data, which includes performing a boron concentration analysis, and complete the verification.. REFERENCES 1. UFSAR, Section 3.1.
- 2. UFSAR, Section 15.1.5.
- 3. UFSAR, Section 15.4.6.
- 4. Deleted .
- 5. UFSAR, Table 15.4.6-1 .
- 6. UFSAR, Table 9.3.4-1 .
HBRSEP Unit No. 2 B 3.1-6 Revision No. 34-
Core Reactivity B 3.1.2 BASES (continued) SURVEILLANCE SR 3.1.2.1 REQUIREMENTS Core reactivity is verified by periodic comparisons of measured and predicted RCS boron concentrations. The comparison is made, considering that other core conditions are fixed or stable , including control rod position , moderator temperature, fuel temperature, fuel depletion, xenon concentration , and samarium concentration . The Surveillance is performed prior to entering MODE 1 as an initial check on core conditions and design calculations at BOC. The SR is modified by a Note. The Note indicates that the normalization of predicted core reactivity to the measured value must take place within the first 60 effective full power days (EFPD) after each fuel loading . This allows sufficient time for core conditions to reach steady state, but prevents operation for a large fraction of the fuel cycle without establishing a benchmark for the design calculations. The required subsequent i;requenoy of 31 Ei;Po, following the initial 60 Ei;Po after entering MODE 1, is aooeptable, based on the slow rate of sore changes due to fuel depletion and the presence of other indicators (QPTR , Ai;o , eto.) for f*8fflf3t indication of an anomaly. 1'
!INSERT 3 !
REFERENCES 1 .UFSAR Section 3.1.
- 2. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.1-12 Revision No. Q
Rod Group Alignment Limits B 3.1.4 BASES ACTIONS D.2 (continued) The allowed Completion Time is reasonab le, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.1.4.1 REQUIREMENTS 1*
\ ~ rifisation that individual rod positions are within alignmm~t limits at a Frequensy of 12 hours provides a history that allows the operator to detest a rod that is beginning to deviate from its expested position. If the
!INSERT 3 1-j->~ rod position deviation monitor in inoperable, a frequensy of 4 hours assomplishes the same goal. The spesified Frequensy takes into assount other rod position information that is sontinuously available to the operator in the sontrol room , so that during astual rod motion , deviations san immediately be detested . SR 3.1.4.2 Verifying each control rod is OPERABLE would require that each rod be tripped . However, in MODES 1 and 2, tripping each control rod would result in radial or axial power tilts, or oscillations. Exercising each individual control rod every 92 days provides increased confidence that all rods continue to be OPERABLE without exceeding the alignment limit, even if they are not regularly tripped. Moving each control rod by 1O steps will not cause radial or axial power tilts, or oscillations , to occur. ~ The 92 day Frequensy takes into consideration other information ~- ..... - - ~ available to the operator in the control room and SR 3.1.4 .1, which is !INSERT 3 j performed more frequently and adds to the determination of OPERABILITY of the rods. Between required performances of SR 3.1.4.2 (determination of control rod OPERABILITY by movement), if a control rod(s) is discovered to be immovable by the normal CROM , but remains trippable, the control rod(s) is considered to be OPERABLE. At any time, if a control rod(s) is immovable by the normal CROM , a determination of the trippability (OPERABILITY) of the control rod(s) must be made, and appropriate action taken. (continued) HBRSEP Unit No. 2 B 3.1-28 Revision No. G
!no changes on this page I Shutdown Bank Insertion Limits B 3.1.5 BASES APPLICABILITY move, and requires the shutdown bank to move below the LCO (continued) limits, which would normally violate the LCO .
ACTIONS A.1 .1, A.1 .2 and A.2 When one or both shutdown banks is not within insertion limits, 2 hours is allowed to restore the shutdown banks to within the insertion limits. This is necessary because the available SOM may be significantly reduced , with one or more of the shutdown banks not within their insertion limits. Also , verification of SOM or initiation of boration within 1 hour is required , since the SOM *in MODES 1 and 2 is ensured by adhering to the control and shutdown bank insertion limits (see LCO 3.1.1 ). If shutdown banks are not within their insertion limits, then SOM will be verified by performing a reactivity balance calculation , considering the effects listed in the BASES for SR 3.1.1.1. The allowed Completion Time of 2 hours provides an acceptable time for evaluating and repairing minor problems without allowing the plant to remain in an unacceptable condition for an extended period of time. If the shutdown banks cannot be restored to within their insertion limits within 2 hours, the unit must be brought to a MODE where the LCO is not applicable. The allowed Completion Time of 6 hours.is reasonable , based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.1.5.1 REQUIREMENTS Verification that the shutdown banks are within their insertion limits prior to an approach to criticality ensures that when the reactor is critical , or being taken critical , the shutdown banks will be available to shut down the reactor, and the required SOM will be maintained following a reactor trip. This SR and Frequency ensure that the (continued) HBRSEP Unit No. 2 B 3.1-33 Revision No. O
Shutdown Bank Insertion Limits B 3.1.5 BASES in accordance SURVEILLANCES SR 3.1 .5.1 (continued) REQUIREMENTS with the Surveillance shutdown banks are withdrawn before the control banks are withd Frequency Control during a unit startup. Program Since the shutdown banks are positioned manually by the control room operator, a verification of shutdown bank position at a Frequency ef 12 hours, after the reactor is taken critical , is adequate to ensure that they are within their insertion limits. Also , the 12 hour rrequensy takes into assount other information available in the sontrol room for the purpose of monitoring the status of shutdown rods. ~ N_S..._ER_T_3--,I 1,--1 REFERENCES 1. UFSAR, Section 3.1.
- 2. 10 CFR 50.46 .
- 3. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.1-34 Revision No. G
Control Bank Insertion Limits B 3.1.6 BASES SURVEILLANCE SR 3.1 .6.1 (continued) REQUIREMENTS criticality could be an unnecessary burden . There are a number of unit parameters requiring operator attention at that point. Performing the ECP calculation within 4 hours prior to criticality avoids a large error from changes in xenon concentration , but allows the operator some flexibility to schedule the ECP calculation with other startup activities. SR 3.1.6.2 With an OPERABLE bank insertion limit monitor, verification of the control bank insertion limits at a rrequenoy of 12 hours is sufficient to ensure OPERABILITY of the bank insertion limit monitor and to detest control banks that may be approaching the insertion limits since, IINSERT 3 I normally, very little rod motion ooours in 12 hoursWlf the insertion limit monitor becomes inoperable, verification of the control bank position at a Frequency is sufficient to detect control banks that may be in accordance approaching th insertion limits. with the Surveillance Frequency Control SR 3.1.6.3 Program When control banks are maintained within their insertion limits as checked by SR 3.1.6.2 above, it is unlikely that their sequence and overlap will not be in accordance with requirements provided in the COLR. A Frequency of 12 hours is consistent with the insertion limit check above in SR 3.1.6.2. REFERENCES 1. UFSAR, Sections 3.1 .2.14, 3.1.2.27, 3.1.2.28, 3.1.2.29, 3.1.2.30 , 3.1.2.31 , and 3.1.2.32 .
- 2. 10 CFR 50.46 .
- 3. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.1-40 Revision No. G
PHYSICS TESTS Exceptions - MODE 2 B 3.1.8 BASES ACTIONS (continued) When the RCS lowest Tavg is< 530°F , the appropriate action is to restore T avg to within its specified limit. The allowed Completion Time of 15 minutes provides time for restoring Tavg to within limits without allowing the plant to remain in an unacceptable condition for an extended period of time. Operation with the reactor critical and with temperature below 530EF could violate the assumptions for accidents analyzed in the safety analyses. D.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within an additional 15 minutes. The Completion Time of 15 additional minutes is reasonable, based on operating experience, for reaching MODE 3 in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.1 .8.1 REQUIREMENTS The power range and intermediate range neutron detectors must be verified to by OPERABLE in MODE 2 by LCO 3.3.1, "Reactor Protection System (RPS) Instrumentation." A CHANNEL OPERATIONAL TEST is performed on each power range and intermediate range channel within 7 days prior to initiation of the PHYSICS TESTS . This will ensure that the RPS is properly aligned to provide the required degree of core protection during the performance of PHYSICS TESTS . The 7 day time limit is sufficient to ensure that the instrumentation is OPERABLE before initiating PHYSICS TESTS . SR 3.1.8.2 Verification that the RCS lowest loop T avg is 2: 530°F will ensure that the unit is not operating in a condition that could invalidate the safety analyses. Verification of the RCS temperature at a Frequency of ao minutes during the (continued) HBRSEP Unit No. 2 B 3.1-55 Revision No. Q
PHYSICS TESTS Exceptions - MODE 2 B 3.1.8 BASES SURVEILLANCE SR 3.1.8.2 (continued) REQUIREMENTS performance of the PHYSICS TESTS will ensure that the initial conditions of tRe *-Y aAalyses are Rot violaled .ll~ERT I 3 SR 3.1 .8.3 Verification that the THERMAL POWER is :5 5% RTP will ensure that the plant is not operating in a condition that could invalidate the safety analyses. Verification of THERMAL POWER at a frequency of 30 minutes during the performance of the PHYSICS TEST will ensure
\ .
that the initial conditions of the safety analyses are not violated . ~
, INSERT 3 SR 3.1.8.4 The SOM is verified by performing a reactivity balance calculation ,
considering the following reactivity effects:
- a. RCS boron concentration ;
- b. Control bank position ;
- c. RCS average temperature;
- d.
- Fuel burnup based on gross thermal energy generation;
- e. Xenon concentration ;
- f. Samarium concentration ; and
- g. Isothermal temperature coefficient (ITC) .
Using the ITC accounts for Doppler reactivity in this calculation because the reactor is subcritical , and the fuel temperature will be changing at the same rate as the RCS. The Frequency of 24 hours is based on the generally slow change in required boron concentration and on the low probability of an accident oGG*rriA~ witRo*t tRe re~*ired SOM. li~ERT I 3 ( continued) HBRSEP Unit No. 2 B 3.1-56 Revision No. 0
F0 (Z) B 3.2.1 BASES SURVEILLANCE last verified to be within specified limits. Because Fb (Z) REQUIREMENTS could not have previously been measured in this reload core, (continued) there is a second Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP . This ensures that some determination of Fb (Z) is made at a lower power level at which adequate margin is available before going to 100% RTP. Also, this Frequency condition , together with the Frequency condition requiring verification of Fb (Z) following a power increase of more than 10%, ensures that they are verified as soon as RTP (or any other level for extended operation) is achieved . In the absence of these frequency conditions, it is possible to increase power to RTP and operate for 31 days without verification o f ~ ~ The Frequency condition is not intended to require verification of these parameters after every 10% increase in power level above the last verification . It only requires verification after a power level is achieved for extended operation that is 10% higher than that power at which F O was last measured. SR 3.2.1.1 The nuclear design process includes calculations performed to determine that the core can be operated within the F 0 (Z) limits. Because flux maps are taken in steady state conditions, the variations in power distribution resulting from normal operational maneuvers are not present in the flux map data. These variations are, however, conservatively calculated by considering a wide range of unit maneuvers in normal operation . The maximum peaking factor increase over steady state values, calculated as a function of core elevation , Z, is called V(Z). Multiplying the measured total peaking factor, Fg (Z) , by V(Z) gives the maximum F 0 (Z) calculated to occur in normal operation , Fb (Z) . The limit with which Fb (Z) is compared varies inversely with power and directly with the function K(Z) provided in the COLR. The V(Z) curve is provided in the COLR for discrete core elevations. Flux map data are typically taken for 30 to 75 core elevations. Fb (Z) evaluations are not applicable for the following axial core regions , measured in percent of core height: (continued) HBRSEP Unit No. 2 B 3.2-7 Revision No. Q
F0 (Z) B 3.2.1 BASES SURVEILLANCE SR 3.2.1.1 (continued) REQUIREMENTS
- a. Lower core region , from O to 10% inclusive; and
- b. Upper core region , from 90 to 100% inclusive.
The top and bottom 10% of the core are excluded from the evaluation because of the low probability that these regions would be more limiting in the safety analyses and because of the difficulty of making a precise measurement in these regions. Performing the Surveillance in MODE 1 prior to exceeding 75% RTP ensures that the F 0 (Z) limit is met when RTP is achieved , because peaking factors are generally decreased as power level is increased. F 0 (Z) is verified at power levels ~ 10% RTP above the THERMAL POWER of its last verification , 12 hours after achieving equilibrium conditions to ensure that F 0 (Z) is within its limit at higher power levels. The Surveillance rrequenoy of 31 ErPD is adequate to monitor the change of power distribution with sore burnup. The Surveillance may be done more frequently if required by the results of F 0 (Z) evaluations. T he r requenoy of 31 ErPD is adequate to monitor the change of power distribution because such a change is sufficiently slow, when the plant is operated in accordance with the TS , to preclude adverse peaking factors Oetweea 31 <lay """"'illaRGe&. ~Z';iERT I
- 3 REFERENCES 1. 10 CFR 50.46 , 1974.
- 2. UFSAR Section 4.4.2.1.
- 3. UFSAR Section 15.4.8.
- 4. UFSAR Section 3.1.
HBRSEP Unit No. 2 B 3.2-8 Revision No. G
F~H 8 3.2.2 BASES SURVEILLANCE SR 3.2.2.1 (continued) REQUIREMENTS reduction computer program then calculates the maximum value of F~ H from the measured flux distributions. The measured value of F~ H must be multiplied by 1.04 to account for measurement uncertainty before making comparisons to the F~ H limit. This Surveillance is modified by a Note that may require that the evaluation of F~ (Z) against its limits be performed with a penalty factor or that more frequent surveillances be performed . If F~ H is within limits and measurements indicate that F~ H is increasing with exposure, then F~ (Z) is increased by a factor of 1.02 , and F~ (Z) is then reverified to be within limits: or, SR 3.2.1.1 and SR 3.2.3.3 are ferformed once per 7 EFPDs until two successive measurements of Fti H show that F~ H is not increasing . These alternative requirements prevent F~ (Z) from exceeding its limit for any significant period of time during the surveillance interval. After each refueling , F~ H must be determined in MODE 1 prior to exceeding 75% RTP . This requirement ensures that F~ H limits are met at the beginning of each fuel cycle. The 31 Ef PD frequency is acceptable because the power distribution changes relatively slowly over this amount of fuel burnup . Accordingly, this frequency is short enough that the FiA-l-1 limit cannot be mmeeded for any significant period of operation . REFERENCES 1. UFSAR Section 4.4.2.1. INSERT 3
- 2. UFSAR Section 15.4.8.
- 3. UFSAR Section 3.1.
- 4. 10 CFR 50.46.
HBRSEP Unit No. 2 8 3.2-16 Revision No. G
AFD B 3.2.3 BASES ACTIONS D.1 (continued) Reducing the power level to < 15% RTP within the Completion Time of 9 hour$ and complying with LCO penalty deviation time requirements for subsequent increases in THERMAL POWER ensure that acceptable xenon conditions are restored . This Required Action must also be implemented either if the cumulative penalty deviation time is > 1 hour during the previous 24 hours, or the AFD is not within the target band and not within the acceptable operation limits. Condition Dis modified by a Note that requires Action D.1 be completed whenever this Condition is entered . SURVEILLANCE SR 3.2.3.1 REQUIREMENTS The AFD is monitored on an automatic basis using the unit process computer that has an AFD monitor alarm . The computer determines the 1 minute average of each of the OPERABLE excore detector outputs and
- provides an alarm message immediately if the AFDs for two or more OPERABLE excore channels are outside the target band and the THERMAL POWER is > 90% RTP or 0.9 APL, whichever is less. During operation at THERMAL POWER levels < 90% RTP or 0.9 APL,
- whi chever is less but > 15% RTP, the computer sends an alarm message when the cumulative penalty deviation time is > 1 hour in the previous 24 hours.
This Surveillance verifies that the AFD as indicated by the NIS excore channels is within the target band and consistent with the status of the AFD monitor alarm . The Surveillance r"requency of 7 days is adequate because the ArD is controlled by the operator and monitored by the process computer. rurthermore, any deviations of the ArD from the ta,get baA8 that is Rot ala"'1e8 sho"l8 Be ,ea8ily Aolise8 . ~ERT I 3 SR 3.2.3.2 With the AFD monitor alarm inoperable, the AFD is monitored to detect operation outside of the target band and to compute the penalty deviation time. During operation at~ 90% RTP or 0.9 APL, whichever is less, the AFDis (continued) HBRSEP Unit No. 2 B 3.2-23 Revision No. G
AFD B 3.2.3 BASES SURVEILLANCE SR 3.2.3.2 (continued) REQUIREMENTS monitored at a Surveillance Frequency of 15 minutes to ensure that the AFD is within its limits at high THERMAL POWER levels. At power levels
< 90% RTP or 0.9 APL, whichever is less, but> 15% RTP , the Surveillance Frequency is reduced to. 1 hour because the AFD may deviate from the target band for up to 1 hour using the methodology of Parts B and C of this LCO to calculate the cumulative penalty deviation time before corrective action is required .
SR 3.2.3.2 is modified by a Note that states that monitored and logged values of the AFD are assumed to exist for the preceding 24 hour interval in order for the operator to compute the cumulative penalty deviation time. The AFD should be monitored and logged more frequently in periods of operation for which the power level or control bank positions are changing to allow corrective measures when the AFD is more likely to move outside the target band. SR 3.2.3.3 Measurement of the target flux difference is accomplished by taking a flux map when the core is at equilibrium xenon conditions, preferably at high power levels with the control banks nearly withdrawn . This flux map provides the equilibrium xenon axial power distribution from which the target value can be determined . The target flux difference varies slowly with core burnup. A Frequency of 31 EFPD after each refueling and 31 EFPD thereafter for feffieasuring the target flux differences adjusts the target flux difference for each excore channel to the value measured at steady state
~
-~
A Note modifies this SR to allow the predicted beginning of cycle AFD from the cycle nuclear design to be used to determine the initial target flux difference after each refueling . A second Note modifies this SR to require that the target flux difference be determined in conjunction with the measurement of the heat flux hot channel factor, F 0 (Z), in accordance with SR 3.2.1.1. This is a requirement of the PDC-3 Axial Offset Control Methodology. (continued) HBRSEP Unit No. 2 B 3.2-24 Revision No. e
QPTR B 3.2.4 BASES SURVEILLANCE SR 3.2.4.1 (continued) REQUIREMENTS performance of SR 3.2.4.2 in lieu of SR 3.2.4.1. This Surveillance verifies that the QPTR, as indicated by the Nuclear Instrumentation System (NIS) excore channels or Emergency Response Facility Information System (ERFIS) , is within its limits. The Frequency of 7 days when the QPTR alarm is OPERABLE is acceptable because of the low probability that this alarm can remain inoperable without detection. ~ VI/hen the QPTR alarm is inoperable, the Frequenoy is inoreased to 12 hours. This Frequency is adequate to detect any relatively slow changes in QPTR , because for those causes of QPT that occur quickly (e.g., a dropped rod), there typically are other indications of abnormality that prompt a verification of core po11.ier tilt. SR 3.2.4.2 This Surveillance is modified by a Note, which states that it is not
.. ,. required until 12 hours after the input from one or niore Power Range Neutron Flux channels are inoperable and the* THERMAL POWER is
~ 75% RTP .
With an NIS power range channel inoperable, tilt monitoring for a portion of the reactor core becomes degraded . Large tilts are likely detected with the remaining channels, but the capability for detection of small power tilts in some quadrants is decreased . Performing SR 3.2.4 .2 at a Frequency of 12 hours provides an accurate alternative means for ensuring that any tilt remains wit.hin its limits. ~SERT ! 3 For purposes of monitoring the QPTR when one power range channel is inoperable, the moveable incore detectors are used to confirm that the normalized symmetric power distribution is consistent with the indicated QPTR and any previous data indicating a tilt. The symmetric thimble flux map can be used to generate symmetric thimble "tilt." This can be compared to a reference symmetric thimble tilt, from the most recent full (continued) HBRSEP Unit No. 2 B 3.2-32 Revision No. G
RPS Instrumentation B 3.3 .1 BASES SR 3.3.1.1 Performance of the CHANNEL CHECK once every 12 hours ensures that gross failure of instrumentation has not occurred . A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure ; thus, it is key to verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION . Deviation criteria are determined by the unit staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria , it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal , but more frequent, checks of channels during normal operational use of tRo Ois~lays assooiatOO witR tRe LGO req"ireO oRaaaols. ~ERT I 3 SR 3.3.1.2 SR 3.3.1.2 compares the calorimetric heat balance calculation to the NIS channel output every 24 hours. If the calorimetric exceeds the NIS channel output by> 2% RTP , the NIS is not declared inoperable, but must be adjusted . If the NIS channel output cannot be properly adjusted, the channel is declared inoperable. Two Notes modify SR 3.3.1 .2. The first Note indicates that the NIS channel output shall be adjusted consistent with the calorimetric results if the absolute difference between the NIS channel output and the calorimetric is > 2% RTP. The second Note clarifies that this Surveillance is required only if reactor power is;:: 15% RTP and that 12 (continued) HBRSEP Unit No. 2 B 3.3-47 Revision No. G;-4-e Amendment No. 4QG
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1 .2 (continued) REQUIREMENTS hours are allowed for performing the first Surveillance after reaching 15% RTP . At lower power levels, calorimetric data are inaccurate. The Frequency of every 24 hours is adequate. It is based on unit operating experience, considering instrument reliability and operating history data for instrument drift. Together these factors demonstrate the change in the absolute difference bet\*;een NIS and heat balance calculated powers rarely exceeds 2% in any 24 hour period . In addition , control room operators periodically monitor redundant indications and alarFRs to Eietest Eieviations in shannel o"tP"ts. ):SERT I 3 SR 3.3.1.3 SR 3.3.1 .3 compares the incore system to the NIS channel output ev-ery
. 31 EFPD. If the absolute difference is~ 3% , the NIS channel is still OPERABLE, but must be readjusted.
If the NIS channel cannot be properly readjusted, the channel is declared inoperable. This Surveillance is performed to verify the f(Lll) input to the overtemperature and overpower Ll T Functions. Two Notes modify SR 3.3.1.3. Note 1 indicates that the excore NIS channel shall be adjusted if the absolute difference between the incore and excore AFD is ~ 3%. Note 2 clarifies that the Surveillance is required only if reactor power is ~ 15% RTP and that 36 hours is allowed for performing the first Surveillance after reaching 15% RTP. The Frequency of every 31 EFPD is adequate. It is based on industry operating experience, considering instrument reliability and operating history data for instrument drift. Also , the slow changes in neutron flux during the fuel cycle can be detected during this interval ' - ....~ - - - , (@ERT3! (continued) HBRSEP Unit No. 2 B 3.3-48 Revision No. ~ Amendment No. 1QO
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1.4 REQUIREMENTS (continued) SR 3.3.1.4 is the performance of a TADOT every 31 days on a STAGGERED TEST BASIS . This test shall verify OPERABILITY by actuation of the end devices. The RTB test shall include separate verification of the undervoltage and shunt trip mechanisms. Independent verification of RTB undervoltage and shunt trip Function is not required for the bypass breakers. No capability is provided for performing such a test at power. The independent test for bypass breakers is included in SR 3.3.1.14. The bypass breaker test shall include a local shunt trip. A Note has been added to indicate that this test must be performed on the bypass breaker prior to placing it in service. The Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based on industry operating experience, considering iRslrumeRI ,eliability aREI operatiRg history Elala . @SERT I 3 SR 3.3.1.5 SR 3.3.1 .5 is the performance of an ACTUATION LOGIC TEST. The RPS is tested every 31 days on a STAGGERED TEST BASIS. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation . All possible logic combinations, with and without applicable permissives, are tested for each protection function . The Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based on industry operating experience, considering instrument reliability arid operating history data. ~ INSERT ! 3 A note is added to SR 3.3.1.5 stating that the SR is not requ ired to be performed for the source range neutron flux detector channels prior to entry into MODE 3 from MODE 2 until 4 hours after entry into MODE 3. This Note allows normal shutdown to proceed without delay for testing in MODE 2 and in MODE 3 until the RTBs are open and SR 3.3.1.5 is no longer required to be performed (i.e., the 4 hour delay allows a normal shutdown to be completed without a required hold on power reduction to perform the testing required by this SR) . If the unit is in MODE 3 with the RTBs closed for greater than 4 hours, this SR must be performed prior to 4 hours after entry into MODE 3. (continued) HBRSEP Unit No. 2 B 3.3-49 Revision No. G;-4e Amendment No. 49G
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1.6 REQUIREMENTS (continued) SR 3.3.1.6 is a calibration of the excore channels to the incore channels. If the measurements do not agree, the excore channels are not declared inoperable but must be calibrated to agree with the incore detector measurements. If the excore channels cannot be adjusted , the channels are declared inoperable. This Surveillance is performed to verify the f(lil) input to the overtemperature and overpower li T Functions. A Note modifies SR 3.3.1.6. The Note states that this Surveillance is required only if reactor power is> 50% RTP and that 24 hours is allowed for performing the first surveillance after reaching 50% RTP . The F"requency of Q2 EF"PD is adequate. It is based on industry operating experience, considering instrument reliability and operating history 8ata !or iastr"meat 8rill. [wsERT I 3 SR 3.3.1.7 SR 3.3.1.7 is the performance of a COT every Q2 days. A COT is performed on each requ ired channel to ensure the entire channel will perform the intended Function . Setpoints must be within the Allowable Values specified in Table 3.3.1-1. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 8) . The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology (Ref. 8) . The "as found" and "as left" values must also be recorded and reviewed for consistency with the assumptions of Reference 7. SR 3.3.1.7 is modified by a Note that provides a 4 hour delay in the requirement to perform this Surveillance for source range instrumentation when entering MODE 3 from MODE 2. This Note allows a normal shutdown to proceed without ( continued) HBRSEP Unit No. 2 B 3.3-50 Revision No. O
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1.7 (continued) REQUIREMENTS a delay for testing in MODE 2 and for a short time in MODE 3 until the RTBs are open and SR 3.3.1.7 is no longer required to be performed (i.e. , the 4 hour delay allows a normal shutdown to be completed without a required hold on power reduction to perform the testing required by this SR) . In addition , performing the COT of the source range instrumentation prior to entry into MODE 3 from MODE 2 may increase the probability of a reactor trip . If the unit is to be in MODE 3 with the RTBs closed for > 4 hours this Surveillance must be performed prior to 4 hours after entry into MODE 3. The FroqYCRG!f el 92 days is j Ystified ia Referoase ~;N~ ERT I 3 SR 3.3.1.8 SR 3.3.1.8 is the performance of a COT as described in SR 3.3.1.7, except it is modified by a Note that this test shall include verification that the P-6 and P-10 interlocks are in their required state for the existing unit condition . The Frequency is modified by a Note that allows this surveillance to be satisfied if it has been performed with* 92 days of the frequencies prior to reactor startup a s after reducing power the Frequency specified in below P-10 and P- uency of "prior to startup" ensures this the Surveillance _s.uni:e!H1!n1~1s performed prior to critical operations and applies to the Frequency Control source, intermediate and power range low instrument channels. The Program Frequency of "4 hours after reducing power below P-10" (applicable to intermediate and power range low channels) and "4 hours after reducing power below P-6" (applicable to source range channels) allows a normal shutdown to be completed and the unit removed from the MODE of Applicability for this surveillance without a delay to perform the testing required by this surveillance. The Frequency of every 92 days thereafter applies if the plant remains in the MODE of Applicability after the initial performances of prior to reactor startup and four hours after reducing power below P-10 or P-6. The MODE of Applicability for this surveillance is < P-10 for the power range low and intermediate range channels and < P-6 for the source range channels. Once the unit is in MODE 3, this surveillance is no longer required . If power is to be maintained < P-10 or < P-6 for more than 4 hours, then the (continued) HBRSEP Unit No. 2 B 3.3-51 Revision No. G
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3 .1.8 (continued) REQUIREMENTS testing required by this surveillance must be performed prior to the expiration of the 4 hour limit. Four hours is a reasonable time to complete the requ ired testing or place the unit in a MODE where this surveillance is no longer required . This test ensures that the NIS source, intermediate, and power range low channels are OPERABLE prior to taking the reactor critical and after reducing power into the applicable MODE(< P-10 or< P-6) for periods> 4 hours. '
~pN....,_S_E-RT~3I SR 3.3.1 .9 SR 3.3.1.9 is the performance of a TADOT an is performed every 92 days, as justified in Reference 7.
The SR is modified by a Note that excludes verification of setpoints from the TADOT . Since this SR applies to RCP undervoltage and underfrequency relays , setpoint verification requires elaborate bench calibration and is accomplished during the CHANNEL CALIBRATION . SR 3.3.1.10
/\ CHANNEL C/\LIBR/\TION is performed every 18 months, or approximately at every refueling . CHANNEL CALIBRATION is a complete check of the instrument loop , including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology (Ref. 8). The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 8) . The Frequency of 18 months is based on the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology (Ref. 8) . ,,........__*_ __,
@SERT 3!
(continued) HBRSEP Unit No. 2 B 3.3-52 Revision No. G
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3 .1.10 (continued) REQUIREMENTS SR 3.3.1 .10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. This Note applies to those Functions equipped with electronic dynamic compensation . Not all Functions to which SR 3.3.1.10 is applicable are equipped with electronic dynamic compensation. SR 3.3.1.11 SR 3.3.1.11 is the performance of a CHANNEL CALIBRATION , as described in SR 3.3.1.10, every 18 months. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION . The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux map performed above 15% RTP . The CHANNEL CALIBRATION for the source range and intermediate range neutron detectors consists of obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors. +Re 48-month F"requency is based on industry operating experience, considering instrument reliabi lity and operating history data. Operating experience has shown these components usually pass the Surveillance whoa ~ell<m.,ed oa the 16 moath F,eqyeasy. @SERT ] 3 SR 3 .3.1.12 SR 3.3.1 .12 is the performance of a CHANNEL CALIBRATION , as described in SR 3.3.1.10, every 18 months. For Table 3.3.1-1 Functions 5 and 6, the CHANNEL CALIBRATION shall include a narrow range RTD cross calibration . This SR is modified by a Note stating that this test shall include verification of the electronic dynamic compensation time constants and the RTD response time constants. The RCS (continued) HBRSEP Unit No. 2 B 3.3-53 Revision No. Q
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1.12 (continued) REQUIREMENTS narrow range temperature sensors response time shall be :5 a 4.0 second
- lag time constant.
The Frequency is justified by the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. rr§s:ERT ! 3 SR 3.3.1 .13 SR 3.3.1.13 is the performance of a COT of RPS interlocks evep;- 18 months. The Frequency is based on the known reliability of the interlocks and the multichannel redundancy available, and has been shown to be aGGeplable IAraugA aperaling e*periensejl~ERT I 3 SR 3.3.1.14 SR 3.3.1.14 is the performance of a TADOT of the Manual Reactor Trip , RCP Breaker Position , and the SI Input from ESFAS and the P-7 interlock. This TADOT is performed every 18 months. The test shall independently verify the OPERABILITY of the undervoltage and shunt trip mechanisms for the Manual Reactor Trip Function for the Reactor Trip Breakers and the undervoltage trip mechanism for the Reactor Trip Bypass Breakers. The test shall also independently verify the OPERABILITY of the low power reactor trip block from the Power Range Neutron Flux (P-10) interlock and turbine first stage pressure. The TADOT verifies that when either the Turbine Impulse Pressure inputs or the Power Range Neutron Flux (P-10) interlock engage, reactor trips that are blocked by P-7 are enabled . The Frequency is based on the known reliability of the Functions and the multichannel redundancy available, and has been shown to be asooplabla lAraugA aparaling e*periense. ~SERT I 3 (continued) HBRSEP Unit No. 2 B 3.3-54 Revision No. 0
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE A Note (Note 1) has been added to the SR Table to clarify REQUIREMENTS that Table 3.3.2-1 determines which SRs apply to which ESFAS (continued) Functions. Note that each channel of process protection supplies both trains of the ESFAS. When testing channel I, train A and train B must be examined . Similarly, train A and train B must be examined when testing channel II , channel Ill , and channel IV (if applicable) . The CHANNEL CALIBRATION and COTS are performed in a manner that is consistent with the assumptions used in analytically catculating the required channel accuracies. The Surveillances are also modified by Note 2 to indicate that when a channel is placed in an inoperable status solely for the performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours provided the redundant ESFAS train is OPERABLE. Upon completion of the Surveillance or expiration of the 6 hour allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and the Required Actions performed . If maintenance is to be subsequently performed as a result of a failed surveillance test, LCO 3.3,2 ACTIONS are applicable. Note 2 to the Surveillance Requirements is based on operating history which has shown that.6 hours is generally the time .required to perform the channel surveillance with additional time to allow for short term plant changes or verification of any abnormal responses. This 6 hour testing allowance does not significantly reduce the probability that the ESFAS will initiate when necessary. SR 3.3.2.1 Performance of the CHANNEL CHECK once every 12 hours ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure: thus, it is key to verifying the (continued) HBRSEP Unit No. 2 B 3.3-86 Revision No. G
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR 3.3.2.1 (continued) REQUIREMENTS instrumentation continues to operate properly between each CHANNEL CALIBRATION. Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and reliability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. The rrequency is based on operating experience that demonstrates channel failure is rare. The CHAN~JEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of
!Re <l isplays assasiale<l .wilR tRe LGO "'~"ire<I sRaRRels. IT[SERT j 3
SR 3.3.2.2 SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST. TRe ESr relay logic is tested every 31 days on a STAGGERED TEST BASIS. The train being tested is placed in the test condition. All possible logic combinations , with and without applicable permissives, are tested for each protection function. In addition, *the master relay coil is tested for continuity. This verifies that the logic modules are OPERABLE and that there is an intact voltage signal path to the master relay coils. TRe Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based on industry operating experience, eonsidering iRslr""'""I reliability aR<i aperatiR~ Rista,y <lata. ~ERT j 3 SR 3.3.2.3 SR 3.3.2.3 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay. The master relay is actuated by either a manual or automatic initiation of the function being tested. Contact operation is verified either by a continuity check of the circuit containing the master relay or proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 18 months. The 18 month rrequency is adequate, based on (continued) HBRSEP Unit No. 2 B 3.3-87 Revision No. O
ESFAS Instrumentation B 3 .3.2 BASES SURVEILLANCE SR 3.3.2 .3 (continued) REQUIREMENTS industry operating experience, and is consistent with the typical refueling Gl'*le, wAisA provi8es tAe plaat saa8itiaas aesessary far testiag . lSERT I 3 SR 3 .3.2.4 SR 3 .3.2.4 is the performance of a COT. A COT is performed on each required channel to ensure the entire channel , with the exception of the transmitter sensing device, will perform the intended Function. Setpoints must be found within the Allowable Values specified in Table 3 .3.2- 1. The difference between the current "as found " values and the previous test "as left" va lues must be consistent with the drift allowance used in the setpoint methodology (Ref. 9). The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology (Ref. 9) .
- The "as found" and "as left" values must also be recorded and reviewed for consistency with the assumptions of the surveillance interval extension analysis in WCAP- 10271-P-A (Ref. 8) when applicable.
TAe Fre~ueRG\' al 92 day& isjustifie8 iR Refereaoo \ ~ERT l 3 SR 3.3.2.5 SR 3 .3.2.5 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays . Contact operation is verified either by a continuity check of the circuit containing the slave relay, or by verification of proper operation of the end device during supported equipment simulated or actual automatic actuation test. +rus test is performed every 18 months. The 18 month rrequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary far testiag. ~SERT 31 (continued) HBRSEP Unit No. 2 B 3.3-88 Revision No. G
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR 3.3.2 .6 REQUIREMENTS (continued) SR 3.3.2.6 is the performance of a TADOT. This test is a check of Manual Actuation Functions. It is performed ei.*ery 18 months. Each Manual Actuation Function is tested up to, and including, the master relay coils. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.). The Frequency is adequate, based on industry operating experience and is consistent with the typical refueling cycle. ~ The SR is modified by a Note that excludes verification of setpoints during ~ the TADOT for manual initiation Functions. The manual initiation Functions have no associated setpoints. SR 3.3.2.7 SR 3.3.2.7 is the performance of a CHANNEL CALIBRATION . A CHANNEL CALIBRATION is performed every 18 months, or approximately at e11ery refueling . CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy. CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology (Ref. 9). The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The Frequency of 18 months is based on the assumption of an 18 month' oalibration interval in the determination of the magnitude of equipment Elrill iA !Re set~eiat metAeElelegy. v@s INSERT 3! REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 7.
- 3. UFSAR, Chapter 15.
- 4.
- UFSAR, Section 3.1.
(continued) HBRSEP Unit No. 2 B 3.3-89 Revision No. G
PAM Instrumentation B 3.3.3 BASES ACTIONS (continued) Condition H applies to the Containment Sump Water Level , Containment Pressure , Containment Area Radiation , Auxiliary Feedwater Flow, PORV Position , PORV Block Valve Position , and Safety Valve Position Functions, which have alternate monitoring means available for use. These alternate means may be temporarily installed if the normal PAM channel cannot be restored to OPERABLE status within the allotted time. If these alternate means are used , the Required Action is not to shut down the unit but rather to follow the directions of Specification 5.6.6, in the Administrative Controls section of the TS. The report provided to the NRC should discuss the alternate means used, describe the degree to which the alternate means are equivalent to the installed PAM channels, justify the areas in which they are not equivalent, and provide a schedule for restoring the normal PAM channels . SURVEILLANCE A Note has been added to the SR Table to clarify that REQUIREMENTS SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1 ; except Function 9, Containment Isolation Valve Position; Function 22, PORV Position (Primary); Function 23, PORV Block Valve Position (Primary) ; and Function 24, Safety Valve Position (Primary) . SR 3.3.3.3 applies only to Functions 9, 22 , 23, and 24. SR 3.3.3.1 Performance of the CHANNEL CHECK once every 31 days ensures that a gross instrumentation failure has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure ; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. The high radiation instrumentation (continued) HBRSEP Unit No. 2 B 3.3-106 Revision No. ~
PAM Instrumentation B 3.3.3 BASES SURVEILLANCE SR 3.3.3.1 (continued) REQUIREMENTS should be compared to similar unit instruments located throughout the unit. Channel deviation criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria , it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria , it is an indication that the channels are OPERABLE. As specified in the SR, a CHANNEL CHECK is only required for those channels that are normally energized . The Frequency of 31 days is based on operating mcperience that demonstrates that channel failure is rare. The Cl=IAN~JEL Cl=IECK supplements less formal , but more frequent, cheeks of ohannels during normal operational use of the displays assooiated with the LCO required ohannels. r::sERT ! 3 SR 3.3.3.2 A Cl=IA~JNEL CALIBRATIO~J is performed every 1B months, or approximately at every refueling . CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by a Note that excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1 , "Reactor Protection System (RPS) Instrumentation." The Frequenoy is based on operating experienoe and soRsis!eRsy wilh lhe lypisal iRd"s!ry ref"eliR§ sysle. (!NsERT I 3 SR 3.3.3.3 SR 3.3.3.3 is the performance of a TADOT of containment isolation valve position indication , PORV position (primary) indication, PORV block valve position (primary) indication, and safety valve position (primary) indication. This TADOT is performed every 18 months. The test shall independently (continued) HBRSEP Unit No. 2 B 3.3-107 Revision No. G
PAM Instrumentation B 3.3.3 BASES SURVEILLANCE SR 3.3.3.3 (continued) REQUIREMENTS verify the OPERABILITY of position indication against the actual position of the associated valves. The r"requency is based upon the known reliability of the runctions and has been shown to be acceptable through operating m<perience. ~
. INSERT 3!
The SR is modified by a Note that excludes verification of setpoints from the TADOT. The affected Functions have no setpoints. REFERENCES 1. NRC Safety Evaluation Report, H. B. Robinson Steam Electric Plant Unit No. 2, Docket No. 50-261 , Conformance to Regulatory Guide 1.97, transmitted to CP&L by letter dated March 5, 1987.
- 2. Regulatory Guide 1.97 , Revision 3, May 1983.
- 3. NUREG-0737 , Supplement 1, "TMI Action Items."
- 4. CP&L Letter to NRC , "Inadequate Core Cooling Instrumentation, Generic Letter 82-28 , NUREG-0737, Item 11.F.2, Implementation Letter/License Amendment Request," dated September 16, 1987.
- 5. CP&L letters dated December 31 , 1984, July 18, 1985, July 28, 1985, May 1, 1987, September 9, 1987, and September 14, 1999, regarding the HBRSEP Regulatory Guide 1.97 submittal.
HBRSEP Unit No. 2 B3.3-108 Revision No. ~
Remote Shutdown System B 3.3.4 BASES ACTIONS B.1 and B.2 (continued) If the Required Action and associated Completion Time of Condition A is not met, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status , the unit must be brought to at least MODE 3 within 6 hours and to MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.3.4.1 REQUIREMENTS Performance of the CHANNEL CHECK once every 31 days ensures that a gross failure of instrumentation has not occurred . A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION . Channel deviation criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If the channels are within the criteria, it is an indication that the channels are OPERABLE. If a channel is outside the criteria , it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. As specified in the Surveillance, a CHANNEL CHECK is only required for those channels which are normally energized. The i;requency of 31 days is based upon operating experience which demonstrates that channel fai lure is rare. The CHA~JNEL CHECK supplements less formal , but more frequent , checks of channels during normal operational use of the displays assosialeEI witR !Re LGO reqYireEI sRaaaels. n@ERT I 3 (continued) HBRSEP Unit No. 2 B 3.3-112 Revision No. G
Remote Shutdown System B 3.3.4 BASES SURVEILLANCE SR 3.3.4.2 REQUIREMENTS (continued) SR 3.3.4.2 verifies each required Remote Shutdown System control circuit and transfer switch performs the intended function . This verification is performed from the remote shutdown panel and locally, as appropriate. Operation of the equipment from the remote shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the unit can be placed and maintained in MODE 3 from the remote shutdown panel and the local control stations. The 18 month rrequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. (However, this Surveillance is not requ ired to be performed only during a unit outage.) Operating e>Eperience demonstrates that remote shutdown control channels usually pass the Surveillance test when performed at the 18 month rrequency. ~ .....----'----,
~ERT3!
SR 3.3.4 .3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. The rrequency of 18 months is based upon operating e>Eperience and GGRSisleRGl' wltR tile ty~isal iml"stl)I ,eh.Jeliag Gl'*le. rsERT I 3 SR 3.3.4.4 SR 3.3.4.4 is the performance of a TADOT e*.iery 18 months. This test should verify the OPERABILITY of the reactor trip breakers (RTBs) open and closed indication on the remote shutdown panel , by actuating the RTBs. The rrequency is based upon operating e>Eperience and consistency with the typical industry refueling outage. %SERT ! 3 REFERENCES 1. UFSAR, Section 7.4.1. HBRSEP Unit No. 2 B 3.3-113 Revision No. G
LOP DG Start Instrumentation B 3.3.5 BASES ACTIONS 8.1 (continued) The specified Completion Time and time allowed for tripping one channel are reasonable considering the Function remains fully OPERABLE on every bus and the low probability of an event occurring during these intervals. Condition C applies when more than one degraded voltage channel on a single bus is inoperable.
, Required Action C.1 requires restoring all but one channel on each bus to
. OPERABLE status. The 1 hour Completion Time should allow ample time to repair most failures and takes into account the low probability of an event requiring an LOP start occurring during this interval.
D.1 Condition D applies to each of the LOP DG start Functions when the Required Action and associated Completion Time for Condition A, B, or C are not met. In these circumstances the Conditions specified in LCO 3.8.1, "AC Sources - Operating ," or LCO 3.8.2, "AC Sources - Shutdown," for the DG made inoperable by failure of the LOP DG start instrumentation are required to be entered immediately. The actions of those LCOs provide for adequate compensatory actions to assure unit safety. SURVEILLANCE SR 3.3.5.1 REQUIREMENTS SR 3.3.5.1 is the performance of a TADOT. This test is performed every 18 months. The test checks trip devices that provide actuation signals directly, bypassing the analog process control equipment. :+Re Frequency is based on the known reliability of the relays and controls and the multichannel redundancy available, and has been shown to be acceptable through operating experience. ~ ....___.~---,
~ERT3!
(continued) HBRSEP Unit No. 2 B 3.3-119 Revision No. G
LOP DG Start Instrumentation B 3.3.5 BASES SURVEILLANCE SR 3.3.5.1 (continued) REQUIREMENTS The SR is modified by a Note that excludes verification of the setpoint from the TADOT. Setpoint verification is accomplished during the CHANNEL CALIBRATION . SR 3.3.5.2 SR 3.3.5.2 is the performance of a CHANNEL CALIBRATION. The setpoints, as well as the response to a loss of voltage and a degraded voltage test, should include a single point verification that the trip occurs within the required time delay, as shown in Reference 1. A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling . CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and .accuracy. The Frequency of 18 months is based on operating experience and consistency 1.vith the typical industry refueling cycle and is justified by the assumption of an 18 month calibration interval in the determination of the "1agai!Y<le of eq"ip"1eRI dFift ia the setpeial aaalysis. lmsERT I 3 REFERENCES 1. UFSAR, Section 8.3.
- 2. Calculation RNP-E-8.002, AC Auxiliary Electrical Distribution System Voltage/Load Flow/Fault Current Study
- 3. UFSAR, Chapter 15.
- 4. EGR-NGGC-0153, Engineering Instrument Setpoints
- 5. RNP-I/INST-1010, Emergency Bus- Degraded Grid Voltage Relay HBRSEP Unit No. 2 B 3.3-120 Revision No. ae
Containment Ventilation Isolation Instrumentation B 3.3.6 BASES ACTIONS A.1 and A.2 (continued) position is met, and the applicable Conditions of LCO 3.9.3, "Containment Penetrations," are met for each valve made inoperable by failure of isolation instrumentation . The Completion Time for these Required Actions is Immediately. SURVEILLANCE A Note has been added to the SR Table to clarify that REQUIREMENTS Table 3.3.6-1 determines which SRs apply to which Containment
- Ventilation Isolation Functions.
SR 3.3.6.1 Performance of the CHANNEL CHECK once every 12 hours ensures that a gross failure of the radiation monitor instrumentation has not occurred . The Frequency is based on operating e:><perience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal , but more frequent, checks of channels during normal operational use of tAe displays assesiated ~ilA IAe LGO re~"ired sAaaaels. [Ns"ERT I 3 SR 3.3.6.2 SR 3.3.6.2 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the test condition . All possible logic combinations, with and without applicable permissives , are tested for each protection function . In addition, the master relay coil is tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils . This test is performed every 31 days on a STAGGERED TEST BASIS. The Surveillance interval is acceptable based on instrument reliability and iad"stry eperatiag e*periease. !WSERT I 3 SR 3.3.6.3 SR 3.3.6.3 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay. (continued) HBRSEP Unit No. 2 B3.3-125 Revision No. G
Containment Ventilation Isolation Instrumentation B 3.3.6 BASES SURVEILLANCE SR 3.3.6.3 (continued) REQUIREMENTS The master relay is actuated by either a manual or automatic initiation of the function being tested. Contact operation is verified either by a continuity check of the circuit containing the master relay or proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 18 months. The 18 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which
~re,i8es l~e ~laAI GOA8iliaas aesessa,y far tesliag . ~ERT I 3
SR 3.3.6.4 A COT is performed every Q2 days on each required channel to ensure the entire channel will perform the intended Function . The Frequency is based on the staff recommendation for increasing the availability of radiation monitors according to t>JUREG 1366 (Ref. 2) . his test verifies the capability of the radiation monitor instrumentation to itiate Containment Ventilation System isolation. The setpoint s uld be left consist~nt with the calibration procedure tolerance. INSERT 3 SR 3.3.6.5 SR 3.3.6.5 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified either by a continuity check of the circuit containing the slave relay, or by verification of proper operation of the end device during the supported equipment simulated or actual automatic actuation test. ms test is performed every 18 months. The 18 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing . ~ SR 3.3.6.6 SR 3.3.6 .6 is the performance of a TADOT. This test is a check of the Manual Actuation Functions and is performed (continued) HBRSEP Unit No. 2 B 3.3-126 Revision No. Q
Containment Ventilation Isolation Instrumentation B 3.3.6 BASES (continued) SURVEILLANCE SR 3.3.6.6 (continued) REQUIREMENTS every 18 months. Each Manual Actuation Function is tested up to, and including , the master relay coils. In some instances, the test includes actuation of the end device (i.e., pump starts , valve cycles, etc.). The test also includes trip devices that provide actuation signals directly to the relay logic, bypassing the analog process control equipment. The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Functions tested have no setpoints associated with them . The rrequency is based on the known reliability of the runction and the redundancy available, and has been shown to be acceptable through operating m<perience. ~ .....~ ~ - - .
~ERT3!
SR 3.3 .6.7 A CHANNEL CALIBRATIO~J is performed every 18 months, or apprm<imately at every ref1::1eling . CHANNEL CALIBRATION is a complete check of the instrument loop; including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. The rrequency is based on operating experience and is consistent with the typical industry refueling cycle. ~ SERT 3! REFERENCES 1. Deleted.
- 2. ~JU REG 1366, "I mprovements to Technical Specification Surveillance Requirements,"' December, 1992. !Deleted.
HBRSEP Unit No. 2 B 3.3-127 Revision No. ~
CREFS Actuation Instrumentation B 3.3.7 BASES ACTIONS (continued) Condition B applies to the failure of two CREFS actuation trains, or the radiation monitor channel. The Required Action is to place one CREFS train in the emergency pressurization mode of operation immediately. This accomplishes the actuation instrumentation Function that may have been lost and places the unit in a conservative mode of operation . C.1 and C.2 Condition C applies when the Required Action and associated Completion Time for Condition A or B have not been met and the unit is in MODE 1, 2, 3, or 4. The unit must be brought to a MODE in which the LCO requirements are not applicable . To achieve this status, the unit must be brought to MODE 3 within 6 hours and MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems . 0 .1 and 0.2 Condition D applies when the Required Action and associated Completion Time for Condition A or B have not been met when irradiated fuel assemblies are being moved . Movement of irradiated fuel assemblies must be suspended immediately to reduce the risk of accidents that would require CREFS actuation. SURVEI LLANCEA Note has been added to the SR Table to clarify that REQUIREMENTS Table 3.3.7-1 determines which SRs apply to which CREFS Actuation Functions. SR 3.3.7.1 Performance of the CHANNEL CHECK once every 12 hours ensures that a gross failure of radiation monitor instrumentation has not occurred . (continued) HBRSEP Unit No. 2 B 3.3-131 Revision No. ~
CREFS Actuation Instrumentation B 3.3.7 BASES SURVEILLANCE SR 3.3.7.1 (continued) REQUIREMENTS The Frequency is based on operating e*perience that deR1onstrates channel failure is rare. The CHANNEL CHECK suppleR1ents less forR1al , but Rlore frequent, checks of channels during norR1al operational use of tRe Elisplays assesiateEI witR tRe LGO requireEI sRaaaels. sERT I 3 SR 3.3.7.2 A COT is performed once e1;ery 92 days on the required radiation monitor channel to ensure the entire channel will perform the intended function . This test verifies the capability of the instrumentation to provide actuation of both CREFS trains. The setpoint should be left consistent with the unit specific calibration procedure tolerance. The Frequency is based on the known reliability of the Rlonitoring equipR1ent and has been shown to be acceptable through operating e*perience. , .....- - - - - .
. ~SERT3!
SR 3.3.7 .3 SR 3.3.7.3 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the test condition . All possible logic combinations, with and without applicable permrssives , are tested for each protection function . In addition , the master relay coil is tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils . This test is performed every 31 days on a STAGGERED TEST BASIS. The Frequency is justified in WCAP 10271 P A, SuppleR1ent 2, Rev. 1 (Ref. 1). ~.------.
~ERT3!
SR 3.3.7.4 SR 3.3.7.4 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay. The master relay is actuated by either a manual or automatic initiation of the function being tested. Contact operation is verified either by a continuity check of the circuit containing the master relay or proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is perforR1ed every 18 (continued) HBRSEP Unit No. 2 83.3-132 Revision No. G
CREFS Actuation Instrumentation B 3.3.7 BASES SURVEILLANCE SR 3.3.7.4 (continued) REQUIREMENTS months. The 18 month F"requency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing . ~
~.--~S-E-RT---,3j SR 3.3.7.5 SR 3.3.7.5 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified either by a continuity check of the circuit containing the slave relay, or by verification of proper operation of the end device during the supported equipment simulated or actual automatic actuation test. Tflis test is performed every 18 months. The 18 month F"requency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary
!er lesliag. @SERT 31 SR 3.3.7.6 A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling . CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
The F"requency is based on operating experience and is consistent with the typical industry refueling cycle. l}ffi SERT 3! REFERENCES 1. WCAP 10271 PA, Supplement 2, Rev. 1, June 1990. !Deleted . HBRSEP Unit No. 2 B 3.3-133 Revision No. Q
Auxiliary Feedwater (AFW) System Instrumentation B 3.3.8 BASES ACTIONS E.1 and E.2 (continued) an OPERABLE status. If the Function cannot be returned to an OPERABLE status, 6 hours are allowed to place the unit in MODE 3. The allowed Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit systems. In MODE 3, the unit does not have any analyzed transients or conditions that require the explicit use of the protection function noted above. The allowance of 48 hours to return the train to an OPERABLE status is justified in WCAP-10271-P-A (Ref. 3). SURVEILLANCE The SRs for each AFW Actuation Function are identified by REQUIREMENTS the SRs column of Table 3.3.8-1 . A Note has been added to the SR Table to clarify that Table 3.3.8-1 determines which SRs apply to which Functions. The CHANNEL CALIBRATION and COTs are performed in a manner that is consistent with the assumptions used in analytically calculating the required channel accuracies. SR 3.3.8.1 Performance of the CHANNEL CHECK onoe every 12 hours ensures that a gross failure of instrumentation has not occurred . A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Channel deviation criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and reliability. If a channel is outside the criteria, it may be an indication (continued) HBRSEP Unit No. 2 B 3.3-142 Revision No. G
Auxiliary Feedwater (AFW) System Instrumentation B 3.3.8 BASES SURVEILLANCE SR 3.3.8 .1 (continued) REQUIREMENTS that the sensor or the signal processing equipment has drifted outside its limit. The Frequency is based on operating experience that demonstrates channel fai lure is rare . The CHi\t>lNEL CHECK supplements less formal , but more frequent , checks of channels during normal operational use of the Sis~lays assosiatea wRh the LGO ,eqaire8 shaaaels. rws:ERT J 3 SR 3.3.8.2 SR 3.3.8.2 is the performance of a COT . A COT is performed on each required channel to ensure the entire channel , with the exception of the transmitter sensing device, will perform the intended Function . Setpoints must be found within the tolerances and Allowable Values specified in Table 3.3.8-1. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 4) . The setpoint must be left set consistent with the assumptions of t he setpoint methodology (Ref. 4) . The "as found " and "as left" values must also be recorded and reviewed for consistency with the assumptions of the surveillance interval extension analysis in Reference 3 when applicable. The Frequency of 92 days is justified in Reference J . >'>-.
.--~-s""'""E-RT---.3!
SR 3.3.8.3 SR 3.3.8.3 is the performance of a TADOT. This test is a check of AFW automatic pump start on loss of offsite power, undervoltage RCP , and trip of all MFW pumps Functions. It is performed every 18 months. Each applicable Actuation Function is tested up to , and including , the end device start circuitry. In some instances, the test includes actuation of the end device (i.e. , pump starts, valve cycles, etc.) . As noted , this SR requires the injection of a simulated or actual signal for the Trip of Main Feedwater (continued) HBRSEP Unit No. 2 B 3.3-143 Revision No. Q
Auxiliary Feedwater (AFW) System Instrumentation B 3.3.8 BASES SURVEILLANCE SR 3.3.8.3 (continued) REQUIREMENTS Pumps Function. The injection of the signal should be as close to the sensor as practical. The rrequency is adequate, based on industry
- t::.:*perieRse aml is soRsisteRt witR tRe typisal releeliRg sysle. [NsERT J 3
SR 3.3.8.4 is the performance of a CHANNEL CALIBRATION. A CHAN~JEL CALIBRATION is performed every 18 months, or appro>Eimately at every refueling . CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy. CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology (Ref. 4). The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 4). The rrequency of 18 months is based on the assumption of an 18 month calibration interval in the determination of the magnitude of equipment Orilt iR tRe setpoiRI metRo8olo[jy (lsel. 4). l]N
. INSERT 3!
REFERENCES 1. UFSAR, Section 7.3.1
- 2. UFSAR, Section 3.1
- 3. WCAP-10271-P-A, Supplement 2, Rev. 1., June 1990
- 4. EGR-NGGC-0153, Engineering Instrument Setpoints HBRSEP Unit No. 2 B 3.3-144 Revision No. ea
RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 BASES ACTIONS (continued) If Required Action A.1 is not met within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status , the plant must be brought to at least MODE 2 within 6 hours. In MODE 2, the reduced power condition eliminates the potential for violation of the accident analysis bounds. The Completion Time of 6 hours is reasonable to reach the required plant conditions in an orderly manner. SURVEILLANCE SR 3.4.1.1 REQUIREMENTS Since Required Action A .1 allows a Completion Time of 2 hours to restore parameters that are not within limfts, the 12 hour Surveillance Frequency for pressurizer pressure is sufficient to ensure the pressure can be restored to a normal operation , steady state condition following toad changes and other expected transient operations. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and to verify operation is within safety aaalysis ass"m~tioa.s. ~ERT I 3 SR 3.4.1.2 Since Required Action A.1 allows a Completion Time of 2 hours to restore parameters that are not within limits, the 12 hour Surveillance Frequency for RCS average temperature is sufficient to ensure the temperature can be restored to a normal operation , steady state condition following load changes and other expected transient operations. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and to verify operation is within safely aaalysis ass"mptioas. ~ERT I 3 SR 3.4.1.3 The 12 hour Surveillance Frequency for RCS total flow rate is performed using the installed flow instrumentation. The 12 hour interval has been shown by operating practice to be (continued) HBRSEP Unit No. 2 B 3.4-4 Revision No. G
RCS Pressure, Temperature, and Flow DNB Limits B 3.4 .1 BASES SURVEILLANCE SR 3.4.1 .3 (continued) REQUIREMENTS sufficient to regularly assess potential degradation and to verify operation within safety analysis asssmfllians. gERT I 3 SR 3.4 .1.4 Measurement of RCS total flow rate by performance of a precision calorimetric heat balance once every 18 months allows the installed RCS flow instrumentation to be calibrated and verifies the actual RCS flow rate is greater than or equal to the minimum required RCS flow rate. The F=requency of 18 months reflects the importance of verifying flo1N after a refueling outage when the core has been altered , which may ha*;e caused an alteration of flo*N resistance. INSERT 3 This SR is modified by a Note that allows en ry 1n o ODE 1, without having performed the SR, and placement of the unit in the best condition for performing the SR. The Note states that the SR is not required to be performed until 24 hours after :l 90% RTP. This exception is appropriate since the heat balance requires the plant to be at a minimum of 90% RTP to obtain the stated RCS flow accuracies . The Surveillance shall be performed within 24 hours after reaching 90% RTP . REFERENCES 1. UFSAR, Chapter 15.
- 2. UFSAR, Section 4.4.2.
HBRSEP Unit No. 2 B 3.4-5 Revision No. G
RCS Minimum Temperature for Criticality B 3.4.2 BASES APPLICABILITY temperatures to fall below the temperature limit of this (continued) LCO . ACTIONS If the parameters that are outside the limit cannot be restored , the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 2 with Kett < 1.0 within 30 minutes. Rapid reactor shutdown can be readily and practically ach ieved within a 30 minute period . The allowed time is reasonable, based on operating experience, to reach MODE 2 with Kett < 1.0 in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.4.2.1 REQUIREMENTS RCS loop average temperature is required to be verified at or above 530°F every 30 minutes when the low T avg alarm is not reset and any RCS loop T avg < 543°F. The SR is modified by a Note which states that the Surveillance is only required when any RCS loop average temperature is < 543°F and the low T avg alarm is alarming , since RCS loop average temperatures could fall below the LCO requirement without additional warning . The SR to verify RCS loop average temperatures every 30 minutes is frequent enough to preyent the inad,;ertent violation et the LGO. l!&ERT I 3 REFERENCES 1. UFSAR, Section 15.0.4. HBRSEP Unit No. 2 B 3.4-8 Revision No. Q
RCS PIT Limits B 3.4.3 BASES ACTIONS C.1 and C.2 (continued) Condition C is modified by a Note requiring Required Action C.2 to be completed whenever the Condition is entered . The Note emphasizes the need to perform the evaluation of the effects of the excursion outside the allowable limits. Restoration alone per Required Action C.1 is insufficient because higher than analyzed stresses may have occurred and may have affected the RCPB integrity. SURVEILLANCE SR 3.4 .3.1 REQUIREMENTS Verification that operation is within the limits of Figures 3.4.3-1 and 3.4 .3-2 is required every 30 minutes when RCS pressure and temperature conditions are undergoing planned changes. +ms Frequency is considered reasonable in view of the control room indication available to monitor RCS status . Also, since temperature rate of change limits are specified in hourly increments, 30 minutes permits assessment and correction for minor deviations 'Nithin a reasonable time . Surveillance for heatup, cooldown , or ISLH testing may be discon ,nue when the definition given in the relevant plant procedure for ending the activity is satisfied . This SR is modified by a Note that only requires this SR to be performed during system heatup, cooldown , and ISLH testing . No SR is given for criticality operations because LCO 3.4 .2 contains a more restrictive requirement. REFERENCES 1. 10 CFR 50 , Appendix G .
- 2. ASME , Boiler and Pressure Vessel Code, Section XI , Appendix G, 1995 Edition with 1996 Addenda .
- 3. Yanichko, S. E. , "Carolina Power & Light Company, H. B.
Robinson Unit No. 2 Reactor Vessel Radiation Surveillance Program ," Westinghouse Nuclear Energy Systems, WCAP-7373 , January, 1970.
- 4. Laubham , T. J., et al , "Analysis of Capsule X from the Carolina Power and Light H. B. Robinson Unit No. 2 Reactor (continued)
HBRSEP Unit No. 2 B 3.4-17 Revision No. ~
RCS Loops - MODES 1 and 2 B 3.4.4 BASES (continued) SURVEILLANCE SR 3.4.4.1 REQUIREMENTS This SR requires verification every 12 hours that each RCS loop is in operation . Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal while maintaining the margin to DNB. The frequency of 12 hours is sufficient considering other indications and alarms available to the operator in lhe oonlrol room lo monitor RCS loop performanoo. ~ - SERT 3 j REFERENCES 1. UFSAR, Section 15.3. HBRSEP Unit No. 2 B 3.4-22 Revision No. Q
RCS Loop - MODE 3 B 3.4.5 BASES ACTIONS 0 .1, 0 .2, and D.3 (continued) With Required Action C.1 and associated Completion Time not met, two required RCS loops inoperable, or no RCS loops in operation (except during the conditions permitted by the Note in the LCO section), all CRDMs must be de-energized by opening the RTBs or de-energizing the MG sets. All operations involving introduction of coolant into the RCS with boron concentration less than required to meet the minimum SOM of LCO 3.1.1 must be suspended , and action to restore one of the RCS loops to OPERABLE status and operation must be initiated. A planned reduction in RCS boron concentration requires forced circulation for proper mixing , and opening the RTBs or de-energizing the MG sets removes the possibility of an inadvertant rod withdrawal. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SOM of LCO 3.1.1 is required to assure continued safe operation . With coolant added without forced circulation , unmixed coolant could be introduced to the core, however, coolant added with boron concentration meeting the minimum SOM maintains acceptable margin to subcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation . SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR requires verification every 12 hours that the required loops are in operation . Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. The Frequency of 12 hours is sufficient considering other indications and alarms available to the operator in the control room to monitor RC~ loop performance. l!NSERT I 3 SR 3.4.5.2 SR 3.4.5.2 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is
~ 16% for required RCS loops. If the SG secondary side narrow range water level is< 16%, the tubes may become uncovered and the associated loop may (continued)
HBRSEP Unit No. 2 B 3.4-28 Revision No. G,--1-e Amendment No. 49G
RCS Loop - MODE 3 B 3.4.5 BASES SURVEILLANCE . SR 3.4 .5.2 (continued) REQUIREMENTS not be capable of providing the heat sink for removal of the decay heat. The 12 hour Frequensy is sonsidered adequate in view of other indisations available in the sontrol room to alert the operator to a loss of SG level. [wsERT 31 SR 3.4.5.3, SR 3.4.5.4, SR 3.4.5.5, and SR 3.4.5.6 Periodic verification of the alternate administrative controls established by LCO 3.4.5 items a, b, c, or d, is prudent to preclude the possibility of a power excursion associated with an inadvertent control rod withdrawal when only one RCS loop is in operation . The 12 hour Frequensy f.or SR 3.4.5 .3, SR 3.4 .5.4, and SR 3.4 .5.5 is asseptable sinse the status of the affested somponents is not likely to shange without the operator being aware of it. The 24 hour Frequensy for SR 3.4.5 .6 is based on the generally slow shange in the required boron sonsentration and the low probability of an assident ossurring without the required SOM. ~INSERT 1 4 SR 3.4 .5.3, SR 3.4.5.4 , SR 3.4.5.5 and SR 3.4.5.6 have been modified by Notes, which* clarify that these SRs are not required to be met if the alternate requirements of SR 3.4.5.3, SR 3.4.5.4, SR 3.4.5.5, SR 3.4.5.6, as applicable, are satisfied . SR 3.4.5.7 Verification that the required RCPs are OPERABLE ensures that safety analyses limits are met. The requirement also ensures that an additional RCP can be placed in operation , if needed , to maintain decay heat removal and reactor coolant circulation . Verification is performed by verifying proper breaker alignment and power availability to the required RCPs. ifNs INSERT 3 I REFERENCES None. HBRSEP Unit No. 2 B 3.4-29 Revision No. Q,-4e Amendment No. 4W
RCS Loops - MODE 4 B 3.4.6 BASES ACTIONS C.1 and C.2 (continued) maintaining operation for decay heat removal. The action to restore must be continued until one loop or train is restored to OPERABLE status and operation . SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification every 12 hours that one RCS loop or RHR train is in operation. Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. The frequency of 12 hours is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS loop and RHR train performance. ~~-;::,,._-~ SR 3.4.6.2 ~ERT 3 ! SR 3.4.6.2 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is 2: 16%. If the SG secondary side narrow range water level is < 16%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink necessary for removal of decay heat. The 12 hour Frequency is considered adequate in viei.v of other indications available in the control room to alert the operator to the loss of SG level. [msERT 31 SR 3.4.6.3 Verification that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation , if needed, to maintain decay heat removal and reactor coolant circulation . Verification is performed by verifying proper breaker alignment and power available to the required pump. The frequency of 7 days is considered reasonable i:s in view of other administrative controls available and has been shown to be acceptable by operating experience. REFERENCES None. INSERT
.___ _ _3_._ !
HBRSEP Unit No. 2 B 3.4-34 Revision No. G,4e Amendment No. 400
RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES ACTIONS B.1 and B.2 (continued) the RCS of coolant with boron concentration less than requ ired to meet the minimum SOM of LCO 3.1.1 is required to assure continued safe operation . With coolant added without forced circulation , unmixed coolant could be introduced to the core, however, coolant added with boron concentration meeting the minimum SOM maintains acceptable marg in to subcritical operations . The immediate Completion Times reflect the importance of maintaining operation for heat removal. SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This SR requ ires verification every 12 hours that the required train is in operation . Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. The Frequency of 12 hours is sufficient considering other indications and alarms available to the operator in the control room to monitor R~R train performance. r@sERT I 3 SR 3.4.7.2 Verifying that at least one SG is OPERABLE by ensuring its secondary side narrow range water level is ~ 16% and the RCS is not vented ensures an alternate decay heat removal method in the event that the second RHR train is not OPERABLE. If both RHR trains are OPERABLE, this Surveillance is not needed . The 12 hour Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of SG level or the RCS pressure boundary. PFJsERT I 3 SR 3.4.7.3 Verification that a second RHR pump is OPERABLE ensures that an additional pump can be placed in operation , if needed , to maintain decay heat removal and reactor coolant circulation . Verification is performed by verifying proper breaker alignment and power available to the RHR pump. If secondary (continued) HBRSEP Unit No. 2 B 3.4-39 Revision No. O, 1e, 18 Amendment No. 4-QQ
RCS Loops - MODE 5, Loops Filled 8 3.4.7 BASES SURVEILLANCE SR 3.4.7.3 (continued) REQUIREMENTS side water level is ~ 16% in at least one SG and the RCS is not vented , this Surveillance is not needed . The frequency of 7 days is considered reasonable in 1Jiew of other administrati'le controls a1Jailable and has been shown to be acceptable by operating experience. ~ERT I 3 REFERENCES 1. NRC Information Notice 95-35 , "Degraded Ability of Steam Generators to Remove Decay Heat by Natural Circulation ," August 28, 1995. HBRSEP Unit No. 2 B 3.4-39a Revision No. G,-4e Amendment No. 4W
RCS Loops - MODE 5, Loops Not Filled B 3.4.8 BASES (continued) ACTIONS A.1 If only one RHR train is OPERABLE and in operation , redundancy for RHR is lost. Action must be initiated to restore a second train to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal. B.1 and B.2 If no required RHR trains are OPERABLE or in operation , except during conditions permitted by Note 1, all operations involving introduction of coolant into the RCS with boron concentration less than required to meet the minimum SOM of LCO 3.1.1 must be suspended and action .must be initiated immediately to restore an RHR train to OPERABLE status and operation . A planned reduction in RCS boron concentration requires forced circulation for uniform dilution, and the margin to criticality must not be reduced in this type of operation . Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SOM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation , unmixed coolant could be introduced to the core, however, coolant added with boron concentration meeting the minimum SOM maintains acceptable margin to subcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must continue until one train is restored to OPERABLE status and operation. SURVEILLANCE SR 3.4 .8.1 REQUIREMENTS This SR requires verification every 12 hours that one train is in operation . Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. +l=le Frequenoy of 12 hours is suffioient oonsidering other indioations and alarms available to the operator in the eontrol room to monitor Rl=IR train
~effe,maaoo. [Ns'ERT 31 (continued)
HBRSEP Unit No. 2 B 3.4-42 Revision No. G,4e Amendment No. 49G
RCS Loops - MODE 5, Loops Not Filled B 3.4.8 BASES SURVEILLANCE SR 3.4 .8.2 (continued) REQUIREMENTS Verification that the required number of pumps are OPERABLE ensures that additional pumps can be placed in operation , if needed , to maintain decay heat removal and reactor coolant circulation . Verification is performed by verifying proper breaker alignment and power available to the required pumps. The F'requency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience. @i SERT 3 ! REFERENCES None. HBRSEP Unit No. 2 B 3.4-43 Revision No. G;--4-e Amendment No. 4W
Pressurizer B 3.4.9 BASES SURVEILLANCE SR 3.4 .9.1 (continued) REQUIREMENTS limit to provide a minimum space for a steam bubble. The Surveillance is performed by observing the indicated level. The Frequenoy of 12 hours oorresponds to verifying the parameter eaoh shift. The 12 hour interval has been shown by operating praotioe to be suffioient to regu larly assess level for any deviation and verify that operation is within safety analyses assumptions. Alarms are also available for early deteotion of abnormal le"81 iaElisalioas. [NsERT I 3 SR 3.4.9.2 The SR is satisfied when the power supplies are demonstrated to be capable of producing the minimum power and the associated pressurizer heaters are verified to be at their design rating . This may be done by testing the power supply output and heater current, or by performing an electrical check on heater element continuity and resistance. +fte Frequenoy of 18 months is oonsidered adequate to detest heater degradation and has been shown by operating experienoe to be aooeptable. ~ ....~--__,
~ERT3!
SR 3.4 .9.3 This Surveillance demonstrates that the heaters can be manually transferred from the normal to the emergency power supply and energized . The Frequenoy of 18 months is based on a typioal fuel oyole and is oonsistent with similar verifioations of emergenoy power supplies. '@:sERT I 3 REFERENCES 1. UFSAR, Chapter 15.
- 2. NUREG-0737, November 1980.
HBRSEP Unit No. 2 B 3.4-48 Revision No. G
Pressurizer PORVs B 3.4.11 BASES SURVEILLANCE SR 3.4.11 .1 REQUIREMENTS Block valve cycling verifies that the valve(s) can be opened and closed if needed. The basis for the Frequency of 92 days is the ASME Code,
* . If the block valve is closed to isolate a PORV that is capable of be* anually cycled , the OPERABILITY of the block valve is of imp ce, because opening the block valve is necessary to permit ORV to be used for manual control of reactor pressure. If the block INSERT 3 valve is closed to isolate an inoperable PORV that is incapable of being manually cycled , the maximum Completion Time to restore the PORV and open the block valve is 72 hours, which is well within the allowable limits (25%) to extend the block valve Frequency of 92 days.
Furthermore, these test requirements would be completed by the reopening of a recently closed block valve upon restoration of the PORV to OPERABLE status. The Note modifies this SR by stating that it is not required to be met with the block valve closed , in accordance with the Required Action of this LCO. SR 3.4.11 .2 SR 3.4.11.2 requires a complete cycle of each PORV. Operating a PORV through one complete cycle ensures that the PORV can be manually actuated. Testing thePORVs in MODE 3 is required in order to simulate the temperature and pressure environmental effects on PORVs. In the HBRSEP Unit No. 2 PORV design, testing in MODE 4 or MODE 5 is not considered to be a representative test for assessing PORV performance under normal plant operating conditions. The Frequency of 18 months is based on a typical refueling cycle and industry accepted practice. ~ The Note provides guidance to perform this SR within 12 hours of entering MODE 3. This allows adequate time to establish proper plant conditions and ensures the SR is performed in a timely manner. (continued) HBRSEP Unit No. 2 B 3.4-59 Revision No. O
Pressurizer PORVs B 3.4.11 BASES SURVEILLANCE SR 3.4.11.3 REQUIREMENTS (continued) Operating the solenoid air control valves and check valves on the nitrogen accumulators ensures the PORV control system actuates properly when called upon. The Frequency of 18 months is based on a typical refueling cycle and the Frequency of the other SuF\leillances used ta demaast,ate PG~V OPERAB ILITY. ==..--....___-----.
~ERT3!
SR 3.4.11.4 The Surveillance demonstrates that the accumulators are capable of supplying sufficient nitrogen to operate the PORVs if they are needed for RCS pressure control, and normal nitrogen and the backup instrument air systems are not available. Backup instrument air is supplied when the accumulator reaches its low pressure setpoint. This SR must be performed by isolating the normal air and nitrogen supplies from the cycle and industry accepted practice. 1M PORVs. The Frequency of 18 months is based on a typical refueling SERT 3 ! REFERENCES 1. UFSAR, Section 15.6.
- 2. Generic Letter 90-06, "Resolution of Generic Issue 70, ' Power-Operated Relief Valve and Block Valve Reliability,' and Generic Issue 94, 'Additional Low-Temperature Overpressure Protection for Light-Water Reactors,' Pursuant to 10 CFR 50 .54(f)," dated June 25, 1990.
- 3. ASME, Boiler and Pressure Vessel Code, Section XI. !Deleted .
HBRSEP Unit No. 2 B 3.4-60 Revision No. O
LTOP System B 3.4.12 BASES SURVEILLANCE SR 3.4.12.1, SR 3.4.12.2, and SR 3.4.12.3 (continued) REQUIREMENTS The SI pump is rendered incapable of injecting into the RCS through removing the power from the pumps by racking the breakers out under administrative control. An alternate method of LTOP control may be employed using at least two independent means to prevent a pump start or to isolate the injection flow paths into the RCS such that a single failure or single action will not result in an injection into the RCS . This may be accomplished through removal of control power fuses and at least one valve in the injection flow paths being closed , or at least one valve in the injection flow paths being locked closed or closed and deenergized. The rrequency of 12 hours is sufficient, considering other indications and alarms available to the operator in the control room , to 1,erify the required status of the equipment. ~ SR 3.4.12.1 is modified by a Note indicating that this SR is only required to be met when all RCS cold leg temperatures are ~ 175°F and the requirements of LCO 3.4.12.b are not met. Below an RCS temperature of 175°F with the requirements of LCO 3.4.12.b not met, all SI pumps must be incapable of injection into the RCS , as required by SR 3.4.12.2. SR 3.4.12.2 is modified by a Note indicating that this SR is only requ ired to be met when any RCS cold leg temperature is < 175°F and the requirements of LCO 3.4.12.b are not met. Below an RCS temperature of 175°F with the requirements of LCO 3.4.12.b not met, all SI pumps must be incapable of injection into the RCS . Above an RCS temperature of 175°F, only one SI pump may be capable of injecting into the RCS as required by SR 3.4.12.1. SR 3.4.12.4 The RCS vent of~ 4.4 square inches is proven OPERABLE by verifying its open condition eitAeF. Once every 12 hours for a *.ialve that cannot be locked. (continued) HBRSEP Unit No. 2 B 3.4-72 Revision No. G
LTOP System B 3.4.12 BASES SURVEILLANCE SR 3.4.12.4 (continued) REQUIREMENTS b:- Once ei;ery 31 days for a i;ali;e that is locked , sealed , or secured in position . A remo*.ied pressurizer safety i;ali;e fits this category. ~ The passive vent arrangement must only be open to be OPERABLE. ~ This Surveillance is requi red to be met if the vent is being used to satisfy the pressure rel ief requirements of the LCO 3.4.12.b. SR 3.4 .12.5 The PORV block valve must be verified open ei;ery 72 hours to provide the flow path for each required PORV to perform its function when actuated . The valve must be remotely verified open in the main control room . This Surveillance is performed if the PORV satisfies the LCO . The block valve is a remotely controlled , motor operated valve . The power to the valve operator is not required removed , and the manual operator is not required locked in the inactive position . Thus, the block valve can be closed in the event the PORV develops excessive leakage or does not close (sticks open) after relieving an overpressure situation. The 72 hour i;::requency is considered adequate in i;ie11,1 of other administratii;e controls available to the operator in the control room , such as i;ali;e position indication, that i;erify that the PORV block valve remains
~ ~
I',--~N""'-;S-E-RT-3-,I SR 3.4.12.6 Performance of a COT is required within 12 hours after decreasing RCS cold leg temperature to~ 350°F and every 31 days on each required PORV to verify and , as necessary, adjust its lift setpoint. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The COT will verify the setpoint is within the allowed maximum limits in the LTOP analysis. PORV actuation could depressurize the RCS and is not required . (continued) HBRSEP Unit No. 2 B 3.4-73 Revision No. e4
LTOP System B 3.4.12 BASES SURVEILLANCE SR 3.4 .12.6 (continued) REQUIREMENTS To provide operators flexibility during MODE 4 transition activities a note has been added indicating that this SR is not required to be performed until 12 hours after decreasing RCS cold leg temperature to ~ 350°F . The 12 hour FREQUENCY considers the unlikelihood of a low temperature overpressure event during this time. The COT is required to be performed within 12 hours after entering the LTOP MODES when the PORV lift setpoint is reduced to the LTOP setting . The d1 day FR~QIJ~l>JGY soRsiders experieRse with *~"ipmeRI reliaBility. fJNSERT I 3 SR 3.4.12.7 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 18 months to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input. if§s . INSERT 3 ! REFERENCES 1. 10 CFR 50 , Appendix G.
- 2. Generic Letter 88- 11 .
- 3. UFSAR, Chapter 5.
- 4. Letter, RNP-RA/96-0141 , CP&L (R. M. Krich) to NRC, "Request for Technical Specifications Change, Conversion to Improved Standard Technical Specifications Consistent with NUREG-1431 ,
- Standard Technical Specifications-Westing house Plants,'
Revision 1," August 30, 1996, Enclosure 5.
- 5. Letter, NG-77-1215, CP&L (B . J . Furr) to NRC (R. W . Reid) ,
"Reactor Vessel Overpressurization Protection ," October 31 ,
1977.
- 6. Letter, NG-77-1426, CP&L (E. E. Utley) to NRC (R. W . Reid) ,
"Response to Overpressure Protection System Questions,"
December 15, 1977. ( continued) HBRSEP Unit No. 2 B 3.4-74 Revision No. e4
RCS Operational LEAKAGE B 3.4 .13 BASES SURVEILLANCE SR 3.4.13.1 REQUIREMENTS Verifying RCS LEAKAGE to be within the LCO limits ensures the integrity of the RCPB is maintained. Pressure boundary LEAKAGE would at first appear as unidentified LEAKAGE and can only be positively identified by inspection. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. Unidentified LEAKAGE and identified LEAKAGE are determined by performance of an RCS water inventory balance. The RCS water inventory balance must be met with the reactor at steady state operating conditions. The surveillance is modified by two notes. Note 1 states that this SR is required within 12 hours after reaching continuous steady state operation . Steady state operation is required to perform a proper inventory balance; calculations during maneuvering are not useful and a Note requires the Surveillance to be met when steady state is established . For RCS operational LEAKAGE determination by water inventory balance, steady state is defined as stable RCS pressure, temperature , power level , pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows . An early warn ing of pressure boundary LEAKAGE or unidentified LEAKAGE is provided by the automatic systems that monitor the containment atmosphere radioactivity and the containment sump level. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. These leakage detection systems are specified in LCO 3.4 .15, "RCS Leakage Detection Instrumentation." Note 2 states that this SR is not applicable to primary to secondary LEAKAGE because LEAKAGE of 75 gallons per day cannot be measured accurately by an RCS water inventory balance. The 72 hour Frequency during steady state operation is a reasonable interval to trend LEAKAGE and recognizes the importance of early leakage deloolioR iR t~e ~F<lllORtioR of assideats. ~ERT I 3 (continued) HBRSEP Unit No. 2 B 3.4-80 Revision No. ~
RCS Operational LEAKAGE B 3.4.13 BASES SURVEILLANCE SR 3.4.13.4 [j REQUIREMENTS (continued) This SR verifies that primary to secondary LEAKAGE is less or equal to 75 gallons per day through any one SG. Satisfying the primary to secondary LEAKAGE limit ensures that the operational LEAKAGE performance criterion in the Steam Generator Program is met. If this SR is not met, compliance with LCO 3.4.18, "Steam Generator Tube Integrity," should be evaluated . The 75 gallons per day limit is measured at room temperature as described in Reference 4. The operational LEAKAGE rate limit applies to LEAKAGE through any one SG . If it is not practical to assign the LEAKAGE to an individual SG , the entire primary to secondary LEAKAGE should be conservatively assumed to be from one SG . The Surveillance is modified by a Note which states that the Surveillance is not required to be performed until 12 hours after establishment of steady state operation . For RCS primary to secondary LEAKAGE determination, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown , and RCP seal injection and return flows. The Surveillance frequency of 72 hours is a reasonable interval to trend primary to secondary LEAKAGE and recognizes the importance of early leakage detection in the prevention of accid'ents. he primary to secondary LEAKAGE is determined using continu s process radiation monitors or radiochemical grab sampling in accorda e with the EPRI
. guidelines (Ref. 4).
INSERT 3 REFERENCES 1. UFSAR, Section 3.1.
- 2. UFSAR, Chapter 15.
- 3. NEI 97-06 , "Steam Generator Program Guidelines."
- 4. EPRI , "Pressurized Water Reactor Primary-to-Secondary Leak Guidelines."
HBRSEP Unit No. 2 B 3.4-81 Revision No. 32
RCS PIVs B 3.4.14 BASES SURVEILLANCE SR 3.4.14.1 (continued) REQUIREMENTS To satisfy ALARA requirements, leakage may be measured indirectly (as from the performance of pressure indicators) if accomplished in accordance with approved procedures and supported by computations showing that the method is capable of demonstrating valve compliance with the leakage criteria. Leakage rates> 1.0 gpm and s 5.0 gpm are considered unacceptable if the latest measured rate exceeds the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the 5.0 gpm limit by~ 50% . Leakage rates> 5.0 gpm are considered to be unacceptable. More than one valve may be tested in parallel. The combined leakage must be within the limits of this SR. In addition , the minimum differential pressure when performing the SR shall not be < 150 psid . For two PIVs in series , the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested , one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation , the protection provided by redundant valves would be lost. Testing is to be performed every 18 months, a typical refueling cycle. Testing must atse be performed once prior to entering MODE 2 whenever the unit has been in MODE 5 for at least 7 days if leakage testing has not been performed in the previous 9 months. The 18 month Frequency is consistent with the frequency allowed by the American Society of Mechanical Engineers (ASME) Code, Section XI (Ref. 6) . ~ INSERT 3 ! n addition , testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating . PIVs disturbed in the performance of this Surveillance should also be tested unless it has been established per Note 3 that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours after the valve has been reseated if in MODES 1 or 2, or prior to entry into MODE 2 if not in MODES 1 or 2 at the end of the 24 hour period . Within 24 hours is a reasonable and practical time limit for performing this test after opening or reseating a valve. (continued) HBRSEP Unit No. 2 B 3.4-87 Revision No. 0
RCS PIVs B 3.4.14 BASES SURVEILLANCE SR 3.4.14.1 (continued) REQUIREMENTS The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures . Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complementary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. In addition, this Surveillance is not required to be performed on the RHR System when the RHR System is aligned to the RCS in the shutdown cooling mode of operation . PIVs contained in the RHR shutdown cooling flow path must be leakage rate tested after RHR is secured and stable unit conditions and the necessary differential pressures are established . SR 3.4.14.2 Verifying that the RHR interlock is OPERABLE ensures that RCS pressure will not pressurize the RHR system beyond 125% of its design pressure of 600 psig . The interlock setpoint prevents the valves from being opened and is set so the actual RCS pressure must be< 474 psig to open the valves. This setpoint ensures the RHR design pressure will not be exceeded and the RHR relief valves will not lift. The 18 month rrequency is based on the need to perform the Surveillance under conditions that apply during a plant outage. The 18 month rrequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment. ~ INSERT ~ 3 REFERENCES 1. 10 CFR 50.2.
- 2. 10 CFR 50 .55a(c) .
- 3. UFSAR, Section 3.1.
- 4. WASH-1400 (NUREG-75/014) , Appendix V, October 1975.
(continued) HBRSEP Unit No. 2 B 3.4-88 Revision No. G;--7 Amendment No. ~
RCS PIVs B 3.4.14 BASES REFERENCES 5. NUREG-0677, May 1980. (continued) ASME , Boiler and Pressure Vessel Code, Section XI. !Deleted . ! HBRSEP Unit No. 2 B 3.4-89 Revision No. {)
RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS E.1 and E.2 (continued) If a Required Action of Condition A, B, C, or D cannot be met, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. F.1 With all required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required . SURVEILLANCE SR 3.4.15.1 REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. The check gives reasonable confidence that the channel is operating properly. +Re rrequency of 12 hours is based on instrument reliability and is reasonable for detecting off normal conditions . ~~~--~
~SERT3j SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the required containment atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string . +Re rrequency of Q2 days considers instrument reliabi lity, and operating
**~eFieRse Ras sRowR tRat it is ~re~er for lleteatiR§ QegrallatioR. @SERT I 3
(continued) HBRSEP Unit No. 2 B 3.4-96 Revision No. ~
RCS Leakage Detection Instrumentation B 3.4.15 BASES SURVEILLANCE SR 3.4.15.3, SR 3.4.15.4, and SR 3.4 .15.5 REQUIREMENTS (continued) These SRs require the performance of a CHANNEL CALIBRATION for each of the required RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string , including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability. A~aiR, eperatiR~ **pe,ieaoo Ras P"'""".tilat tilis ~'"q"""GY is asoopta81e. !WSERT I 4 REFERENCES 1. UFSAR, Section 3.1 .
- 2. UFSAR, Section 5.2.
HBRSEP Unit No. 2 B 3.4-97 Revision No. ~
RCS Specific Activity B 3.4.16 BASES (continued) SURVEILLANCE SR 3.4.16.1 REQUIREMENTS SR 3.4.16.1 requires performing a gamma isotopic analysis as a measure of the gross specific activity of the reactor coolant at least once every 7 days. The analysis shall consist of a qualitative measurement of the total radioactivity of the primary coolant in units of µCi/gm. While basically a quantitative measure of radionuclides with half lives longer than 15 minutes, excluding iodines, this measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken . This Surveillance provides an indication of any increase in gross specific activity. Trending the results of this Surveillance allows proper remedial action to be taken before reaching the LCO limit under norrt1al operating conditions. The Surveillance is applicable in MODES 1 and 2, and in MODE 3 with Tavg at least 500°F. The 7 day Frequency considers the unlikelihood of a gross fuel failure during the time. ~ ....--"'------. l!!i_SERT 3 ! SR 3.4.16.2 This Surveillance is performed in MODE 1 only to ensure iodine remains within limit during normal operation and following fast power changes when fuel failure is more apt to occur. The 14 day Frequency is adequate to trend changes in the iodine activity level , considering gross activity is monitored every 7 days. The Frequency, between 2 and 6 hours after a power change 2!: 1 o RTP within a 1 hour period, is established because the iodine lev Is peak during this time following fuel failure ; samples at other times wou d provide inaccurate results . INSERT 3 SR 3.4.16.3 . A radiochemical analysis for E determination is required every 184 days (6 months) with the plant operating in MODE 1 equilibrium conditions. The E determination directly relates to the LCO and is required to verify plant operation within the specified gross activity LCO limit. The analysis for E is a measurement of the average energies per disintegration for isotopes with half lives longer than (continued) HBRSEP Unit No. 2 B 3.4-102 Revision No.G
RCS Specific Activity B 3.4.16 BASES SURVEILLANCE SR 3.4.16.3 (continued) REQUIREMENTS 15 minutes, excluding iodines. The rrequency of 184 days recognizes E does not change rapidly. This SR has been modified y a o e at indicates the e determination is required to be performed within 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for at least 48 hours. This ensures that the radioactive materials are at equilibrium so the analysis for E is representative and not skewed by a crud burst or other similar abnormal event. REFERENCES 1. 10 CFR 100.11 .
- 2. UFSAR, Section 15.6.3 .
HBRSEP Unit No. 2 B 3.4-103 Revision No. ~
eves B 3.4.17 BASES ACTIONS F.1 and F.3 (continued) required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.4.17.1 REQUIREMENTS Verification of seal injection to the RCP seals ensures that adequate cooling to the RCP seals is maintained. Verification of seal injection flow is accomplished by direct measurement of seal injection flow or by other means as defined in procedures. ,A., 12 hour Frequency is considered reasonable in view of other administrative controls and the existence of plant alarms that will ensure that an undetected loss of seal injection for mere u,aa a sRert time is ualikely. ~ERT I 3 SR 3.4.17.2 Verification of seal injection flow to the RCP seals via the Makeup Water Pathways ensures that adequate cooling to the RCP seals can be maintained from the RWST. /l.n 18 month Frequency is considered reasonable considering the unlikely failure mechanisms associated with passive piping and operation of the two valves. ~INSERT 1 3 Verification of OPERABILITY of the Makeup Water Pathways from the RWST is also satisfied by SR 3.5.4.2, which verifies an adequate inventory of makeup water. REFERENCES 1. UFSAR Paragraph 9.3.4 .
- 2. CP&L Letter to NRC , 'Submittal of Independent Plant Examination (IPE)," dated August 31 , 1992.
HBRSEP Unit No. 2 B 3.4-109 Revision No. G
Accumulators B 3.5.1 BASES ACTIONS 0 .1 and 0 .2 (continued) 6 hours and pressurizer pressure reduced to [IpOO psig within 12 hours. The allowed Completion Times are reasonable , based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. If more than one accumulator is inoperable, the plant is in a condition outside the accident analyses; therefore, LCO 3.0.3 must be entered immediately. SURVEILLANCE SR 3.5.1.1 REQUIREMENTS Each accumulator isolation valve should be verified to be fully open prior to removing power from the operator. This verification ensures that the accumulators are available for injection. If an isolation valve is not fully open , the rate of injection to the RCS would be reduced . Although a motor operated valve position should not change with power removed , a closed valve could result in not meeting accident analyses assumptions. This Frequency is considered reasonable in view of other administrative controls that ensure a mispositioned isolation valve is unlikely. SR 3.5.1.2 and SR 3.5.1.3 (fil E¥ery 12 hours, b orated water volume and nitrogen cover pressure are verified for each accumulator. This Frequency is sufficient to ensure adequate injection during a LOCI\. Because of the static design of the accumulator, a 12 hour Frequency usually allows the operator to identify changes before limits are reached . Operating mcperience has shown this Frequency to be appropriate for early detection and correctiorref.-eff
"""""I lreR~S. IWsERT 41 (continued)
HBRSEP Unit No. 2 B 3.5-7 Revision No. G
Accumulators B 3.5.1 BASES SURVEILLANCE SR 3.5.1.4 REQUIREMENTS (continued) The boron concentration should be verified to be within required limits for each accumulator every 31 days since the static design of the accumulators limits the ways in which the concentration can be changed . The 31 day Frequency is adequate to identify changes that could occur from mechanisms such as stratification or inleakage. ~ Sampling the affected accumulator within 6 hours after a 2: 70 gallon n ,~lN~!S_E_R_T-3
~1 volume increase will identify whether inleakage has caused a reduction ._ ______._
in boron concentration. The 70 gallon volume increase and time limit of 6 hours is based on preventing a reduction in boron concentration in an accumulator below 1950 ppm with an initial boron concentration of 2000 ppm assuming in-leakage of 70 gallons pure water at a maximum in-leakage rate of 0.2 gpm . It is not necessary to verify boron concentration if the added water inventory is from the refueling water storage tank (RWST), because the water contained in the RWST is within the accumulator boron concentration requirements. This is consistent with the recommendation of NUREG-1366 (Ref. 4). SR 3.5.1.5 Verification every 31 days that control power is removed from each accumulator isolation valve operator ensures that an active failure could not result in the undetected closure of an accumulator motor operated isolation valve. If this were to occur, only one accumulator would be available for injection given a single failure coincident with a LOCA.
~ince power is removed under administrative control , the 31 day Frequency will provide adequate assurance that power is removed . ~SERT I 3
This SR allows power to be supplied to the motor operated isolation valves when pressurizer pressure is< 1000 psig , thus allowing operational flexibility by avoiding unnecessary delays to manipulate the breakers during plant startups or shutdowns. REFERENCES 1. UFSAR, Section 6.2.1.
- 2. 10 CFR 50.46.
(continued) HBRSEP Unit No. 2 B 3.5-8 Revision No. Q
ECCS - Operating B 3.5.2 BASES ACTIONS B.1 and B.2 (continued) control power restored . Additionally, Required Action B.2 requires the control power to be removed to the valve within 24 hours. In this condition, the valves could be subject to a spurious single failure that could result in closure of the valve and isolation of an accumulator. During the interval in which control power is restored, the valve remains in its required position or if a valve is repositioned after the restoration of power, the applicable condition associated with the ECCS train or flow path must be entered. The flow path to FCV-605 may be isolated in lieu of FCV-605 being in the required position. The 24 hour Completion Time is reasonable considering a low probability of a"spurious single failure coincident with a LOCA. C.1 and C.2 If the inoperable trains cannot be returned to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status , the plant must be brought to MODE 3 within 6 hours and MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.5.2.1 REQUIREMENTS Verification of proper valve position ensures that the flow path from the ECCS pumps to the RCS is maintained. Misalignment of these valves could render both ECCS trains inoperable. Securing these valves in position by removal of control power or by key locking the control in the correct position ensures that they cannot change position as a result of an active failure or be inadvertently misaligned . These valves are of the type , described in Reference 6, that can disable the function of both ECCS trains and invalidate the accident analyses. A 12 hour Frequency is considered reasonable in view of other administrative controls that will
"""""' a mispositioAeO val"" is ""likely. ~ERT I 3
(continued) HBRSEP Unit No. 2 B 3.5-17 Revision No. ~
ECCS - Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.2 REQUIREMENTS (continued) Verifying the correct alignment for manual , power operated , and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation . This SR does not apply to valves that are locked , sealed , or otherwise secured in position , since these were verified to be in the correct position prior to locking , sealing , or securing . A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve will automatically reposition within the proper stroke time . This Surveillance does not require any testing or valve manipulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct position. +Re J1 day frequency is appropriate because the valves are operated under adR1inistrative control, and an iRlproper valve position would only affect a single train . This frequency has been shown to be acceptable through o~erating e*~erienoo. ~ERT I 3
.SR 3.5.2.3 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by Section XI of the ASME Code. This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the plant safety analysis. This ensures that pump performance is consistent with the pump curve. SRs are specified in the lnservice Testing Program ,
which encompasses Section XI of the ASME Code . Section XI of the Code provides the activities and Frequencies necessary to satisfy the requirements. SR 3.5.2.4 and SR 3.5.2.5 These Surveillances demonstrate that each automatic ECCS valve actuates to the required position on an actual or (continued) HBRSEP Unit No. 2 B 3.5-18 Revision No. G
ECCS - Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.4 and SR 3.5.2.5 (continued) REQUIREMENTS simulated SI signal and that each ECCS pump starts on receipt of an actual or simulated SI signal. This Surveillance is not required for valves that are locked , sealed , or otherwise secured in the required position under administrative controls. The 18 month frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for unplanned plant transients if the Surveillances were performed with the reactor at power. The 18 month frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment. The actuation logic is tested as part of ESf Actuation System testing , and equipment performance is monitored as part of the lnservice Testing Program . lffisERT 4 j SR 3.5.2.6 Periodic inspections of the containment sump suction inlet ensure that it is unrestricted and stays in proper operating condition . The 18 month frequency is based on the need to perform this Surveillance under the 68-R4itions that apply during a plant outage, on the need to have access to the location, and because of the potential for an unplanned transient if the Surveillance were performed with the reactor at power. This frequency has been found to be sufficient to detect abnormal degradation and is oonli,med by o~eraling e*~e,ienoe. ~.---"----,
~ERT3j SR 3.5.2.7 Verification of proper valve position ensures the proper flow path is established for the LHSI system following operation in RHR mode. '.1=Re frequency of 31 days is commensurate with the accessibility and radiation le11els involved in ~erle,ming 11,e """'eillanoo (Rel. ~). ~ERT j 3
SR 3.5.2.8 Verification of proper valve position ensures the proper flow path is established for the LHSI system following operation in RHR mode. '.1=Re Frequency of 92 days is based on (continued) HBRSEP Unit No. 2 B 3.5-19 Revision No. G
ECCS - Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.8 (continued) REQUIREMENTS the locked status for the valve as well as the accessibility and radiation levels invol 11ed in performing the surveillance (Ref. 6) . !S-,. N-S-E-RT-3--,l
.--!I REFERENCES 1. UFSAR Paragraph 3.1 .2.37.
- 2. 10 CFR 50.46 .
- 3. UFSAR, Chapter 15.
- 4. UFSAR,*Chapter 6.
- 5. NRC Memorandum to V . Stello , Jr., from R.L. Baer, "Recommended Interim Revisions to LCOs tor ECCS Components," December 1, 1975 .
. . a-:- IE Information Notice No. 87 01 . !Deleted.!
- 7. CP&L Letter to NRC, from G. E. Vaughn ,*"Emergency Core Cooling System *(ECCS) Failure Mode and Effects Analysis (FMEA)
Summary Information," May 7, 1991 . HBRSEP Unit No. 2 B 3.5-20 Revision No. G
RWST B 3.5.4 BASES ACTIONS B.1 (continued) In this Condition , neither the ECCS nor the Containment Spray System can perform its design function . Therefore, prompt action must be taken to restore the tank to OPERABLE status or to place the plant in a MODE in which the RWST is not required . The short time limit of 1 hour to restore the RWST to OPERABLE status is based on this condition simultaneously affecting redundant trains. C.1 and C.2 If the RWST cannot be returned to OPERABLE status within the associated Completion Time , the plant must be brought to a MODE in which the LCO does not apply. To achieve this status , the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.5.4.1 REQUIREMENTS The RWST borated water temperature should be verified every 24 hours to be within the limits assumed in the accident analyses band . +his Frequency is sufficient to identify a temperature change that would approach either limit and has been shown to be acceptable through operating experience.~INSERT 3 I The SR is modified by a Note that eliminates the requirement to perform this Surveillance when ambient air temperatures are within the operating limits of the RWST. With ambient air temperatures within the band , the RWST temperature should not exceed the limits. SR 3.5.4.2 The RWST water volume should be verified every 7 days to be above the required minimum level in order to ensure that a sufficient initial supply is available for injection and to support continued ECCS and Containment Spray System pump (continued) HBRSEP Unit No. 2 B 3.5-29 Revision No. ()
RWST B 3.5.4 BASES SURVEILLANCE SR 3.5.4.2 (continued) REQUIREMENTS operation on recirculation . Since the RWST volume is normally stable and is protected by an alarm , a 7 day Frec:iuency is appropriate and has Oeea showa 1G Oe aGGeptaOle threagh ope,atiag e*perieaoo. il@ERT I 3 SR 3.5.4.3 The boron concentration of the RWST should be verified every 7 days to be within the required limits. This SR ensures that the reactor will remain subcritical following a LOCA. Further, it assures that the resulting sump pH will be maintained in an acceptable range so that boron precipitation in the core will not occur and the effect of chloride and caustic stress corrosion on mechanical systems and components will be minimized. Since the RWST volume is normally stable, a 7 day sampling Frec:iuency to verify boron concentration is appropriate and has been shovm to be
*.GGeptaOle thr~agh ope,atiag e*peFiease. ~N~ERT I 3
REFERENCES 1. UFSAR, Chapter 6 and Chapter 15. HBRSEP Unit No. 2 B 3.5-30 Revision No. G
Containment Air Lock B 3.6.2 BASES SURVEILLANCE SR 3.6.2.2 REQUIREMENTS (continued) The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment OPERABILITY. Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment. Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely meshanisal nature of this interlosk, and given that the interlosk meshanism is not normally shallenged when the sontainment air losk door is used for entry and exit (prosedures require strist adherense to single door opening), this test is only required to be performed every 24 months. The 24 month Frequensy is based on the need to perform this Surveillanse under the sonditions that apply during a plant outage, and the potential for loss of sontainment OPeRABILITY if the surveillanse were performed with the roaster at power. The 24 month Frequensy for tAe-ffiterlosk is justified based on generis operating experiense. The 24 month Frequensy is based on engineering judgment and is sonsidered adequate given that the interlosk is not shallenged during the use of the interlosk. ~ - - - - - -- - -~ - _INSERT 3-j - - - - - - - - - - - - REFERENCES 1. 10 CFR 50, Appendix J, Option B.
- 2. UFSAR, Paragraph 6.9.2 .
HBRSEP Unit No. 2 B 3.6-12 Revision No. e-9
Containment Isolation Valves B 3.6 .3 BASES SURVEILLANCE SR 3.6 .3.1 (continued) REQUIREMENTS safety related considerations (equipment or personnel) to support plant operations and maintenance activities within containment. Examples of
* : this may include operating the valves to reduce activity to increase stay
-~ , . : times, eliminate the need for respiratory protective equipment, reduce
* , a,mbient temperatures during hot months, to increase the effectiveness of
*. workers and to minimize occupational effects of necessary, non-routine activities in containment, .or for Surveillances that require the valves to be
. open . The valves are capable of closing in the *e*nvironment following a LOCA. Therefore , these valves are allowed to be open for limited periods
,of time . The 3.1 day Frequunoy is consistent with other oontainment isolation valve requirements discussed in SR 3.6.3.3. ince it is not operationally necessary, it is desirable to preclude the 2 inch valves and
.6 inch valves frer:n being open at the same time. A Not to this SR restricts the 6 inch and 42 inch valves from being opens ultaneously.
INSERT 3
. .. SR 3.6.3.2
.. * '. ,. This. SR requires verification that each* containment isolation manual valve
**and blind flange* lo:9ated outside containment and ndt locked , sealed or
"'., '. : - otherwi~e secured and -required to be closed during accident conditions is
- clos.e~t The :SRhelps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits.
This* SR does not require any testing or valve manipulation . Rather, it involves verification , through a system walkdown , that those containment isolation valves outs*ide containment and capable of being mispositioned are in the correct position. 8inoe verifioation of valve position for containment isolation valves outside ocmta1nment is relatively easy, the 31 day Frequenoy is applioable to oontainment isolation valves (exoept Penetration Pressurization System valves with a diameter < 3/8 inoh) and blind flanges. The 18 month Frequency is applioable to Penetration Pressurization System valves 1Nith a diameter < 3/8 inoh. These Frequencies are based on engineering judgment and were chosen to provide added assuranoe of the correct positions. The 18 month Frequenoy for Penetration Pressurization System val 11es < 3/8 inoh in diameter is oonsidered aooeptable based on the low (continued) HBRSEP Unit No. 2 B 3.6-22 Revision No. a+-
Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6 .3.2 (continued) REQUIREMENTS probability of these valves being mispositioned and the minimal consequences associated with mispositioning one of these valves . SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time INSERT 3 the valves are open . This SR does not apply to valves that are locked , sealed or otherwise secured in the closed position , since these were verified to be in the correct position upon locking , sealing or securing . The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3 and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in the proper position , is small. SR 3.6.3.3 This SR requires verification that each containment isolation manual valve and blind flange located inside containment and not locked , sealed or otherwise secured and required to be closed during accident cond itions is closed . The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. For containment isolation valves inside containment, the Frequency of "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is appropriate since these containment isolation valves are operated under administrative controls and the probability of their misalignment is low. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time they are open . This SR does not apply to valves that are locked, sealed or otherwise secured in the closed position , since these were verified to be in the correct position upon locking , sealing or securing . This Note allows valves and blind flanges located in high radiation areas to be verified closed by use of (continued) HBRSEP Unit No. 2 B 3.6-23 Revision No. 3-7
Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6 .3.3 (continued) REQUIREMENTS administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, and 4, for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position , is small. SR 3.6.3.4 Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time and Frequency of this SR are in accordance with the lnservice Testing (1ST) Program . In addition to the 1ST program testing frequency, the 42 inch purge supply and exhaust valves will be tested prior to use if not tested within the previous quarter. Otherwise, the 42 inch purge supply and exhaust valves are not cycled quarterly only for testing purposes. SR 3.6.3 .5 Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a OBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. This surveillance is not required for valves that are locked, sealed , or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this Surveillance Vlhen performed at the 18 month Frequency. Therefore , the Frequency was soasl"ded tG be asseptable Imm a reliability staadpoiat. )sERT I 3 (continued) HBRSEP Unit No. 2 B 3.6-24 Revision No . .a+
Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.6 REQUIREMENTS (continued) Verifying that each 42 inch inboard containment purge valve is blocked to restrict opening to s 70° is required to ensure that the valves can close under OBA conditions within the times assumed in the analyses of References 1 and 2. If a LOCA occurs, the purge valves must close to maintain containment leakage within the values assumed in the accident analysis . At other times when purge valves are required to be capable of closing (e.g ., during movement of irradiated fuel assemblies), pressurization concerns are not present, thus the purge valves can be fully open . The 18 month rrequency is appropriate because the blocking deyises ar<> typisally "'"'oved ORiy dYriR§ a re!YeliR§ 0Yta9e. ~SERT I 3 REFERENCES 1. UFSAR, Chapter 15.
- 2. UFSAR, Section 6.2.
- 3. Standard Review Plan 6.2.4.
HBRSEP Unit No. 2 B 3.6-25 Revision No. ~
Containment Pressure B 3.6.4 BASES (continued) ACTIONS When containment pressure is not within the limits of the LCO , it must be restored to within these limits within 1 hour. The Required Action is necessary to return operation to within the bounds of the containment analysis. The 1 hour Completion Time is consistent with the ACTIONS of LCO 3.6.1 , "Containment," which requires that containment be restored to OPERABLE status within 1 hour. B.1 and B.2 If containment pressure cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable , based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.4.1 REQUIREMENTS Verifying that containment pressure is within limits ensures that unit operation remains within the limits assumed in the containment analysis. The 12 hour Frequenoy of this SR was developed based on operating experienoe related to trending of oontainment pressure variations during the applioable MODES . Furthermore, the 12 hour Frequenoy is oonsidered adequate in view of other indioations available in the oontrol room , inoluding alarms, to alert the operator to an abnormal oontainment pressure oondition . ~ INSERT 3 I REFERENCES 1. UFSAR, Section 6.2 .
- 2. 10 CFR 50 , Appendix K.
HBRSEP Unit No. 2 B 3.6-28 Revision No. G
Containment Air Temperature B 3.6.5 BASES (continued) SURVEILLANCE SR 3.6.5.1 REQUIREMENTS Verifying that containment average air temperature is within the LCO limit ensures that containment operation remains w ithin the limit assumed for the containment analyses. In order to determine the containment average air temperature, a volumetric average is calculated using measurements taken at locations within the containment selected to provide a representative sample of the overall containment atmosphere. The 24 hour F"requenoy of this SR is oonsidered aooeptable based on observed slow rates of temperature inorease within oontainment as a result of environmental heat souroes (due to the large volume of oontainment). F"urthermore, the 24 hour F"requenoy is oonsidered adequate in view of other indioations available in the oontrol room to alert the operator to an abnormal oontainment temperature oondition . ~ INSERT 3 I REFERENCES 1. UFSAR, Section 6.2.
- 2. 10 CFR 50.49.
HBRSEP Unit No. 2 B 3.6-32 Revision No. G
Containment Spray and Cooling Systems B 3.6.6 BASES ACTIONS Ll (continued) With two containment spray trains or any combination of three or more containment spray and cooling trains inoperable, the unit is in a condition outside the accident analysis . Therefore, LCO 3.0.3 must be entered immediately. SURVEILLANCE SR 3.6.6.1 REQUIREMENTS Verifying the correct alignment for manual, power operated , and automatic valves in the containment spray flow path provides assurance that the proper flow paths will exist for Containment Spray System operation . This SR does not apply to valves that are locked , sealed , or otherwise secured in position , since these were verified to be in the correct position prior to locking , sealing , or securing . This SR does not require any testing or valve manipulation. Rather, it involves verification , through a system walkdown , that those valves outside containment and capable of potentially being mispositioned are in the correct position .
~
SR 3.6.6.2 Operating each containment cooling train fan unit for 2!: 15 minutes ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure , or excessive vibration can be detected for corrective action . +Re 31 day Frequency was developed considering the known reliability of the fan units and controls , the two train redundancy available, and the low probability of significant degradation of the containment cooling train occurring between surveillances. It has also been shown to be acceptable through operating experience. ~ .....- - ---.
~ERT3!
SR 3.6.6.3 Verifying that each containment cooling SW cooling flow rate to each cooling unit is 2!: 750 gpm provides assurance that the design flow rate assumed in the safety analyses will be achieved (Ref. 4) . The Frequency was developed considering the known reliability of the Cooling VVater System , the two (continued) HBRSEP Unit No. 2 B 3.6-40 Revision No. G
Containment Spray and Cooling Systems B 3.6.6 BASES SURVEILLANCE SR 3.6.6.3 (continued) REQUIREMENTS train redundancy available, and the low probabi lity of a significant de§radalioa al flow osseFFiR§ belweea serveillaases. [JNS'ERT I 3 SR 3.6.6.4 Verifying each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential pressure are normal tests of centrifugal pump performance required by Section XI of the ASME Code (Ref. 5) . Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on recirculation flow. This test confirms pump performance is consistent with the pump design curve and is indicative of overall performance, by setting the pump head and measuring the test flow. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of the SR is in accordance with the lnservice Testing Program . SR 3.6.6.5 and SR 3.6.6.6 These SRs require verification that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation of a containment High - High pressure signal. SR 3.6.6.5 is not required for valves that are locked , sealed , or otherwise secured in the required position under administrative controls. SR 3.6.6.6 must be performed with the isolation valves in the spray supply lines at the containment and spray additive tank locked closed . The 18 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillances when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a rel iability slaad~oiat. ~ERT I 4 (continued) HBRSEP Unit No. 2 B 3.6-41 Revision No. G
Containment Spray and Cooling Systems B 3.6.6 BASES SURVEILLANCE SR 3.6.6 .7 REQUIREMENTS (continued) This SR requires verification that each containment cooling train actuates upon receipt of an actual or simulated safety injection signal. The 18 month Frequency is based on engineering judgment and has been sho'Nn to be acceptable through operating experience. See SR 3.6 .6.5 and SR 3.6 .6.6, above, for further discussion of tile basis for tile 18 meRtll Fre~"eRsy. ~~--""---~
~ERT3!
SR 3.6.6.8 With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degraded . Performance is required following activities which could result in nozzle blockage. Such activities may include: (1) a major configuration change; or (2) a loss of foreign material control such that the final condition of the system cannot be assured . The frequency is considered adequate due to the passive design of the nozzles, the stainless steel construction of the piping and nozzles, and the use of foreign material exclusion controls during system opening . REFERENCES 1. UFSAR, Section 3.1.
- 2. 10 CFR 50, Appendix K.
- 3. UFSAR, Section 6.2.
- 4. UFSAR, Section 9.4 .
- 5. ASME , Boiler and Pressure Vessel Code, Section XI.
HBRSEP Unit No. 2 B 3.6-42 Revision No. ~
Spray Additive System B 3.6.7 BASES ACTIONS 8 .1 (continued) account the time necessary to restore the System to Operable Status, the relative importance of pH adjustment of the Containment Spray System flow for corrosion protection and iodine removal as well as the low probability of the worst case DBA occurring during this period . C.1 and C.2 If the Spray Additive System cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 84 hours. The allowed Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows 48 hours for restoration of the Spray Additive System in MODE 3 and 36 hours to reach MODE 5. This is reasonable when considering the reduced pressure and temperature conditions in MODE 3 for the release of radioactive material from the Reactor CooJant System. SURVEILLANCE SR 3.6.7.1 REQUIREMENTS Verifying the correct alignment of Spray Additive System manual , power operated , and automatic valves in the spray additive flow path provides assurance that the system is able to provide additive to the Containment Spray System in the event of a DBA. This SR does not apply to valves that are locked , sealed , or otherwise secured in position , since these valves were verified to be in the correct position prior to locking , sealing , or securing. This SR does not require any testing or valve manipulation. Rather, it involves verification , through a system walkdown , that those valves outside containment and capable of potentially being mispositioned are in the correct position .
~
(continued) HBRSEP Unit No. 2 B 3.6-46 Revision No. Q
Spray Additive System B 3.6.7 BASES SURVEILLANCE SR 3.6.7.2 REQUIREMENTS (continued) To provide effective iodine removal , the containment spray must be an alkaline solution. Since the RWST contents are normally acidic, the volume of the spray additive tank must provide a sufficient volume of spray additive to adjust pH for all water injected . This SR is performed to verify the availability of sufficient NaOH solution in the Spray Additive System. The 184 day Frequency was developed based on the low probability of an undeteeted change in tank volume oeeurring during the SR interval (the tank is isolated during normal unit operations) . Tank level is also indieated and alarmed in the eontrol room , so that there is Ri~R soRMeRoo tRat a s"BstaRtial sRaR~e iR IC\lel wo"IEI Be EletesteEI. ITN?ERT I 3 SR 3.6.7.3 This SR provides verification of the NaOH concentration in the spray additive tank and is sufficient to ensure that the spray solution being injected into containment is at the correct pH level. The 184 day Frequency is sufficient to ensure that the coneentration level of ~JaOH in the spray *additive tank remains above the limit. This is based on the low likelihood of an uncontrolled change in concentration (the tank is normally isolated) and the probability that any substantial variance in tank volume will Be EleteateEI. ~ERT I 3 SR 3.6.7.4 This SR provides verification that each automatic valve in the Spray Additive System flow path actuates to its correct position. This Surveillance is not required for valves that are locked , sealed , or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillanee under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at pov.ier. Operating experience has shown that these components usually pass the Surveillanee when performed at the 18 month Frequeney. Therefore, the Frequency was concluded to be asooptal,le fro"' a reliaBility staRElpoiRt. ~ERT I 3 (continued) HBRSEP Unit No. 2 B 3.6-47 Revision No. Q
IVSW System B 3.6.8 BASES ACTIONS B.1 and B.2 (continued) If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status , the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. Tt:ie allowed Completion Times are reasonable , based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.8.1 REQUIREMENTS This SR verifies the IVSW tank has the necessary pressure to provide motive force to the seal water. A pressure ~ 46.2 psig ensures the containment penetration flowpaths that are sealed by the IVSW System are maintained at a pressure which is at least 1.1 times the calculated peak containment internal pressure (Pa) related to the design bases accident. Verifisation of the IVSW tank pressure on a Frequensy of onse per 12 hours is asseptable. This Frequensy is suffisient to ensure availability of IVSW. Operating experiense has shown this Frequensy to be ap"'9priale fer early Oelestiea aaO sorrestioa el ell ROFffial treaOs. [!Ns'ERT I 3 SR 3.6.8.2 This SR verifies the IVSW tank has an initial volume of water necessary to provide seal water to the containment isolation valves served by the IVSW System . An initial volume~ 85 gallons ensures the IVSW System contains the proper inventory to maintain the required seal. Verifisation of IVSVV tank level on a Frequensy of onse per 31 days is asseptable sinse alarm iR t~e soatfol reOffi-j'>Fief te level Oesreasiag te 85 galleas. #RT tank level is sontinueusly monitored by installed instrumentation and will I 3 SR 3.6.8.3 This SR verifies the stroke time of each automatic air operated header injection solenoid valve is within limits. The frequency is specified by the lnservice Testing (continued) HBRSEP Unit No. 2 B 3.6-52 Revision No. a4
IVSW System B 3.6.8 BASES SURVEILLANCE SR 3.6.8.3 (continued) REQUIREMENTS Program , and previous operating experience has shown that these valves usually pass the required test when performed. SR 3.6.8.4 This SR ensures that automatic header injection valves actuate to the correct position on a simulated or actual signal. The 18 month i;::requensy is based on the need to perform this Surveillanse under the sonditions that apply during a plant outage and the potential for an unplanned transient if the Surveillanse were performed with the roaster at power. Operating experiense has shown these somponents usually pass the Surveillanse *.vhen performed at the 18 month i;::requensy. Therefore, the
- q:.: a: was oaaol"EiaEi ta be aoseptable. [N&ERT I 5 3 This SR ensures the capability of the dedicated nitrogen bottles to pressurize the IVSW system independent of the Plant Nitrogen System .
The 18 month i;::requensy is based on the need to perform this Surveillanse under the sonditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were perler"1eEi witR !Re reaotar at power. ~ERT I 3 SR 3.6.8.6 Integrity of the IVSW seal boundary is important in providing assurance that the design leakage value required for the system to perform its sealing function is not exceeded. The 18 month i;::requensy is based on the need to perform this Surveillanse under the sonditions that apply during a plant outage and the potential for an unplanned transient if the S"rveillaaoe were perlem,eEi witR !Re reaotar at power. ~ERT I 3 (continued) HBRSEP Unit No. 2 B 3.6-53 Revision No. G
AFW System B 3.7.4 BASES ACTIONS F.1 (continued) In MODE 4, either the reactor coolant pumps or the RHR loops can be used to provide forced circulation . This is addressed in LCO 3.4 .6, "RCS Loops - MODE 4 ." With one required AFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status. The immediate Completion Time is consistent with LCO 3.4.6. SURVEILLANCE SR 3.7.4.1 REQUIREMENTS Verifying the correct alignment for manual, power operated , and automatic valves in the AFW System water and steam supply flow paths provides assurance that the proper flow paths will exist for AFW operation. This SR does not apply to valves that are locked , sealed , or otherwise secured in position, since they are verified to be in the correct position prior to locking , sealing , or securing . This SR also does not apply to valves that cannot be inadvertently misaligned , such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position . The 31 day frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation , and ensures oorrest **l*e ~asitiaRs. @sERT I 3 SR 3.7.4.2 Verifying that each AFW pump's developed head at the flow test point is greater than or equal to the required developed head ensures that AFW pump performance has not degraded during the cycle. Flow and differential head are normal tests of centrifugal pump performance required by Section XI of the ASME Code (Ref. 4) to monitor centrifugal pump performance. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. This ensures that pump performance is consistent with the pump curve . Performance of inservice testing discussed in the ASME Code, Section XI (Ref. 4) ( continued) HBRSEP Unit No. 2 B 3.7-28 Revision No. ~
AFW System B 3.7.4 BASES SURVEILLANCE SR 3.7.4.2 (continued) REQUIREMENTS (only required at 3 month intervals) satisfies this requirement. :+Re 31 day Frequensy on a STAGGERED TEST BASIS results in te~sting eash pump onse every 3 months, as required by Referense 4. INSERT 3 This SR is modified by a Note indicating that the SR should be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test. SR 3.7.4.3 This SR verifies that AFW can be delivered to the appropriate steam generator in the event of any accident or transient that generates an AFW actuation signal , by demonstrating that each automatic valve in the flow path actuates to its correct position on an actual or simulated actuation signal. This Surveillance is not required for valves that are locked , sealed , or otherwise secured in the required position under administrative controls. The 18 month i;:requensy is based on the need to perform this Surveillanse under the sonditions that apply during a unit outage and the potential for an unplanned transient if the Surveillanse were performed with the reastor at power. The 18 month i;:requensy is asseptable based on operating e*periense and the design reliability of the equipment. ~ This SR is modified by a Note that states the SR is not required in MODE 4 when AFW is being used for heat removal. In MODE 4, the required AFW train is already aligned and operating . SR 3.7.4.4 This SR verifies that the AFW pumps will start in the event of any accident or transient that generates an AFW actuation (continued) HBRSEP Unit No. 2 B 3.7-29 Revision No. 49
AFW System B 3.7.4 BASES SURVEILLANCE SR 3.7.4.4 (continued) REQUIREMENTS signal by demonstrating that each AFW pump starts automatically on an actual or simulated actuation signal in MODES 1, 2, and 3. In MODE 4, the autostart function is not required . The 18 A1onth Frequency is based on the need to perforA1 this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were perforA1ed with the reactor at power. ~ This SR is modified by two Notes. Note 1 indicates that the SR be deferred until suitable test conditions are established . This deferral is required because there is insufficient steam pressure to perform the test. Note 2 states that the SR is not required in MODE 4. In MODE 4 , the heat removal requirements would be less providing more time for operator action to manually start the required AFW pump. SR 3.7.4.5 This SR verifies proper AFW System alignment and flow path OPERABILITY from the CST to each SG following extended outages to determine that no misalignment of valves has occurred . The SR is performed prior to entering MODE 2 after more than 30 days in MODE 5 or 6. OPERABILITY of AFW flow paths must be verified before sufficient core heat is generated that would require the operation of the AFW System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgment and other administrative controls that ensure that flow paths remain OPERABLE. This SR is modified by a Note that allows entry into and operation in MODE 3 and MODE 2 prior to performing the SR for the steam driven AFW pump. This is necessary because sufficient decay heat is not available following an extended outage. The unit must be at a point of adding minimum core heat in order to provide sufficient steam to operate the steam driven AFW pump to verify water flow. ( continued) HBRSEP Unit No. 2 B 3.7-30 Revision No. G
AFW System B 3.7.4 BASES SURVEILLANCE SR 3.7.4.6 REQUIREMENTS (continued) This SR verifies that the automatic bus transfer switch associated with the "swing" motor driven AFW flow path discharge valve V2-16A will function properly to automatically transfer the power source from the aligned emergency power source to the other emergency power source upon loss of power.to the aligned emergency power source. The
- Surveillance consists of two tests to assure that the switch will perform in either direction. One test is performed with the automatic bus transfer switch aligned to one emergency power source initially, and the test is repeated with the switch initially aligned to the other emergency power source. Periodic testing of the switch is necessary to demonstrate OPERABILITY. Operating experience has sho1Nn that this component usually passes the Surveillance when performed at the 18 month rrequency. Therefore, the rrequency is acceptable from a reliability standpoint. ~ ~ - - - ~
- - - - - - - ----1 ~ERT 3!1---- ---------- REFERENCES 1. UFSAR, Section 10.4.8.
- 2. UFSAR, Section 15.2.8.
- 3. UFSAR, Section 15.2.7.
- 2. ASME , Boiler and Pressure Vessel Code, Section XI.
HBRSEP Unit No. 2 B 3.7-31 Revision No. 49
CST B 3.7.5 BASES ACTIONS C.1 and C.2 (continued) reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.5.1 REQUIREMENTS This SR verifies that the CST contains the required volume of cooling water. The 12 hour Frequency is based on operating experience and the need for operator awareness of unit evolutions that may affect the CST inventory between checks. Also , the 12 hour Frequency is considered adequate in view of other indications in the control room , including alarms, to alert tRe o~orator to aOaormal ~eviatioas iR tRe CST le¥CI. UNs:ERT I 3 SR 3.7.5.2 This SR verifies by administrative means that the backup water supply to the AFW System from the SWS is OPERABLE. In this situation , verification by administrative means is necessary because it is not prudent to cycle the valves and risk introduction of non-feedwater grade water into the SGs. An administrative verification of OPERABILITY is simply a visual inspection of the water supply connection between the SWS and the AFW System to verify that the valves are in place and locked closed , the tell-tale drain valve is open , and the piping is intact and free from leakage. The 31 day Frequency is based on engineering judgement, and is consistent with the procedural controls that ensure that a water supply is OPERABLE. Also, the 31 day Frequency is considered adequate in view of the infrequent need to operate val 11es in the flow paths due to testing or operational requirements. ~
---,_INSERT 3 I- - - - - - - -
REFERENCES 1. UFSAR, Section 9.2.5.
- 2. UFSAR, Chapter 6.
- 3. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.7-35 Revision No. G
CCW System B 3.7.6 BASES ACTIONS 8 .1 and 8.2 (continued) allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.6.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the CCW flow to individual components may render those components inoperable but does not affect the OPERABILITY of the CCW System . Verifying the correct alignment for manual, power operated , and automatic valves in the required CCW flow path provides assurance that the proper flow paths exist for CCW operation . This SR does not apply to valves that are locked , sealed , or otherwise secured in position , since these valves are verified to be in the correct position prior to locking , sealing , or securing . This SR also does not apply to valves that cannot be inadvertently misaligned , such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position . The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation , and ensures oarrost valve ~asiliaas. ~ERT I 3 SR 3.7.6.2 This SR verifies proper automatic operation of the required CCW pumps on an actual or simulated LOP DG start undervoltage signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation . The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating e:><perience has shown that these components usually pass the Surveillance when performed at (continued) HBRSEP Unit No. 2 B 3.7-39 Revision No. ~ Amendment ..:j.g6
CCW System B 3.7.6 BASES SURVEILLANCE SR 3.7.6 .2 (continued) REQUIREMENTS the 18 month frequency. Therefore , the frequency is acceptable from a reliability standpoint. :'::ilNSERT 3 I REFERENCES 1. UFSAR, Section 9.2.2. HBRSEP Unit No. 2 B 3.7-40 Revision No. G
sws B 3.7.7 BASES ACTIONS 0 .1 and D.2 (continued) If the Required Actions and associated Completion Times of Conditions A, B, or C cannot be met, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status , the unit must be placed in at least MODE 3 within 6 hours and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditfons from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.7.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the SWS component~ or systems may render those components inoperable, but does not affect the OPERABILITY of the SWS . Verifying the correct alignment for manual , power operated , and automatic valves in the SWS flow path provides assurance that the proper flow paths exist for SWS operation . This SR does not apply to valves that are locked , sealed , or otherwise secured in position, since they are verified to be in the correct position prior to being locked , sealed , or secured . This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position . This SR does not apply to valves that cannot be inadvertently misaligned , such as check valves. The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures oorreot valve ~osilioas. [!NsERT j 3 SR 3.7.7.2 This SR verifies proper automatic operation of the SWS valves on an actual or simulated actuation signal. The SWS is a normally operating system that cannot be fully actuated as part of normal testing . This Surveillance is not required for valves that are locked , sealed , or otherwise secured in the requi red position under administrative (continued) HBRSEP Unit No. 2 B 3.7-45 Revision No. G
sws B 3.7.7 BASES SURVEILLANCE SR 3.7.7.2 (continued) REQUIREMENTS controls. The 18 Rlonth F"requensy is based on the need to perforRl this Surveillanse under the sonditions that apply during a unit outage and the potential for an unplanned transient if the Surveillanse were perforR1ed v;ith the reastor at power. Operating experiense has shown that these soR1ponents usually pass the Surveillanse when perforR1ed at the 18 Rlonth F"requensy. Therefore, the F"requensy is asseptable froRl a reliability standpoint. '~--"'---~
~ERT3!
SR 3.7.7.3 This SR verifies proper automatic operation of the SWS pumps and SWS booster pumps on an actual or simulated actuation signal. The SWS is a normally operating system that cannot be fully actuated as part of normal testing during normal operation . The 18 R1onth F"requensy is based on the need to perforRl this Surveillanse under the sonditions that apply during a unit outage and the potential for an unplanned transient if the Surveillanse were perforR1ed with the reastor at power. Operating experiense has shown that these GORlponents usually pass the Surveillanse when perforR1ed at the 18 Rlonth F"requensy. Therefore, the Fre~""""Y is asse~tal,le fro"' a relial,ility staaO~oiat. ~ R T I 3 SR 3.7.7.4 This SR verifies that the automatic bus transfer switch associated with turbine building service water isolation valve V6-16C, will function properly to automatically transfer the power source from the aligned emergency power source to the other emergency power source upon loss of power to the aligned emergency power source. The surveillance consists of two tests to assure that the switch will perform in either direction . One test is performed with the automatic bus transfer switch aligned to one emergency power source initially, and the test is repeated with the switch initially aligned to the other emergency power source. Periodic testing of the switch is necessary to demonstrate OPERABILITY. Operating experiense has shown that this soR1ponent usually passes the Surveillanse when perforR1ed at the 18 Rlonth F"requensy. (continued) HBRSEP Unit No. 2 B 3.7-46 Revision No. O
sws B 3.7.7 BASES SURVEILLANCE SR 3.7.7.4 (continued) REQUIREMENTS TlaeFe!or<>, !Re ~""l"ensy is asse~lalale lraFA a r<>lialailily stan<l~oinl. ~'ifERT [ 3 REFERENCES 1. UFSAR, Section 9.2.1.
- )
*o
- 2. UFSAR, Section 6.2 .
- 3. UFSAR, Section 5.4.4.
HBRSEP Unit No. 2 B 3.7-47 Revision No. G
UHS 8 3.7.8 BASES ACTIONS A.1 and A.2 (continued) The Completion Time of Required Action A.1 was developed considering that some activities required to complete the evaluation of required cooling capacity could be completed prior to the Condition being entered . The Completion Time of Required Action A.2 is based on shift schedules for convenience and is considered acceptable since temperature
- monitoring capability is available to detect an increase in* SW temperature throughout the period of Condition A.
8 .1 and 8 .2 If the Required Actions and associated Completion Times are not met or the UHS is inoperable for reasons other than Condition A , the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours and in MODE 5 within 36 hours. The allowed Completion Times are reasonable , based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.8.1 REQUIREMENTS This SR verifies that adequate long term (22 day) cooling can be maintained. The specified level also ensures that sufficient NPSH is available to operate the SWS pumps. The 24 hour Frequency is based on operating experience related to trending of the parameter variations during the applisaBle MODE~. ' \is SR ~erifies that the UHS water level is
;;:: 218 ft MSL.
INSERT 3 (continued) HBRSEP Unit No. 2 B 3.7-50a Revision No. ~ Amendment No. 4B4
UHS B 3.7.8 BASES SURVEILLANCE SR 3.7.8.2 REQUIREMENTS This SR verifies that the SWS is available to cool the CCW System to at least its maximum design temperature with the maximum accident or normal design heat loads for 30 days following a Design Basis Accident. The 24 hour F'requenoy is based on operating experience related to trending of the parameter variations during the applicable MODES. This SR verifies that the service water temperature is::;; 97°F. - - - - - - - - - - - - - - - - - - - - - - ---1 1NSERT 3 REFERENCES 1. UFSAR, Section 9.2.4.
- 2. UFSAR Section 2.4.6.1.
- 3. UFSAR Section 2.1.1.2.
- 4. NUREG-75/024, "Final Environmental Statement Related to the Operation of H. B. Robinson Nuclear Steam-Electric Plant Unit 2,"
U. S. Nuclear Regulatory Commission , Washington DC 20555 , April 1975, page 3-7.
- 5. USGS Historical Daily Values for Station Number 02130900, Black Creek Near McBee, South Carolina , Years 1960-1993.
HBRSEP Unit No. 2 B 3.7-51 Revision No. ~ Amendment No. 4S+
CREFS B 3.7 .9 BASES ACTIONS H.1 (continued) Conditions A or E for other reasons which may make one or more CREFS trains inoperable. Similarly, entry into Conditions A or E for reasons other than Condition G , does not preclude entry into Condition G at the same or later time. In MODE 1, 2, 3, or 4, if the inoperable CRE boundary cannot be restored to OPERABLE status within the requi red Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the un it must be placed in at least MODE 3 within 6 hours, and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challeng ing unit systems. SURVEILLANCE SR 3.7.9.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on th is system are not too severe, testing each train once every month provides an adequate check of this system . Operation for ~ 15 minutes is adequate to demonstrate the function of the system . The 31 day Frequency is based on the rel iability of the equipment and the two train
- "::*:: a,ailaBi li!~. TusERT 31 This SR verifies that the required CREFS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP) . The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate , and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.
(continued) HBRSEP Unit No. 2 B 3.7-58 Revision No. 48
CREFS 8 3.7.9 BASES SURVEILLANCE SR 3.7.9.3 REQUIREMENTS (continued) This SR verifies that each CREFS train starts and operates on an actual or simulated actuation signal. The Frequency of 1g months is consistent with Position C.5 of Regu latory Guide 1.52 (Ref. 4) . The rn month Frequency is based on the refueling cycle. Operating experience has shO\'.'n that these components usually pass the Surveillance when performed at the 1g month Frequency.
~ERT31 SR 3.7.9.4 This SR verifies the integrity of the CRE boundary. The CRE Habitability Program specifies administrative controls for temporary breaches to the boundary, preventative maintenance requirements to ensure the boundary is maintained , and leak test surveillance requirements. The details and frequencies for these requirements are specified in the CRE Habitability Program.
REFERENCES 1. UFSAR, Section 6.4.
- 2. UFSAR Section 6.4.2.3.
- 3. UFSAR, Chapter 15.
I Regulatory Guide 1.52, Rev. 2, March 197g_ Deleted . j HBRSEP Unit No. 2 B 3.7-58a Revision No. 48
CREATC 83.7.10 BASES ACTIONS F.1 and F.2 (continued) In MODE 1, 2, 3, or 4, if both inoperable WCCU trains cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.10.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the heat load assumed in the control room . This SR consists of a combination of testing and calculations. +he 18 month frequency is appropriate since significant degradation of the WCCUs is slow and is not
. e*pesled """.' l~is liffie--pe~ ~s'ERT I 3
REFERENCES 1. . UFSAR, SectLon 6..4. HBRSEP Unit No. 2 B 3.7-62 Revision No. Q
FBACS B 3.7.11 BASES (continued) SURVEILLANCE SR 3.7.11 .1 REQUIREMENTS The FBACS should be checked periodically to ensure that it functions properly. As the environmental and normal operating conditions on this system are not severe, testing once every month provides an adequate check on this system. Operation with the heaters on for ~ 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that heater failure , blockage, fan or motor failure , or excessive vibration can be detected for corrective action. The a1 day Frequenoy is based on the kROWR ,elia~ilily el Ike e~ei~RaeRI. ~ERT I 3 SR 3.7.11 .2 This SR verifies that the requ ired FBACS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA fi lter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal. (general use and following specific operations) . Specific test frequencies and add itional information are discussed in detail in the VFTP. SR 3.7.11.3 This SR verifies the integrity of the fuel build ing enclosure. The ability of the fuel building to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the FBACS. The FBACS is designed to maintain a slight negative pressure in the fuel building , to prevent unfiltered LEAKAGE. The Frequenoy of 18 months is oonsistent with the guidanoe provided in NUREG 0800, Seotion 6.5.1 (Ref. 5) . ~INSERT 31 ISTS SR 3. 7 .13.4 is modified by a Note. This Note provides clarification that the Surveillance is not applicable when the only movement of irradiated fuel is movement of a spent fuel shipping cask containing irradiated fuel. This Note is necessary to permit the shipping cask to be removed from the fuel handling building . When the side walls are opened to (continued) HBRSEP Unit No. 2 B 3.7-65 Revision No. +:J:
FBACS B 3.7.11 BASES SURVEILLANCE SR 3.7.11 .3 (continued) REQUIREMENTS (continued) permit cask egress, ISTS SR 3.7.13.4 cannot be met. OPERABILITY of the FBACS is not necessary when irradiated fuel assemblies are in a spent fuel shipping cask because irradiated fuel assemblies are protected from damage and associated release of fission products by the cask and other controls associated with shipments of spent fuel assemblies. The terms "shipping cask" and "shipment" used within this specification and bases also applies to the transfer cask/dry fuel storage container used to transfer fuel to the onsite Independent Spent Fuel Storage Installation (ISFSI). REFERENCES 1. UFSAR, Section 6.5.1.
- 2. UFSAR, Section 9.4.5 .
- 3. UFSAR, Sectiqn 15.7.4 .
- 4. 10 CFR 50 .67.
NUREG 0800, Section 6.5.1, Rev. 2, July 1981 . !Deleted. !
- 6. Licensee Event Report (LER) 50-26/97-05 , dated May 22 , 1997.
- 7. Deleted .
- 8. Regulatory Guide 1.183.
HBRSEP Unit No. 2 B 3.7-66 Revision No. ~
Fuel Storage Pool Water Level 8 3.7.12 8 3. 7 PLANT SYSTEMS BASES LCO storage racks. The specified water level preserves the (continued) assumptions of the fuel handling accident analysis (Ref. 3) and time to boil calculations (Ref. 2) . As such , it is the minimum required for fuel movement within the fuel storage pool. APPLICABILITY This LCO applies during movement of irradiated fuel assemblies in the fuel storage pool , since the potential for a release of fission products exists. ACTIONS Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply. When the initial conditions for prevention of an accident cannot be met, steps should be taken to preclude the accident from occurring . When the fuel storage pool water level is lower than the required level, the movement of irradiated fuel assemblies in the fuel storage pool is immediately suspended to a safe position . This action effectively precludes the occurrence of a fuel handling accident. This does not preclude movement of a fuel assembly to a safe position. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action . If moving irradiated fuel assemblies while in MODES 1, 2, 3, and 4 , the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown . SURVEILLANCE SR 3.7.12.1 REQUIREMENTS This SR verifies sufficient fuel storage pool water is available in the event of a fuel handling accident. The water level in the fuel storage pool must be checked periodically. The 7 day rrequency is appropriate because ( continued) HBRSEP Unit No. 2 8 3.7-68 Revision No. G
Fuel Storage Pool Water Level B 3.7.12 B 3.7 PLANT SYSTEMS BASES SURVEILLANCE SR 3.7.12.1 (continued) REQUIREMENTS ., the volume in the pool is normally stable. Water level changes are controlled by plant procedures and are acceptable based on operating experience. ~ During fuel transfer operations, the level in the fuel storage pool is in equilibrium with the refueling canal , and the level in the refueling canal is_ checked daily in accordance with SR 3.9.6.1. REFERENCES 1. UFSAR, Section 9.1.2.
- 2. UFSAR, Section 9.1.3.
- 3. UFSAR, Section 15.7.4.
- 4. 10 CFR 50 .67.
HBRSEP Unit No. 2 B 3.7-69 Revision No.~
Fuel Storage Pool Boron Concentration B3.7.13 BASES ACTIONS The Required Actions are modified by a Note indicating that LCO 3.0.3 does not apply. The movement or storage of fuel in the spent fuel storage pool is independent of reactor operation . Therefore, inability to suspend movement of fuel assemblies or maintain the fuel storage pool boron concentration greater than 1500 ppm is not sufficient reason
. to require a reactor shutdown When the concentration of boron in the fuel storage pool is less than required , immediate action must be taken to preclude the occurrence of an accident or to mitigate the consequences of an accident in progress.
This is most efficiently achieved by immediately suspending the movement of fuel assemblies. Prior to resuming movement of fuel assemblies, the concentration of boron must be restored. This does not preclude movement of a fuel assembly to a safe position. When the concentration of boron in the fuel storage pool is less than required , immediate action must be taken to return the concentration to the required limit to ensure K ett remains less than or equal to 0.95 in the high density storage racks .. SURVEILLANCE SR 3.7.13.1 REQUIREMENTS This SR verifies that the concentration of boron in the fuel storage pool is within the required limit. As long as this SR is met, the analyzed accidents and criticality analyses are fully addressed . The 7 day rrequency is appropriate because no major replenishment of pool *.vater is e*~eeted ta take ~lase aver sush a short ~eriad al time. ~§ERT I 3 REFERENCES 1. UFSAR Section 9.1.2. HBRSEP Unit No. 2 B 3.7-72 Revision No. ~
Secondary Specific Activity B3.7.15 BASES SURVEILLANCE SR 3.7.15 .1 (continued) REQUIREMENTS isotopic concentrations th~t might indicate changes in reactor coolant activity or LEAKAGE.
- The 31 day frequency is based on the detection of increasing trends of the level of DOSE EQUIVALENT I 131 , and allows for *~~"'~riate asliaR ta be takeR ta maiRtaiA levels belaw the bGO limit. ~RT I 3
REFERENCES 1. UFSAR, Chapfer 15.
- 2. . 10 CFR 50 .67.
HBRSEP Unit No. 2 B 3.7-80 Revision No. ~
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE The AC sources are designed to permit inspection and REQUIREMENTS testing of all important areas and features , especially those that have a standby function , in accordance with HBRSEP Design Criteria (Ref. 1). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for demonstrating the OPERABILITY of the DGs are consistent with the recommendations of Regulatory Guide 1.137 (Ref. 6), as addressed in the UFSAR. Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. The minimum steady state output voltage of 467 V is 97% of the nominal 480 V output voltage. It allows for voltage drops to motors and other equipment down through the 120 V level where minimum operating voltage is also usually specified as 90% of name plate rating . The specified maximum steady state output voltage of 493 V is within the maximum operating voltage specified for the motors supplied by the 480 V subsystem . It ensures that for a lightly loaded distribution system , the voltage at the terminals of motors is no more than the maximum rated operating voltages. The specified minimum and maximum frequencies of the DG are 58.8 Hz and 61.2 Hz, respectively. These values are equal to +/- 2% of the 60 Hz nominal frequency and are consistent with the recommendations given in Regulatory Guide 1.9 (Ref. 7) . SR 3.8.1.1 This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source. The 7 day rrequency is adequate since breaker position is not likely to change 1.vithout the operator being aware of ii and ~osa"so its stat"s is dis~layed in l~e sonlrol ream . ~ERT I 3 (continued) HBRSEP Unit No. 2 B 3.8-11 Revision No. e7
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.7 REQUIREMENTS (continued) These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and to maintain the unit in a safe shutdown condition . To minimize the wear on moving parts that do not get lubricated when the engine is not running , these SRs are modified by a Note (Note 2 for SR 3.8.1.2) to indicate that all DG starts for these Surveillances may be preceded by an engine prelube period and followed by a warmup period prior to loading . For the purposes of SR 3.8.1.2 and SR 3.8.1.7 testing , the DGs are started from standby conditions. Standby conditions for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations. In order .to reduce stress and wear on diesel engines, the manufacturer recommends a modified start in which the starting speed of DGs is limited , warmup is limited to this lower speed , and the DGs are gradually accelerated to synchronous speed prior to loading . These start procedures are the intent of Note 3, which is only applicable when such modified start procedures are recommended by the manufacturer. SR 3.8.1.7 requ ires that, at a 184 day Frequency, the DG starts from standby conditions and achieves required voltage and frequency within 10 seconds. The minimum voltage and frequency stated in the SR are those necessary to ensure the DG can accept DBA loading while maintaining acceptable voltage and frequency levels. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application . This period may extend beyond the 10 second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR, HBRSEP Unit No. 2 will monitor and trend the actual (continued) HBRSEP Unit No. 2 B 3.8-12 Revision No. &l-
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR -3.8.1.2 and SR 3.8.1.7 (continued) REQUIREMENTS time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 1O second' start requirement supports the ass1:1mptioris of the design basis LOCA analysi*s in the UFSAR, Chapter 15 (Ref. 4) . The 1O second start requirement is not applicable to SR 3.8.1.2 (see Note 3) when a modified start procedure as described above is used. If a modified start is not used , the 10 second start requirement of SR 3.8.1.7 ap'plies.
- Since SR 3.8.1.7 requires a 10 second start, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2. This is the intent of Note 1 of SR 3.8.1.2. * *
.' )
The 31 day Frequency for SR a.8.'1 .2 is' eonsistent with Regulatory Guide 1".9 (Ref: 7) . *rhe 184 eay"Frequency for SR 3:8.1.7 is a reduction in
* *: cold testiAg consistent with Generic Letter 84
- 15 (Ref. 5) . These
~* Frequencies pro 1Jide adequate assuran*c e of DG OPERABILITY, while
. ~iaimiziag degradali~R re_~"lti~g lro~ testiag . ,
\.** *:, *, , 'c." '*',*. '*,r-;;-. , 1 _ - ~
. SR 3*.*8.1".3* ' * ',. :
This Surveillance verifies thatthe* bGs are capable of synchronizing with the offsite electrical system *an ct*accepting loads approximating the design rating of the DGs: A minimum run tinie of 60 minutes is requ ired to stabilize
. engine temperatures, Wt-lile m-iriimi:Zing the time that the DG is connected to the offsite *source. * * ** -* *, * : *-
. '*. ,.} '
Although nci power factor requireme*nts are established by this SR , the DG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while the 1.0 is a physical limitation. The load band is provided to avoid routine overloading of the DG . Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The J1 day Frequency for this Surveillance is eonsistent with Regulatory G"ide 1.9 (Rel. 7). ~ERT 31 (continued) HBRSEP Unit No. 2 B 3.8-13 Revision No. G
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1 .3 (continued) REQUIREMENTS This SR is modified by five Notes. Note 1 indicates that diesel engine runs for this Surveillance may include gradual loading , as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 2 states that momentary transients , because of changing bus loads, do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. Note 3 indicates that this Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations . Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DG start must precede this test to credit satisfactory performance. Note 5 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus . This reduces exposure of the DG to undue risk of damage that might render it inoperable. SR 3.8.1.4 This SR provides verification that the level of fuel oil in the day tank is at or above the level at which fuel oil is automatically added . The level specified is 140 gallons , which is approximately equal to 1/2 full , and is selected to ensure adequate fuel oil for a minimum of 35 minutes of DG operation at full load plus 10%. The a1 day Frequency is adequate to assure that a sufficient supply of fuel oil is available, since low level alarms are provided and facility operators
,..,ould be a,Nare of any large uses of fuel oil during this period . ,
SR 3.8.1.5 ~ Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling , but all must have a water environment in order to survive. Removal of water from the fuel oil day tanks once every a1 days eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling . In addition , it eliminates the potential for water entrainment in the fuel oil during DG operation . Water may (continued) HBRSEP Unit No. 2 B 3.8-14 Revision No. Q
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.5 (continued) REQUIREMENTS come from any of several sources, including condensation , ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system . The Surveillance r"requencies are established by Regu latory Guide 1.137 (Ref. 6) . This SR is for preventative maintenance. he presence of water does not necessarily represent failure of this provided the accumulated water is removed during the performanc of this Surveillance. INSERT 3 SR 3.8.1.6 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from the storage tank to its associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed , and the controls and control systems for automatic fuel transfer systems are OPERABLE. The frequency of 31 days is based on the design of fuel transfer system. The pumps operate automatically in order to maintain an adequate volume of fuel oil iR !Re Elay laRks El"riRg or foll&WiRg EJG lesliRg. ~ERT I 3 SR 3.8.1 .7 See SR 3.8.1 .2. SR 3.8.1.8 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which , if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG load (continued) HBRSEP Unit No. 2 B 3.8-15 Revision No. 0
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1 .8 (continued) REQUIREMENTS response characteristics and capability to reject the largest single load without exceeding the overspeed trip. For this unit, the single load for each DG is a safety injection pump rated at 380 Brake Horsepower. This Surveillance may be accomplished by:
- a. Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus; or
- b. Tripping its associated single largest post-accident load with the DG solely supplying the bus.
The 18 month Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 8) . ~INSERT 3 1 This SR is modified by two Notes. The reason for Note 1 is that during operation with the reactor critical , performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and , as a result, unit safety systems. In order to ensure that the DG is tested under load conditions that are as close to design basis conditions as possible, Note 2 requires that, if synchronized to offsite power, testing must be performed using a power factors; 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience. SR 3.8.1.9 This Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source . This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time. The DG autostart time of 10 seconds is derived from requirements of the accident analysis to respond to a design (continued) HBRSEP Unit No. 2 B 3.8-16 Revision No. G
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.9 (continued) REQUIREMENTS basis large break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability is achieved . The requirement to verify the connection and power supply of permanent and auto connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, emergency Core Cooling Systems (ECCS) injection valves are not required to be stroked open, or high pressure injection systems are not capable of being operated at full flow, or residual heat removal (RHR) systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG systems to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified .
+he frequensy of 18 months takes into sonsideration unit sonditions required to perform the Surveillanse, and is intended to be sonsistent with expested fuel sysle lengths. ~
This SR is modified by three Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing . For the purpose of this testing , the DGs must be started from standby conditions , that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus. This reduces exposure of the DG to undue risk of damage that might render it inoperable. (continued) HBRSEP Unit No. 2 B 3.8-17 Revision No. G
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.10 REQUIREMENTS (continued) This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates for~ 5 minutes. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application . This period may extend beyond the 1O second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR, HBRSEP Unit No. 2 will monitor and trend the actual time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.1 O.d and SR 3.8.1.1O.e ensure that permanently connected loads and emergency loads are energized from the offsite electrical power system on an ESF signal without loss of offsite power. The requirement to verify the connection of permanent and autoconnected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation . For instance, ECCS injection valves are not required to be stroked open , or high pressure injection systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation . In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential , overlapping , or total steps so that the entire connection and loading sequence is verified . The Frequency of 18 months takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with the mEpected fue l cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the (continued) HBRSEP Unit No. 2 B3.8-18 Revision No. G
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1 .1~ (continued) REQUIREMENTS 18 month frequency. Therefore, the frequency was concluded to be acceptable from a reliability standpoint. ~ This SR is modified by three Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing . For the purpose of this testing , the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that during operation with the reactor critical , performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and , as a result, unit safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus . This reduces exposure of the DG to undue risk of damage that might render it inoperable. SR 3.8.1.11 This Surveillance demonstrates that DG noncritical protective functions (e.g., high coolant water temperature) are bypassed . A manual switch is provided which bypasses the non-critical trips. The noncritical trips are normally bypassed during DBAs and provide an alarm on an abnormal engine condition . This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG . This SR is satisfied by simulating a trip signal to each of the non-critical trip devices and observing the DG does not receive a trip signal. The 24 month frequency is based on engineering judgment and is intended to be consistent with DG maintenance interval. The equipment being tested is a manually operated switch . Therefore, frequency was soasluEleEI lo be asse~lable lrom a reliabilily slaREl~oiRI. ~ R T I 3 ( continued) HBRSEP Unit No. 2 B 3.8-19 Revision No. ~
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.12 REQUIREMENTS This SR requires demonstration once per 18 months that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours, ~ 1. 75 hours of which is at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG . The DG start shall be a manually initiated start followed by manual syncronization with other power sources. Additionally, the DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup , discussed in SR 3.8.1.2, and for gradual loading , discussed in SR 3.8.1.3, are applicable to this SR. In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a power factor of !5: 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience. The load band is provided to avoid routine overloading of the DG . Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The 18 month rrequency takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. ~ This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the power factor limit will not invalidate the test. The reason for Note 2 is that during operation with the reactor critical , performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and , as a result, unit safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus. (continued) HBRSEP Unit No. 2 B 3.8-20 Revision No. 30
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.12 (continued) REQUIREMENTS This reduces exposure of the DG to undue risk of damage that might render it inoperable. SR 3.8.1.13 This Surveillance demonstrates that the diesel engine can restart from a hot condition , such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 1O seconds. The 10 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed . This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application . This period may extend beyond the 1O second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR, HBRSEP Unit No. 2 will monitor and trend the actual time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 18 month r"requency is based on engineering joogment and is intended to be consistent with expected fuel cycle lengths. , This SR is modified by two Notes. Note 1 ensures that the test is ~ performed with the diesel sufficiently hot. The load band is provided to avoid routine overloading of the DG . Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The requirement that the diesel has operated for at least 2 hours at full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing . (continued) HBRSEP Unit No. 2 B 3.8-21 Revision No. G
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.14 REQUIREMENTS (continued) Under accident and loss of offsite power conditions, loads are sequentially connected to the bus by the automatic load sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents . The
+/- 0.5 seconds load sequence time setpoint tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equ ipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses.
The Frequency of 18 months takes into consideration unit conditions required to perform the Surveillance , and is intended to be consistent with expected fuel cycle lengths. ~ This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system , and challenge safety systems. SR 3.8.1.15 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel , RCS , and containment design limits are not exceeded . This Surveillance demonstrates the DG operation , as discussed in the Bases for SR 3.8.1.9, during a loss of offsite power actuation test signal in conjunction with an ESF actuation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential , overlapping , or total steps so that the entire connection and loading sequence is verified . The Frequency of 18 months takes into consideration unit conditions required to perform the SuF\1eillance and is intended to be consistent with aa e*~esle<l l<lel sysle leagtR at 18 meatlls. ~ R T I 3 (continued) HBRSEP Unit No. 2 B 3.8-22 Revision No. Q
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.15 (continued) REQUIREMENTS This SR is modified by three Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing . For the purpose of this testing , the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations for DGs. The reason for Note 2 is that the performance of the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system , and challenge safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus. This reduces exposure of the DG to undue risk of damage that might render it inoperable. SR 3.8.1.16 Transfer of the 4.160 kV bus 2 power supply from the auxiliary transformer to the start up transformer demonstrates the OPERABILITY of the offsite circuit network to power the shutdown loads. In lieu of actually initiating a circuit transfer, testing that adequately shows the capability of the transfer is acceptable. This transfer testing may include any sequence of sequential , overlapping , or total steps so that the entire transfer sequence is verified . The 18 month Frequenoy is based on engineering judgement taking into oonsideration the plant oonditions required to perform the Surveillance, and is intended to be oonsistent with expeoted fuel oyole length. ~ This SR is modified by two Notes. The reason for Note 1 is that, during operation with the reactor critical , performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. As stated in Note 2, automatic transfer capability to the SUT is not required to be met when the associated 4.160 kV bus and Emergency Bus are powered from the SUT. This is acceptable since the automatic transfer capability function has been satisfied in this condition . (continued) HBRSEP Unit No. 2 B 3.8-23 Revision No. Q
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1 .17 REQUIREMENTS (continued) This Surveillance demonstrates that the DG starting independence has not been compromised . Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the DGs are started simultaneously. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed . This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application . This period may extend beyond the 10 second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR , HBRSEP Unit No. 2 will monitor and trend the actual time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 10 year Frequency is based on engineering judgment. ~ This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing . For the purpose of this testing , the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. REFERENCES 1. UFSAR, Section 3.1.
- 2. UFSAR , Chapter 8.
- 3. UFSAR, Chapter 6.
- 4. UFSAR, Chapter 15.
- 5. Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," July 2, 1984.
- 6. Regulatory Guide 1.137, Rev. 1, October 1979.
(continued) HBRSEP Unit No. 2 B 3.8-24 Revision No. 0
AC Sources - Operating B 3.8.1 BASES REFERENCES 7. Regulatory Guide 1. 9, Rev. 3, July 1993. (continued) Regulatory Guide 1.108, Rev. 1, August 1977. !Deleted .!
- 9. Regulatory Guide 1.93 , Rev. 0, December 1974.
HBRSEP Unit No. 2 B 3.8-25 Revision No. 0
Diesel Fuel Oil and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.1 (continued) REQURIEMENTS The 7 day Frequency is adequate to ensure that a sufficient supply of fuel oil is a1.iailable, since low level alarms are provided for the U2 DG fuel oil tank and unit operators would be aware of any large uses of fuel oil au,ia~ tllis pefiod. ~ERT I 3 SR 3.8.3.2 The tests listed in the Diesel Fuel Oil Testing Program (API or Specific Gravity, Cloud Point, Water and Sediment, and Viscosity) are a means of determining whether fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion . If results from these tests are within acceptable limits, the fuel oil is acceptable for use. New fuel oil received for storage in the Unit 1 1-C turbine fuel oil storage tank and subsequently transferred to the Unit 2 DG fuel oil storage tank is verified to meet the limits below prior to adding to the Unit 1 1-C storage tanks either by verifying the integrity of the seal on the tank truck against the certificate of compliance or by testing of the fuel oil on the truck prior to transfer. Additionally, stored fuel in the Unit 1 1-C storage tank and in the Unit 2 DG fuel oil storage tank is tested every 31 days. The sampling methodology, tests, and limits are as follows:
- a. Sampling of three vertical IC Turbine tanks is performed as a single entity by recirculating the tanks and sampling at the Unit 1 transfer pump discharge. Sampling of the remaining vertical Unit 1 tank is performed independently from the bottom drain connection . Sampling of the Unit 2 DG fuel oil storage tank is performed from the discharge from the fuel oil storage tank transfer pump (Ref.3); and
- b. Verify in accordance with applicable ASTM standards that the sample has an API gravity of:::: 28, a Saybolt viscosity at 100°F of
- 32 SUS and s 50 SUS , water and sediment s 0.10%, and cloud points 10°F.
Failure to meet any of the limits except cloud point is cause for rejecting the fuel oil. Cloud point will be managed by the Diesel Fuel Oil Testing Program . (continued) HBRSEP Unit No. 2 B 3.8-36 Revision No. ea
Diesel Fuel Oil and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.3 REQUIREMENTS (continued) This Surveillance ensures that, without the aid of the refill compressor, sufficient air start capacity for each DG is available. The system design requirements provide for a minimum of eight engine start cycles without recharging . The pressure specified in this SR is intended to reflect the lowest value at which the eight starts can be accomplished . The 31 day rrequency takes into account the capacity, capability, redundancy, and diversity of the /\C sources and other indications available in the control room, including alarms, to alert the operator to below aarmal air start press"re. ~RT I 3 SR 3.8.3.4 Microbiological fouling is a major cause of fuel oil degradation . There are numerous bacteria that can grow in fuel oil and cause fouling , but all must have a water environment in order to survive. Removal of water from the Unit 2 DG fuel storage tank once e¥ery 31 days eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling . In addition , it eliminates the potential for water entrainment in the fuel oil during DG operation . Water may come from any of several sources, including condensation , ground water, rain water, and contaminated fuel oil , and from breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. This SR is for preventive maintenance. The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during performance of the Surveillance. ~ - - - - - - - -- ----=! - _INSERT 3 1-- I - - - - - - - - - -- - REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
- 3. CP&L Letter to NRC dated November 20, 1981 , "Quality Assurance Requirements Regarding Diesel Generator Fuel Oil."
HBRSEP Unit No. 2 B 3.8-37 Revision No. G
DC Sources - Operating 8 3.8.4 ACTIONS 8.1 and 8 .2 (continued) required unit conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function . Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery (or battery cell) and maintain the battery (or a battery cell) in a fully charged state. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the initial voltages assumed in the battery sizing calculations and permit a single battery cell to be jumpered out. The 7 day frequency is consistent with manufacturer recommendations and IEEE 450 (Ref. 5) . ~.----'----.
~RT3l SR 3.8.4.2 Visual inspection of the battery cells , cell plates, and battery racks provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance.
The 18 month frequency is based on engineering judgment and operational experience and is sufficient to detect battery and rack 8egra8atiea ea a leag term Basis. [Ns'ERT I 3 SR 3.8.4.3 Visual inspection of intercell, intertier, and terminal connections provide an indication of physical damage or abnormal deterioration that could indicate degraded battery condition . The anticorrosion material is used to help ensure good electrical connections and to reduce terminal deterioration. The visual inspection for corrosion is not intended to require removal of and inspection under each (continued) H8RSEP Unit No. 2 8 3.8-42 Revision No. 0
DC Sources - Operating B 3.8.4 SURVEILLANCE SR 3.8.4.3 (continued) REQUIREMENTS term inal connection. The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR provided visible corrosion is removed during performance of SR 3.8.4.3. The 18 month frequency is based on engineering judgment taking into consideration the likelihood of a change in component or system status. IT:ERT3! SR 3.8.4.4 This SR requires that each battery charger be capable of supplying 300 amps and 125 V for 2!: 4 hours. These current and voltage requ irements are based on the design capacity of the chargers. The battery charger supply is based on normal DC loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state. The minimum required amperes and duration ensures that these requirements can be satisfied . The Surveillance rrequency is acceptable, gii.1en the other administrati*,e controls existing to ensure adequate charger performance during these 18 month intervals. In addition , this rrequency is intended to be ooasisteat witR expeste8 fuel oy,;le lea9tRs. ~ERT I 3 SR 3.8.4 .5 A battery service test is a special test of battery capability, as found , to satisfy the design requirements (battery duty cycle) of the DC electrical power system . The discharge rate and test length should correspond to the design duty cycle requirements. !INSERT 3 !i-----+) This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test. (continued) HBRSEP Unit No. 2 B 3.8-43 Revision No. 29
DC Sources - Operating B 3.8.4 SURVEILLANCE SR 3.8.4.6 (continued) REQUIREMENTS The acceptance criteria for this Surveillance are consistent with IEEE-450 (Ref. 5) . This reference recommends that the battery be replaced if its capacity is below 80% of the manufacturer's rating . A capacity of 80% shows that the battery rate of deterioration is increasing , even if there is ample capacity to meet the load requirements. An acceptance criterion of 80% of rated capacity is applicable to the "A" battery only. An acceptance criterion of 91 % is applicable to the "B" battery since the battery's capacity is not as great. The 5urveillanse Frequensy for this test is normally 60 months. If the battery shows degradation , or if the battery has reashed 85% of its expested life with sapasity < 100% of manufasturer's rating , the 5urveillanse Frequensy is redused to 12 months. Degradation is indisated , assording to IEEE 450 (Ref. 5) , when the battery sapasity drops by more than 10% relative to its average on the previous performanse tests or when it is> 10% below the manufasturer's rating . Hovt'ever, if the battery shows no degradation but has reashed 85% of its expested life, the 5urveillanse Frequensy is only redused to 24 months for batteries that retain sapasity ~ 100% of the manufasturer's ratings. These Frequensies are sonsistent with the resommendations in IEEE 450 (Ref. 5) . ~ This SR is modified by a Note. The reason for the Note is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems . REFERENCES 1. UFSAR Section 3.1.
- 2. UFSAR, Chapter 8.
- 3. UFSAR, Chapter 6.
- 4. UFSAR, Chapter 15.
- 5. IEEE-450- 1995.
HBRSEP Unit No. 2 B 3.8-45 Revision No. ~
Battery Cell Parameters B 3.8.6 BASES ACTIONS A.1, A.2 , and A.3 (continued) considered reasonable. The verification is repeated at 7 day intervals until the parameters are restored to Category A or B limits. This periodic verification is consistent with the normal Frequency of pilot cell Surveillances. Continued operation is only permitted for 31 days before battery cell parameters must be restored to within Category A and B limits. With the consideration that, while battery capacity is degraded , sufficient capacity exists to perform the intended function and to allow time to fully restore the battery cell parameters to normal limits, this time is acceptable prior to declaring the battery inoperable. With one or more batteries with one or more battery cell parameters outside the Category C limit for any connected cell , sufficient capacity to supply the maximum expected load requirement is not assured and the corresponding DC electrical power subsystem must be declared inoperable. Additionally, other potentially extreme conditions, such as not completing the Required Actions of Cond ition A with in th e required Completion Time or average electrolyte temperature of representative cells falling below 67°F are also cause for immediately declaring the associated DC electrical power subsystem inoperable. SURVEILLANCE SR 3.8.6.1 REQUIREMENTS This SR verifies that Category A battery cell parameters are consistent with IEEE-450 (Ref. 3) , which recommends regular battery inspections (at least one per month) including voltage (measured to the nearest 0.01 Volts) , specific gravity, and electrolyte temperature of pilot cells. In addition , if water is added to any pilot cell , the amount must be recorded . Data attained must be compared to the data from the previous SR to detect signs of abuse or deterioration. ,
~
(continued) HBRSEP Unit No. 2 B 3.8-52 Revision No. G
Battery Cell Parameters B 3.8.6 BASES SURVEILLANCE SR 3.8.6.2 REQUIREMENTS (continued) The quarterly inspection of specific gravity and voltage is consistent with
~:e-4.:~ ~~ ~ ln addition , within 24 hours of a battery discharge
< 11 O V or a e overcharge > 150 V, the battery must be demon ed to meet Category B limits. Transients , which may entarily cause battery voltage to drop to s 110 V, do not constitute a battery discharge provided the battery terminal voltage and float current INSERT 3 return to pre-transient values . This inspection is also consistent with IEEE-450 (Ref. 3) , which recommends special inspections following a severe discharge or overcharge, to ensure that no significant degradation of the battery occurs as a consequence of such discharge or overcharge.
If water is added to any battery cell , the amount must be recorded . Data obtained must be compared to the data from the previous SR to detect signs of abuse or deterioration. SR 3.8.6.3 This Surveillance verification that the average temperature of representative cells is ~ 67°F is consistent with a recommendation of IEEE-450 (Ref. 3) , that states that the temperature of electrolytes in representative cells should be determined on a quarterly basis. Data obtained must be compared to the data from the previous SR to detect signs of abuse or deterioration. Lower than normal temperatures act to inhibit or reduce battery capacity. This SR ensures that the operating temperatures remain within an acceptable operating range. This limit is based on manufacturer recommendations.
!INSERT 31--!- )
Table 3.8.6-1 This table delineates the limits on electrolyte level , float voltage, and specific gravity for three different categories. The meaning of each category is discussed below. Category A defines the normal parameter limit for each designated pilot cell in each battery. The cells selected (continued) HBRSEP Unit No. 2 B 3.8-53 Revision No. Q
AC Instrument Bus Sources - Operating B 3.8.7 BASES ACTIONS B.1 and B.2 (continued) 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and associated AC instrument buses energized from the Inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation of the RPS and ESFAS connected to the AC instrument buses. The 7 day F"requency takes into account the redundant capability of the Instrument Bus Sources and other indications available in the control room that alert the operator to inverter malfunolions. [Nsf:RT I 3 SR 3.8.7.2 This surveillance verifies that the required circuit breakers are closed and the associated instrument buses energized from the CVTs. Actual measurement of voltage is not required . Confirmation that the buses are energized by observing status lights, instrument displays, etc., is sufficient to confirm the instrument buses are energized. The 7 day frequency takes into account the redundant capability of the AC instrument bus sources and administrative requirements governing alignment of eleotrioal eq"i~ment. ~s'ERT I 3 REFERENCES 1. UFSAR, Chapter 6.
- 3. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.8-60 Revision No. G
AC Instrument Bus Sources - Shutdown B 3.8.8 BASES ACTIONS A.1, A.2 .1, A.2 .2, A.2.3 , and A.2.4 (continued) The Completion Time of immediately is consistent with the required times for actions requiring prompt attention . The restoration of the required AC Instrument Bus Sources should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a non-preferred source. SURVEILLANCE SR 3.8.8 .1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and required AC instrument buses energized from the inverter and that required circuit breakers are closed and required instrument buses are energized from the CVTs or other sources, as allowed by LCO 3.8.8.b. The verification of proper voltage and frequency output for the inverters ensures that the required power is readily available for the instrumentation connected to the associated AC instrument buses. The 7 day Frequency takes into account the redundant capability of the AC Instrument Bus gources, other indications available in the control room that alert the operator to inverter malfunctions , and administrative requirements governing alignment of electrical equipment. ~INSERT 3! This SR is modified by a Note which states that voltage and frequency measurement is not required for the AC instrument buses supplied from CVTs. For these buses , observing status lights, instrument displays, etc. is sufficient to confirm that the required power is readily available to the AC instrument buses supplied from CVTs REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.8-64 Revision No. e,4e Amendment No. 4QQ
Distribution Systems - Operating B 3.8.9 BASES ACTIONS F.1 and F.2 (continued) If the inoperable distribution subsystem cannot be resto red to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable , based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. With two trains with inoperable distribution subsystems that result in a loss of safety function , adequate core cooling , containment OPERABILITY and other instrument functions for OBA mitigation would be compromised , and immediate plant shutdown in accordance with LCO 3.0.3 is requi red . SURVEILLANCE SR 3.8.9.1 REQUIREMENTS This Surveillance verifies that the required AC , DC, and AC instrument bus electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained , and the appropriate voltage is available to each required bus. The 7 day Frequency takes into account the redundant capability of the AC , DC, and AC instrument bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions. ~ This SR is modified by a Note which states that Voltage measurement is not required for the AC Instrument buses supplied from Constant Voltage Transformers (CVTs) . For these buses confirmation that the buses are energized by observing status lights, instrument displays, etc., is sufficient to confirm the buses are energized . (continued) HBRSEP Unit No. 2 B 3.8-75 Revision No. Q
l Distribution Systems - Operating B 3.8.9 BASES SURVEILLANCE SR 3.8.9.2 and SR 3.8.9.3 REQUIREMENTS (continued) The two breakers associated with each ABT will trip on over current as required to prevent fault from affecting both trains of the AC Distribution System . The 18 month Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions desirable for performing the Surveillance, and is intended to be consistent with mcpected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency. Therefore the Frequency was concluded to be acceptable from a reliability standpoint. ~ - - - - -- -- - - - ----=J ------1_INSERT 4 ,_ REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
- 3. SER for HBRSEP Unit No. 2 Amendment 123, dated Sept. 5, 1989
- 4. Regulatory Guide 1.93, December 1974.
HBRSEP Unit No. 2 B 3.8-76 Revision No. Q
Distribution System - Shutdown B 3.8.10 BASES ACTIONS A.1, A.2.1, A.2.2, A.2 .3, A.2.4, and A.2 .5 (continued) Therefore, Required Action A.2.5 is provided to direct declaring RHR inoperable, which results in taking the appropriate RHR actions. The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power. SURVEILLANCE SR 3.8.10.1 REQUIREMENTS This Surveillance verifies that the AC, DC, and AC instrument bus electrical power distribution subsystems are functioning properly, with all the buses energized . The 7 day Frequency takes into account the capability of the electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions. ~ This SR is modified by Note which states that voltage measurement is not required for the AC Instrument buses supplied from Constant Voltage Transformers (CVTs) . For these buses confirmation that the buses are energized by observing status lights, instrument displays, etc., is sufficient to confirm the buses are energized. REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.8-81 Revision No. ~ Amendment No. 4W
Boron Concentration B 3.9.1 BASES ACTIONS A.3 (continued) the operator should begin boration with the best source available for unit conditions. Once actions have been initiated , they must be continued until the boron concentration is restored . The restoration time depends on the amount of boron that must be injected to reach the requ ired concentration . SURVEILLANCE SR 3.9.1 .1 REQUIREMENTS This SR ensures that the coolant boron concentration in the RCS , the refueling canal , and the refueling cavity is within the COLR lim its. The boron concentration of the coolant in each volume is determined periodically by chemical analysis . A minimum frequency of once every 72 hours is a reasonable amount of time to verify the boron concentration of representative samples. The frequency is based on operating e*perience, which has shown 72 hours to be adequate. ~ INSERT 3 I REFERENCES 1. UFSAR, Section 3.1.
- 2. UFSAR, Chapter 15.
HBRSEP Unit No. 2 B 3.9-4 Revision No. Q,4e Amendment No. 49G
Nuclear Instrumentation B 3.9.2 BASES SURVEILLANCE SR 3.9.2.1 REQUIREMENTS SR 3.9.2.1 is the performance of a CHANNEL CHECK, which is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that the two indication channels should be consistent with core conditions. Changes in fuel loading and core geometry can result in significant differences between source range channels , but each channel should be consistent with its local conditions. The Frequency of 12 hours is consistent with the CH/1.f!.lNEL CHECK FrReq"""GY spesifie~ similarly for tile same iRstF<1meats iR LGO 3.3.1. ~ERT :I 3 S 3.9.2.2 SR 3.9.2 .2 is the performance of a CHANNEL CALIBRATION evefJf 18 months. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the source range neutron flux monitors consists of obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. The CHANNEL CALIBRATION for the PAM source range neutron flux monitors only applies to the portion of the channel applicable to providing visual indication of neutron count rate in the Control Room. T-Re 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage. Operating e*perience has shown these components usually pass the Surveillance when performed at the 18 month Frequency. ~ - - - - - - - - - - - - - - - - - - -----=:i - _lNSERT 3 I,_- - - REFERENCES 1. UFSAR, Section 3.1.
- 2. UFSAR, Section 15.4.6.
HBRSEP Unit No. 2 B 3.9-7a Revision No. 5, 16, 17, 18 Amendment No. 180, 1QO
Containment Penetrations B 3.9.3 BASES (continued) APPLICABILITY for the limitting fuel handling accident. In MODES 1, 2, 3, (continued) and 4, containment penetration requirements are addressed by LCO 3.6.1. In MODES 5 and 6, when movement of irradiated fuel assemblies within containment is not being conducted, the potential for a fuel handling accident does not exist. Additionally, due to radioactive decay, a fuel handling accident involving handling fuel that was not recently irradiated (i.e., fuel that has not occupied part of a critical reactor core within the previous 116 hours) will result in doses that are well within the guideline values specified in 10 CFR 50.67 even without containment closure capability. Therefore, under these conditions no requirements are placed on containment penetration status. ACTIONS If the containment equipment hatch, air lock, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere is not in the required status, including the Containment Ventilation Isolation System not capable of automatic actuation when the containment ventilation valves are open , the unit must be placed in a condition where the isolation function is not needed. This is accomplished by immediately suspending movement of recently irradiated fuel asse.mblies within containment. Performance of these actions shall not preclude completion of movement of a component to a safe position. SURVEILLANCE SR 3.9.3.1 REQUIREMENTS This Surveillance demonstrates that each of the containment penetrations required to be in its closed position is in that position . The Surveillance on the open ventilation valves will demonstrate that the valves are not blocked from closing. Also the Surveillance will demonstrate that each valve operator has motive power, which will ensure that each valve is capable of being closed by an OPERABLE automatic containment ventilation isolation signal. The Surveillance is performed e'1ery 7 days during mo¥ement of recently irradiated fuel assemblies within containment. This Surveillance ensures that a postulated fuel handling (continued) HBRSEP Unit No. 2 B 3.9-11 Revision No. -73
Containment Penetrations B 3.9.3 BASES SURVEILLANCE SR 3.9.3.1 (continued) REQUIREMENTS *
- Accident involving handling recently irradiated fuel that releases fission product radioactivity within the containment will not -result in a significant release of fission product radioactivity to the environment. ~
. -- ~
SR
- 3.9.3,2 This Surveillance demonstrates that each containment ventilation valve actuates to its isolation position' on manual initiation or on an actual or simulated high radiation signal. The 18 month frequency maintains consistency with other similar instrumentation and valve testing requirements. In LCO 3.3.6, the Containment Ventilation Isolation instrumentation requires a CHANNEL CHECK e11ery 12 hours and a COT
- every 92 days to ensure the channel G"P ERABILITY during refueling operations. Every 18 months a CHANNEL* CALIBRATION is performed .
Tne system actuation response tirtie is demonstrated every 18 months, during.. refueling , oh a STAGGERED' TEST BASIS . -SR 3.6.3 .5
-demonstrates th'a t the isolatioh time ofeacti valve\ s in accordance with the lnserv"ice Testing Program requirements. These Surveillances
*, '* *performed during MODE 6 'will ensure*that the valves are capable of
*, closing after*a postulated-'fue1 handlr-ng accident involving handling
\ ;. \ ecehtly irradiated fuel -to limit'a' (elease of fission product radioactivity from the containment. ~
* ~ INSERT 3 !1----- - - - - - - -
REFERENCES 1. UFSAR, Section 15.7.4. HBRSEP Unit No. 2 B 3.9-12 Revision No. ~
RHR and Coolant Circulation - High Water Level B 3.9.4 BASES ACTIONS (continued) If RHR train requirements are not met, actions shall be initiated and continued in order to satisfy RHR train requirements. With the unit in MODE 6 and the refueling water level ~ 23 ft above the top of the reactor vessel flange , corrective actions shall be initiated immediately. A.4 If RHR train requirements are not met, all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere must be closed within 4 hours. With the RHR train requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Closing containment penetrations that are open to the outside atmosphere ensures dose limits are not exceeded . The Completion Time of 4 hours is reasonable, based on the low probability of the coolant boiling in that time. SURVEILLANCE SR 3.9.4.1 REQUIREMENTS This Surveillance requires verification every 12 hours that one train is in operation. Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. The Frequency of 12 hours is sufficient, considering the other indications and alarms available to the operator in the control room for monitoring the RHR System . ~ INSERT 31 REFERENCES 1. UFSAR, Section 5.4.4. HBRSEP Unit No. 2 B 3.9- 16 Revision No. G;-4e Amendment No. 49G
RHR and Coolant Circulation - Low Water Level B 3.9.5 BASES (continued) SURVEILLANCE SR 3.9.5.1 REQUIREMENTS This SR requires verification e11ery 12 hours that one train is in operation. Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. :+Re F'requency of 12 hours is sufficient considering other indications and alarms available to the operator in the control room to monitor Rl9R train
~elformaRGe. [NsERT I 3
SR 3.9.5.2 Verification that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation , if needed , to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pump. The F'requency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating mcperience. ~
----=J
----1_INSERT 31- - - - -
REFERENCES 1. UFSAR, Section 5.4.4. HBRSEP Unit No. 2 B 3.9-20 Revision No. G,4-& Amendment No.-1-QG
Refueling Cavity Water Level B 3.9.6 BASES (continued) SURVEILLANCE SR 3.9.6.1 (continued) REQUIREMENTS The rrequency of 24 hours is based on eng ineering judgment and is considered adequate in view of the large volume of water and the normal procedural controls of valve positions, which make significant unplanned level changes unlikely. ~ REFERENCES 1. UFSAR, Section 15.7.4.
- 2. 10 CFR 50.67.
- 3. Regulatory Guide 1.183.
HBRSEP Unit No. 2 B 3.9-23 Revision No. ~
Containment Purge Filter System B 3.9.7 BASES ACTIONS A.1and A.2 (continued) closed . Closure may be achieved by a closed manual or automatic valve , blind flange , or equivalent method . Equivalent closure methods must be approved and may include use of a material that can provide a temporary atmospheric pressure, ventilation barrier for the penetration during fuel movements. Alternately, Required Action A.2 may be taken to place the unit in a condition in which the LCO does not apply. Required Action A.2 requires immediate suspension of movement of recently irradiated fuel assemblies in containment. Suspension of this activity does not preclude the movement of fuel to a safe position . SURVEILLANCE SR 3.9.7.1 REQUIREMENTS This SR verifies that the relative humidity of the containment atmosphere to be processed by the Containment Purge Filter System is ~ 70%. This ensures that the testing performed to validate the safety analysis assumptions relative to charcoal filter efficiency, bounds actual plant conditions for relative humidity at the inlet of the Containment Purge Filter System charcoal filter. The one hour Frequency is based on engineering judgment considering the likelihood of changes in containment relative A*R'lidily d*Fing Fel*eling **lages. ~ERT I 3 SR 3.9.7.2 This SR verifies that the Containment Purge Filter System is in operation and maintaining containment pressure negative relative to the adjacent auxiliary building areas once every 12 hours. This verification ensures that containment pressure is being maintained negative with respect to the outside atmosphere since the pressure of the auxiliary building areas is normally maintained negative with respect to the outside atmosphere. The Containment Purge Filter (continued) HBRSEP Unit No. 2 B 3.9-26 Revision No. ~
Containment Purge Filter System B 3.9.7 BASES SURVEILLANCE SR 3.9.7.2 (continued) REQUIREMENTS System is assumed to maintain a slight negative pressure in the
- containment, to prevent unfiltered leakage to the outside atmosphere.
The Frequency of 12 hours is sufficient considering other indications ai.ia+lable to the operator to monitor Containment Purge Filter System o~eratioa. s:ERT j 3 SR 3.9.7.3 This SR verifies that the required Containment Purge Filter System filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP) . The VFTP includes testing HEPA filter performance , charcoal adsorber efficiency, system flow rate, and the physical properties of the activated charcoal (general use and following specific operations) . Specific test frequencies and additional information are discussed in detail in the VFTP . REFERENCES 1. UFSAR, Section 6.5.1.
- 2. UFSAR, Section 9.4.3.
- 3. UFSAR, Section 15.7.4 .
- 4. 10 CFR 50.67.
HBRSEP Unit No. 2 B 3.9-27 Revision No. ~ to RNP-RA/18-0015 Page 1 ATTACHMENT 5 License Amendment Request H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP) Docket No. 50-261 Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3) TSTF-425 (NUREG-1431) vs. HBRSEP Cross-Reference to RNP-RA/18-0015 Page 2 Technical Specification Section Title/Surveillance Description* TSTF-425 HBRSEP Definitions 1.1 1.1 Staaaered Test Testing Shutdown Margin (SDM) 3.1.1 3.1.1 Verify SOM within limits 3.1.1 .1 3.1.1.1 Core Reactivity 3.1.2 3.1.2 Verify core reactivity within predicted values ' 3.1.2.1 3.1 .2.1 Rod Group Alignment Limits 3.1.4 3.1.4 Verify inidividual rod positions within aliqnment limit 3.1.4.1 3.1.4.1 Verify rod freedom of movement (trippability) 3.1.4.2 3.1.4.2 Shutdown Bank Insertion Limits 3.1.5 3.1.5 Verify shutdown bank within insertion limits specified in COLR 3.1.5.1 3.1.5.1 Control Bank Insertion Limits 3.1.6 3.1.6 Verify cohtroi bank is within the insertion limits specified in COLR 3.1.6.2 3.1.6.2 Verify sequence and overlap limits specified in COLR 3.1.6.3 3.1.6.3 PHYSICS TESTS Exceptions - MODE 2 3.1.8 3.1.8 Verify RCS lowest loop averaQe temperature 3.1.8.2 3.1.8.2
' Verify thermal power 3.1.8.3 3.1.8.3 Verify SOM within limits specified in COLR 3.1.8.4 3.1.8.4 Heat Flux Hot Channel Factor (FQ(Z)) (CAOC-Fxv Methodology) 3.2.1A ---------
Verify° measured values of F0 (Z) 3.2.1 .1 --------- Verify F\v < FLxv 3.2.1 .2 ---------
- Heat Flux Hot .Channel Factor (FQ(Z)) (RAOC-W(Z) Methodology}
- 3.2.1.B u o ****** **
Verify Fac(Z) is within limit 3.2.1.1 ------- Verify F0 w(Z) within limit 3.2.1.2 --------- Heat Flux Hot Channel Factor (FQ(Z)) (CAOC-W(Z) Methodolog}'.} 3.2.1C 3.2.1 Verify F0 c(Z) is within limit 3.2:1 .1 -~------- Verify F0 w(Z) within limit (NOTE: HBRSEP*uses the nomenclature F0 v(Z), which is equivalent) 3.2.1 .2 3.2.1.1 to RNP-RA/18-0015 Page 3 Nuclear Enthalpy Rise Hot Channel Factor (FN AH) 3.2.2 3.2.2 Verify FN t.H within limits specified in COLR 3.2.2.1 3.2.2.1 AXIAL FLUX DIFFERENCE (AFD) (Constant ~ial Offset Contro.1-(CAOC) Methodology) 3.2.3A 3.2.3 Verify AFD is within limits - - 3.2.3.1 3.2.3.1 Update target flux difference 3.2.3.2 ------ Determine, by measurement, target flux difference 3.2.3.3 3.2.3.3 AXIAL FLUX DIFFERENCE (AFD).(Relaxed Axial OffsetContro"(RAOC) Methodology) 3.2.38 - Verify AFD is within limits 3.2.3.1 --------- QUADRANT POWER TILT RATIO (QPTR) 3.2.4 3.2.4 Verify QPTR is within limit by calculation ,. 3.2.4.1 3.2.4.1 Vedfy :a PTR is within limit using movable incore detectors ' 3.2.4.2 3.2.4.2 Reactor Trip System CRTS) Instrumentation (Reactor Protection System Instrumentation for HBRSEP) 3.3.1 3.3.1 Perform CHANNEL CHECK 3.3.1 .1 3.3.1 .1 Compare calorimetric to power range (i.e.~ N*uclear Instrumentation System) channel output 3.3.1.2 3.3.1.2 Compare results of incore detector measurements to NIS AFD 3.3.1.3 3.3.1.3
;,- *,
- i ;.. '
- Perform T ADOT 3.3.1.4 3.3.1.4 Perform ACTUATION LOGIC TEST ' - -* ,,
- 3.3.1 .5 3.3.1.5 Calibrate excore* channels to agree with incore detector measurements 3.3.1 .6 3.3.1.6
" ** l , ...
Perform COT 3.3.1.7 3.3.1 .7 Perform COT 3.3.1.8 3.3.1.8
~
Perform TADOT 3.3.1.9 3.3.1.9 Perform CHANNEL CALIBRATION - 3.3.1.10 3.3.1.10 Perform CHANNEL CALIBRATION (neutron detectors excluded) 3.3.1.11 3.3.1.11 Perform CHANNEL CALIBRATION (include resistance temperature detector) 3.3.1.12 3.3.1.12 Perform COT 3.3.1 .13 3.3.1.13 Perform T ADOT (verification of setpoint is not required) 3.3.1. 14 3.3.1 .14 Verify. RTS RESPONSE TIME within limits 3.3.1.16 --------- Engineered Safety Feature Actuation System (ESFAS) Instrumentation . 3.3.2 3.3.2 Perform CHANNEL CHECK 3.3.2.1 3.3.2.1 to RNP-RA/18-0015 Page4 Perform ACTUATION LOGIC TEST 3.3.2.2 3.3.2.2 Perform ACTUATION LOGIC TEST (continuit:t check ma:t be excluded) 3.3.2.3 ------- Perform MASTER RELAY TEST 3:3.2.4 3.3.2.3 Perform COT 3.3 .2.5 3.3.2.4 Perform SLAVE RELAY TEST 3.3 .2.6 3.3.2.5 Perform TADOT (verification of relay setpoints not required) 3.3.2.7 --------- Perfor111 TADOT (verification of setpoint not requ ired for manual initiation functions) 3.3.2.8 3.3.2.6 . Perform CHANNEL CALIBRATION 3.3.2.9 3.3.2.7 Verify ESFAS RESPONSE TIMES within limit 3.3.2.10 --------- Post Accident Monitoring (PAM) Instrumentation 3.3.3 3.3.3 Perform CHANNEL CHECK 3.3.3.1 3.3 .3.1 Perform CHANNEL CALIBRATION 3.3.3.2 3.3.3.2 Perform TADOT --------- 3.3.3.3 Remote Sh.utdown System 3.3.4 3.3.4 Perform CHANNEL CHECK 3.3.4.1 3.3.4.1 Verify control circuit and transfer switch is capable of performing function 3.3.4.2 3.3.4.2 Perform CHANNEL CALIBRATION 3.3.4.3 3.3.4.3 Perform TADOT (reactor trip breaker) 3.3.4.4 3.3.4.4 Loss of Power (LOP) Diesel. Generator (DG) Start Instrumentation 3.3.5 3.3.5 Perform CHANNEL CHECK 3.3.5.1 ------- Perform TADOT 3.3.5.2 3.3.5.1 Perform CHANNEL CALIBRATION 3.3.5.3 3.3.5.2 Containment Purge and Exhaust Isolation Instrumentation (Containment Ventilation Isolation Instrumentation for HBRSEP) 3.3.6 3.3.6 . Perform CHANNEL CHECK 3.3.6.1 3.3.6.1 Perform ACTUATION LOGIC TEST 3.3.6.2 3.3.6.2 Perform MASTER RELAY TEST 3.3.6.3 3.3.6.3 Perform ACTUATION LOGIC TEST (only applicable*to actuation log ic of ESFAS instrumentation) 3.3.6.4 --------- Perform MASTER *RELAY TEST *(only applicable to master relays of ESFAS instrumentation) 3.3.6.5 --------
. **.l:-**.
Perform COT 3.3.6.6 3.3.6.4 to RNP-RA/18-0015 Page 5 Perform SLAVE RELAY TEST 3.3.6.7 3.3.6.5 Perform TADOT (verification of setpoint not requ ired) *3.3.6.8 3.3.6.6 Perform CHANNE L CAU BRATION 3.3.6.9 3.3.6.7 Control Room Emergency Filtration System (CREFS) Actuation 'instrumentation 3.3.7 3.3.7 Perform CHANNE L CHECK 3 .3.7.1 3.~.7. 1 Perform COT 3.3.?.2* 3.3.7.2 Perform ACTUATION LOG IC TEST .3.-.3.7.3 3.3.7.3 Perform MASTER RELAY TEST 3'. 3.7.4 3.3.7.4 Perform ACTUATION LOGIC TEST (only ap,plicable to actuation logic-of ES FAS instrumentation) 3.3.7.5 -------- Perform MAS,TER RELAY TEST (on ly applicable to master relays of ESFAS.instrumentation) 3.3.7.6 --------- Perform SLAVE RELAY TEST * - 3.3.7.7 3.3.7.5 Perform T ADOT (verification of setpoint not requ ired) 3.3.7.8 --------- Perform CHANNEL CALIBRATION: 3.3.7.9 3.3.7.6 Fuel Building Air Cleanup System (FBACS) Actuation- Instrumentation 3.3.8 --------- Perform CHANNEL CHECK . - ,. .. *
- 3.3.8.1 -------
Perform COT 3.3.8.2 ------ Perform ACTUATION LOGIC TEST 3.3.8.3 -------- Perform TADOT (verification of setpoint not required) 3.3.8.4 ----- -- Perform CHANNEL CALIBRATION
- 3.3.8.5 ----- --
Boron Dilution Protection System (BDPS) 3.3.9 --------- _ Perform CHANNEL CHECK . i . 3.3,9.1 --------- Perform COT 3.3.9.2 -------- Perform CHANNEL CALIBRATION (neutron detectors excluded) 3.3.9.3 -------- . Auxiliary Feedwater (AFW) System Instrumentation -------- 3.3*.8 Perform CHANNEL CHECK --- - --- 3.3.8.1 Perform COT --------- 3.3.8.2 Perform T ADOT --------- 3.3.8.3 Perform CHANNEL CALIBRATION --------- 3. 3.8.4 RCS Pressure, Temperature, and flow Departure -from Nucleate Boil ing (DNB) Limits 3.4.1 3.4.1 Verify pressurizer pressure is Qreater than or equal to lim it specified in COLR 3.4.1 .1 3.4.1 .1 to RNP-RA/18-0015 Page 6 Verify RCS averaQe temperature is less than or equal to limit specified in COLR 3.4.1.2 3.4.1.2 Verify RCS total flow rate Qreater than or equal to limit specified in COLR 3.4.1.3 3.4.1 .3 Verify by precision heat balance that RCS total flow greater than or equal to limit specified in COLR 3.4.1.4 3.4.1.4 RCS Minimum Temperature for Criticality 3.4;2 3.4.2 Verify RCS average temperature in each loop ~ [541 °F] 3.4.2.1 -------- Verify RCS average temperature in each loop~ 530°F (Only required if Tave alarm is inoperabie and RCS loop Tave < 547°F) --------- 3.4.2.1 RCS Pressure and Temperature (PIT) Limits 3.4.3 3.4.3 Verify RCS pressure, temperature and heatup and cooldown rates are within appropriate limits 3.4.3.1 3.4.3.1 RCS Loops - MODES 1 and 2 3.4.4 3.4.4 Verify each RCS loop is in operation 3.4.4.1 3.4.4.1 RCS L9ops - MODE 3 3.4.5 3.4.5 Verify required RCS loops in operation .. 3.4.5.1 3.4.5.1 Verify steam Qenerator water levels 3.4.5.2 3.4.5.2 Verify Rod Control System not capable of rod withdrawal -------- 3.4.5.3 Verify reactor trio breakers are *ooen --------- 3.4.5.4 Verify lift disconnect switches *fcir control rods not fully withdrawn are open -------- 3.4.5.5 Verify SOM within limits .in COLR
-------- 3.4.5.6 Verify correct breaker aliQnment and power to pump 3.4.5.3 3.4.5.7 RCS Loops - MODE 4 3.4.6 3.4.6 Verify RHR or RCS loop in operation (RHR "train" is use_d for HBRSEP instead of "loop") _ 3.4.6.1 3.4.6.1 Verify steam Qenerator water levels 3.4.6.2 3.4.6.2 Verify correct breaker alignment and power to pump 3.4.6.3 3.4.6.3 RCS Loops - MODE 5, Loops Filled 3.4.7 3.4.7 Verify RHR loop in operation (RHR "train" is used for HBRSEP instead of "loop") 3.4.7.1 3.4.7.1 Verify steam generator secondary side water level 3.4.7.2 3.4.7.2
- Verify correct breaker aliQnment and power to* pump 3.4.7.3 3.4.7.3 RCS Loops - MODE 5, Loops Not" Filled 3.4.8 3._4.8 Verify RH.R loop in' operation (RHR "train" is used for HBRSEP instead of "loop") 3.4.8.1 3.4.8.1 Verify correct breaker alignment and power to pump 3.4 .8.2 3.4.8.2 to RNP-RA/18-0015 Page 7 Pressurizer 3.4.9 3.4.9 Verify pressurizer water level 3.4.9.1 3.4.9.1 Verify*capacity of pressurizer heaters 3.4.9.2 3.4.9.2 Verify required pressurizer heaters capable of being powered from emergency power supply 3.4.9.3 3.4.9.3 Pressurizer Power *o perated Relief Valves (PORVs) 3.4.11 3.4.11 Cycle each block valve
- 3.4.11 .1 3.4.11.1 Cycle each PORV
- 3.4.11 .2 3.4.11.2 Cvcle each solenoid air control vavle and check valve 3.4.11.3 3.4.11.3 Verify accumulators are capable of operating PORVs through a complete cycle -------- 3.4.11.4 Verify PORVs and block valves capable of being powered from emergency power sources 3.4.11.4 ---------
Low Temperature Overpressure Protection (LTOP) System 3.4.12 3.4.12 Verify maximum of one [HPI] pump capable of inlecting into RCS ("HPI" pump is "SI" pump at HBRSEP) 3.4.12.1 3.4.12.1 Verify maximum of one charqinq pump capable of injectinq into RCS 3.4.12.2 --------- Verify no SI pumps capable of injecting into RCS -------- 3.4.12.2 Verify each accumulator is isolated
- 3.4.12.3 3.4.12.3 Verify RHR suction valve is open 3.4.12.4 ------
Verify RCS vent path 3.4.12.5 3.4.12.4 Verify PORV block vaive open for each requ ired PORV 3.4.12.6 3.4.12.5 Verify RHR suction valve is locked open with power removed 3.4.12.7 --------- Perform COT (excludinq actuation) 3.4.12.8 3.4.12.6 Perform CHANNEL CALIBRATION 3.4.12.9 3.4.12.7 RCS Operational LEAKAGE 3.4.13 3.4.13 Verify RCS operational LEAKAGE within limits 3.4.13.1 3.4.13.1 Verify primary to secondary LEAKAGE within limits 3.4.13.2 3.4.13.2 RCS Pressure Isolation Valve (PIV) Leakage 3.4.14 3.4.14 Verify leakage from each RCS PIV 3.4.14.1 3.4.14.1 ~~ RHR interlock functionality (openinq) 3.4 .14.2 3.4. 14.2 Verify RHR interlock functionality (closure) 3.4 .14.3 RCS Lea.k age Detection Instrumentation 3.4.15 3.4.15 Perform CHANNEL CHECK (atmosphere radioactivity monitor) 3.4.15.1 3.4.15.1 to RNP-RA/18-0015 Page 8 Perform COT (atmosphere radioactivity monitor) 3.4.15.2 3.4.15.2 Peform CHANNEL CALIBRATION (sump monitor) 3.4.15.3 3.4.15.3 Perform CHANNEL CALIBRATION (atmosphere radioactivity monitor) 3.4.15.4 3.4.15.4 Perform CHANNEL CALIBRATION (air cooler condensate flow rate monitor) 3.4.15.5 3.4.15.5 RCS Speci(ic Activity 3.4.16 3.4.16 Verify gross specific activity 3.4.16.1 3.4.16.1 Verify DOSE EQUIVALENT 1-131 specific activity 3.4.16.2 3.4.16.2 Determine~ 3.4.16.3 3.4.16.3 RCS Loop Isolation Valves 3.4.17 ---------- Verify each loop isolation valve is open and power is removed. from each loop isolation valve operator 3.4.17.1 -------- Chemical and Volume Control System (CVCS) .. ---------- 3.4.17 Verify seal injection flow to each RCP --------- 3.4.17.1 Verify seal injection flow to each RCP from each Makeup Water Pathway from the RWST -------- 3.4.17.2 RCS Loops - Test Exceptions 3.4.19 ---------- Verify THERMAL POWER <P-7 3.4.19.1 ------- Accumulators 3.5.1 3.5.1 Ver.ify each accumulator isolation valve fully open 3.5.1.1 ------ Verify borated water volume in each accumulator 3.5.1.2 3.5.1.2 Verify nitrogen cover pressure in each accumulator 3.5.1 .3 3.5.1 .3 Verify boron concentration in each accumulator 3.5.1.4 3.5.1.4 Verify power removed from each isolation valve operator 3.p.1.5 3.5.1.5 ECCS - Operating 3.5.2 3.5.2 Verify {listed) valves in proper position with power removed 3.5.2.1 3.5.2.1 Verify valves in flow path in the correct position with power removed 3.5.2.2 3.5.2.2 Verify ECCS pipino full of water 3.5.2.3 ----*---- Verify each ECCS automatic valve actuates to correct position on actual or simulated actuation signal 3.5.2.5 3.5.2.4 Verify each ECCS pump starts automatically on actual or simulated actuation signal 3.5.2.6 3.5.2.5 Verify ECCS throttle valves (!isted) in the correct position 3.5.2.7 ----.----- Visual inspection of ECCS train 3.5.2.8 3.5.2.6 Verify valves in listed position --- - - -- 3.5.2.7 to RNP-RA/18-0015 Page 9 Verify manuaJ valve in locked listed position --- ----- 3.5.2.8 Refueling ,Water Storage .-Tan Jc .{RWST) .3.5.4- 3.5.4 Verify RWST bon;Jted wate_ r temperature 3,5,4.1 3.5.4.1 Verify RWSJ borat~d .water volume 3.5._4.2 3-.5.4.2 Verify RWST boron concentration *- 3.5.4.3 3.5.4.3 Seal-Injection Flow 3.5.5 --------- Verify manual seal. injection valves adjusted.to..proper: flow 3.5.5.1 -------- Boron Injection Tank (BIT) . 3.5.6 --------- Verjfy BIT borated water temperature 3.5.6.1 --------- Verifyi,BIT bqra_ted water volurne* _ 3.5.6.2 --- ----- Verify B!T boron concentration - 3.5.6.3 --- ----- Containment Air Locks . - . _. , ,_ , 3.6.2 3.6.2 Verify one door in the _a~r lock -can bf:ropened.at a time 3.6.2.2 3.6.2.2 Containment Isolation Valves . ' ' .* ' 3.6.3 3.6.3 Verify purge valve [42 inch] closed 3.6.3.1 3.6.3.1 Verify purQe valve r8 inchl closed 3.6.3.2 3.6.3.1 Verify containmentis.olatior, manual valves and blind flanges are closed 3.6.3.3 3.6.3.2 Verify isol;:i_tion times -- , . . ,:*._ ;_: - . . ~--
.. -~ ...
3.6.3.5 ------- Cycle each testa_ble check valve through* one full cycle ** 3:6.3.6 --------- Perform leakage rate testing for containment.purge valves with resi lient seals 3.6.3.7 -------- Verify automatic valve~ actuat~to cerrect position on *an actual or simulated siQnal 3.6.3.8 3.6.3.5 Cycle each testable check valve through one full cycle 3.6.3.9 -------- Verify each containment purge valve blocked to restrict flow 3.6.3.10 3.6.3.6 Containment Pressure . 3.6.4A 3.6.4 Verify containment pressure within limits 3.6.4A.1 3.6.4.1 Containment Air Temperature 3.6,5A 3.6.5 Verify containment average air temperature within limit 3.6.5A.1 3.6.5.1 Containment Spray and Cooling Systems , 3.6.6A 3.6.6 Verify valves in the flow path in correct position 3.6.6A.1 3.6.6.1 Operate each containment cooHnc::i train fan unit ~ 15 minutes 3.6.6A.2 3.6.6.2 to RNP-RA/18-0015 Page 10 Verify coolino water flow rate 3.6.6A.3 3.6.6.3 Verify containment spray valves actuate to their correct position on an actual or simulated signal 3.6.6A.5 3.6.6.5 Verify containment spray pumps start on an actual or simulated sional 3.6.6A.6 3.6.6.6 Verify containment cooling trains start on an actual or simulated signal 3.6.6A.7 3.6.6.7 Spray Additive S}'.stem 3.6.7 3.6.7 Verify vafves in flow path in correct position 3.6.7.1 3.6.7.1 Verify spray additive tank solution volume 3.6.7.2 3.6.7.2 Verify spray additive tank NaOH solution concentration 3.6.7.3 3.6.7.3 Verify containment spray additive tank valves actuate to their correct position on an actual or simulated sional 3.6.7.4 3.6.7.4 Verify spray additive flow from each solution's flow path 3.6.7.5 -------- Isolation Valve Seal Water (IVSW) System --------- 3.6.8 Verify IVSW tank pressure -------- 3.6.8.1 Verify IVSW tank volume ------- 3.6.8.2 Verify each automatic IVSW valve actuates to correct position on actual or simulated acuation sional --------- 3.6.8.4 Verify IVSW dedicated nitrogen bottles will pressurize the IVSW tank ~ 46.2 psig --------- 3.6.8.5 Verify total IVSW seal header flow rate::;; 124.cc/minute --------- 3.6.8.6 Main Steam Isolation Valves (MSIVs) 3.7.2 3.7.2 Verify each MSIV actuates to the isolation position on an actual or simulated actuation signal 3.7.2.2 --------- Main Feedwater _ Isolation Valves (MFIVs) and Main Feedwater Regulation Valves (MFRVs) and Associated Bypass Valves 3.7.3 3.7.3 Verify each MFIV, MFRV and associated bypass valve ac_ tuates to the isolation position on an actual or simulated signal 3.7.3.2 --------- Atmospheric Dump Valves (ADVs) 3.7.4 ---------- Verify one complete cycle of each ADV 3.7.4. 1 --------- Verify one complete cycle of each ADV block valve 3.7.4.2 ------- Auxiliary Feedwater (AFW) System 3.7.5 3.7.4 . Verify valves in the water and steam flow path in their correct position 3.7.5.1 3.7.4.1 Verify developed head of each AFW pump at the flow test point --------- 3.7.4.2 Verify each AFW automatic valve actuates to the correct position on an actual or simulated acuation sional 3.7.5.3 3.7.4.3 Verify each AFW ump starts automatically on an actual or simulated actuation signal 3.7.5.4 3.7.4.4 to RNP-RA/18-0015 Page 11 Verify AFW automatic bus transfer switch ass9ciated with discharge valve V2- 16A operates on actual or simulated SiQnai' '" L ** - * ' - - ' ' ' * - - -
--------- 3.7.4.6 Condensate Storage i"'ank (CST) 3.7.6 3.7.5 Verify CST level ** 3.7.6.1 3.7.5.1 Verify by administrative means OPERABILITY of backup Service Water System (SWS) supply to the AFW System * * --- ----- 3.7.5.2 Component Cooling Water (CCW) System 3.7.7 3.7.6 Verify each CCW valve is in the correct position 3.7.7.1 3.7.6.1 Verify each CCW valve in the flow path actuates to the correct position on an actual or simulated signal 3.7.7.2 ----- ----
Verify each CCW pump starts automatically on an actual or simulated actuation siQnal 3.7.7. 3 3.7.6.2 Service Water System (SWS) 3.7.8 3.7.7 Verify each SWS v~lve is in the correct position ._ - .. 3.7.8.1 3.7.7.1 Verify each SWS valve in the flow path actuates to the correct position on an actual or simulated actuation siQnal *
- 3.7.8.2 3.7.7.2 Verify each SWS pump starts automatically on an actual or simulated actuation signal 3.7.8.3 3.7.7,3 Verify the SWS automatic l )l.is tr.ansfer switch associated with Turbine Bldg. valve V6-16C operates on an actual or simulated signal * * - .) * * --------- 3.7.7.4 Ultimate Heat Sink (UHS) * * * * *- - --, ' 3.7.9 3.7.8 Verify water level of UHS 3.7.9.1 3.7.8.1 Verify averaqe watertemperature of UHS 3.7.9.2 3.7.8.2 Operate each cooli ng tower fan ~* 1$"minutes 3.7.9.3 ---------
Verify each cooling tower fan starts ori actual bisimulated actuation signal 3.7.9.4 --------- Control Room Emergency Filtration System (CREFS) 3.7.10 3.7.9 Operate each CREFS train ~ 15 minutes 3.7.10.1 3.7.9.1 Verify each CREFS train actuates on an actuaior simulated- actuation signal 3.7.10.3 3.7.9.3 Verify one CREFS train can maintain a positive pressure 3.7 .10.4 -------- Control Room Emergency Air Temperature Control System (CREATCS) 3.7.11 3.7.10 Verify each CREATCS train has the capability to remove th~ assumed heat load 3.7.11 .1 3.7.10.1 ECCS Pump Room Exhaust Air Cleanup System (PREACS) 3.7.12 --------- Operate each PREACS train for ~ 1O hours with heaters on or ~ 1*5 -*m inutes for systems without heaters 3.7.12.1 --------- Verify each PREACS train actuates 6n an actual or simulated signal 3.7.12.3 ------ -- to RNP-RA/18-0015 Page 12 Verify one PREACS train can maintain pressure 3.7. 12.4 -------*-- Verify each ECCS PREACS filter bypass damper closed 3.7.12.5 ------- Fuel Building Air Cleanup System (FBACS) 3.7.13 3.7.11 Operate each FBACS train for.! 10 hours with heaters on or.! 15 minutes for systems v1ithout heaters 3.7.13.1 3.7.11 .1 Verify each FBACS train actuates on an actual or simulated actuation siqnal 3.7.13.3 --------- Verify one FBACS train can maintain a pressure 3.7.13.4 3.7.11 .3 Verify each FBACS filter bypass damper can be closed 3.7.13.5 -------- Penetration Room Exhaust Air Cleanup System (PREACS) 3.7.14 --------- Operate each PREACS train for .! 10 hours with heaters on or .! 15 minutes for systems without heaters 3.7.14.1 ----- Verify each PREACS train actuates on an actual or simulated siqnal 3.7.14.3 ------- Verify one PREACS train can maintain pressure 3.7.14.4 --------- Verify each PREACS filter bypass damper can be clos.ed 3.7.14.5 --------- Fuel Storage Pool Water Level 3.7.15 3.7.12 Verify fuel storage 12001 water level '
. ,; 3.7.15.1 3.7.12.1 Fuel Storage Pool Boron Concentration 3.7.16 3.7.13 Verify the fuel storaqe pool boron concentration is within lin:tit 3.7.16.1 3.7.13.1 Secondary Specific Activity 3.7.18 3.7.15 Verify the specific activity of the secondary coolant 3.7.18.1 3.7.15.1 AC Sources - Operating 3.8.1 3.8.1 Verify correct breaker alignment 3.8.1 .1 3.8.1.1 Verify each DG starts from standby conditions 3.8.1.2 3.8.1.2 Verify each DG is synchronized and loaded 3.8.1 .3 3.8.1.3 Verify each day tank contains contains proper fuel quantity . 3.8.1.4 3.8.1.4 Check for and remove *accumulated water from each day tank 3.8.1 .5 3.8.1.5 Verify fuel oil transfer operation {from storage tank to day tank) 3.8.1.6 3.8.1.6 Verify each DG starts from standby conditions in proper t1me : ' 3.8.1 .7 3.8.1.7 Verify transfer of AC power sources (normal to alternate) 3.8.1.8 3.8.1.16 Load rejection test (largest post-accident load) 3.8.1.9 3.8.1.8 Verify DG does not trip and voltaqe is maintained durinq and following load rejection 3.8.1.10 ------
Verify DG performs properly on an actual or simulated loss of offsite power siqnal 3.8.1.11 3.8.1.9 to RNP-RA/18-0015 Page 13 Verify on an a~tual or, si.rnulated ESF actuation each DG auto starts from standby conditions 3.8.1.12 3.8.1.10 Verify each DG's nonGritical tr:1ps are-bypassed 3.8.1.13 3.8.1. 1°1 Verify each, DG operates for oreater than 24 hours 3.8.1.14 3.8.1.12 Verify_QG starts and performs properly within 5.minutes of operating for 2 hours a maximum load 3.8.1.15 3,8.1 .13 Verify DG synchronizes with offsite power while loaded with 'emergency ioads 3.8 ._1.16" --------- Verify an actual or simulated ESF sional overrides a test sional 3.8.1.17 --------- Verify interval between each sequenced load block
- 3.8.1.1'8
- 3.8.1.14 Verify on an act~al or simulated loss of offsite power in Qonjunction with actual or simulated ESF signal the DG performs properly 3.8.1.19 3.8.1.15 Verify when ~tarted simultaneously from standby conditions each DG performs properly 3.8 .1.20 3.8.1.17 Diesel Fuel Oil, Lube Oil, and Starting Air - 3.8.3 3.8.3 Verify each fuel oil storage tank volume (gallons) 3.8.3.1 3.8.3.1 Verify lubricatinq oil inventory 3.8.3.2 --------
Verify each DG air start receiver pressure 3.8.3.4 3.8.3.3 Check for and remove accumu.lated water from each fuel oil storaoe tank 3.8.3.5 3.8.3.4 DC Sources - Operating **- 3.8.4 3.8.4 Verify battery terminal vo_itaoe orea:t edhan or equal to minimum established float voltaoe 3.8.4.1 3.8.4.1 Verify each battery charger suppJi_es' ~-[400) amps at greater than or equal to minimum float voltage for ~ [8] hours - .. - 3.8.4.2 3.8.4.4 Verify battery *capa_oity ' ' . .'. 3.8.4.3 3.8.4.5
-- 3.8.4.6 Verify battery cells, cell_plates and racks show no visual indication of physical damage or abnormal deterioration : C
~ ' ,* ,
--------- 3.8.4.2 Remove visible terminal corrosion, verify, battery .ceU _to cell and terminal connections are clean and tight --------- 3.8.4.3 Battery Parameters 3.8.6 3.8.6 Verify battery float current 3.8.6.1 ---------
Verify each battery pilot cell voltage 3.8.6.2 --------- Verify each_battery connected cell electrolyte level is great~r than or equal to minimum established design limits 3.8.6.3 --------- Verify eitch battery pilot cell temperature is oreater than or equal to minimum established desion limits 3.8.6.4 --------- Verify each battery connected cell voltage 3.8.6.5 3.8.6.2 to RNP-RA/18-0015 Page 14 Verify battery capacity 3.8.6.6 ------ Verify battery cell parameters meet Table 3.8.6-1 Category A limits (limits for each designated pilot cell) --------- 3.8.6.1 Verify battery cell parameters meet Table 3.8.6-1 Category B limits (limits for each connected cell) --------- 3.8.6.2 Verify average electrolyte temperature of representative cells is~ 67°F -------- 3.8.6.3 Inverters - Operating (AC Instrument Bus Sources - Operating for HBRSEP) 3.8.7 3.8.7 Verify correct inverter voltage, frequency and alignment to required AC vital buses 3.8.7.1 3.8.7.1 Verify voltage availability and correct Constant Voltage Transformer (CVT) alignment to AC instrument buses --------- 3.8.7.2 Inverters - Shutdown (AC Instrument Bus Sources - Shutdown for HBRSEP) 3.8.8 3.8.8 Verify correct inverter voltage, frequency and alignment to required AC vital buses 3.8.8.1 3.8.8.1 Distribution Systems - Operating 3.8.9 3.8.9 Verify correct breaker alignments and voltage to AC , DC and AC vital bus electrical power distribution subsystems 3.8.9.1 3.8.9.1 Verify capability of the two molded case circuit breakers for AFW Header Discharge Valve to SIG "A", V2-16A to trip on overcurrent -------- 3.8.9.2 Verify capability of the two molded case circuit breakers for SW System Turbine Bldg . Supply Valve, V6-16C to trip on overcurrent --------- 3.8.9.3 Distribution Systems - Shutdown 3.8.10 3.8.10 Verify correct breaker alignments and voltage to AC, DC and AC vital bus electrical power distribution subsystems 3.8.10.1 3.8.10.1 Boron Concentration 3.9.1 3.9.1 Verify boron concentration within the limit specified in COLR 3.9.1.1 3.9.1.1 Unborated Water Source Isolation Valves 3.9.2 --------- Verify each. valve that isolates unborated water sources is secured in the closed position 3.9.2.1 ------- Nuclear Instrumentation 3.9.3 3.9.2 Perform CHANNl=L CHECK 3.9.3.1 3.9.2.1. . Perform CHANNEL CALIBRATION 3.9.3.2 3.9.2.2 - Containment Penetrations 3.9.4 3.9.3 : Verify each. required containment penetration is in the required status 3.9.4.1 3.9.3.1 Verify each.required containment purge and exhaust valve actu ates to the i~olation po~ition on an actual or simulated signal . . '. 3.9.4.2 3.9.3.2 Residual Heat RemQ.v.at (RHR} and Cpolant Circulation - High Water Level 3.9.5 ~.9.4 to RNP-RA/18-0015 Page 15 Verify one RHR loop is in operation and circulating reactor coolant 3.9.5.1 3.9.4.1 Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level 3.9.6 3.9.5 Verify one RHR loop is in operation and circulating reactor coolant .3.9.6.1 3.9.5.1 Verify. correct breaker .alignment and indi.cated. power avajlable to the required RHR pump that is not in operation - 3.9.6.2 3.9.5.2 Refl:1eling Cavity Water Level 3.9.7 3.9.6 ' Verify refueling cavity water level is ~ 23 ft above the top of reactor vessel flange 3.9.7.1 3.9.6.1 Containment Purge Filter System --------- 3.9.7 Verify relative humidity of containment atmosphere to be processed --------- 3.9.7.1 Verify Containment Purge Filter System is in *operation arid maintaining containment pressure negative relative to adjacent areas _ . ** * .* ' - ----- 3.9.7.2 to RNP-RA/18-0015 Page 1 ATTACHMENT 6 License Amendment Request H.B.* Robinson Steam Electric Plant, Unit t,Jo . .2 (H~R~E~} Docket No. 50-261 _ * . ; Application for Technical Specification Change Regarding Risk-Informed Justification for. the Relocation of Specific Surveillance Frequency Requiremen~s to .a Li~ens~e Controlled Program (Adoption of TSTF-425, Revision 3)
- Proposed* No Significant Hazards Consideration to RNP-RA/18-0015 Page 2 Description of Amendment Request:
This change request involves the adoption of an approved change to the standard technical specifications (STS) for Westinghouse plants (NUREG-1431) , to allow relocation of specific TS surveillance frequencies to a licensee-controlled program . The proposed change is described in Technical Specification Task Force (TSTF) Traveler TSTF-425, Revision 3 (ADAMS Accession No. ML090850642) , related to the Relocation of Surveillance Frequencies to Licensee Control - RITSTF Initiative_5b and is described in the Notice of Availability published in the Federal Register on July 6, 2009 (74 FR 31996). The proposed changes are consistent with Nuclear Regulatory Commission (NRC)-approved Industry/Technical Specifications Task Force (TSTF) Traveler TSTF-425 , Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b." The proposed change relocates surveillance frequencies to a licensee-controlled program , the Surveillance Frequency Control Program . This change is applicable to licensees using probabilistic risk guidelines contained in NRG-approved NEI 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies," (ADAMS Accession No. ML071360456). Basis for proposed no significant hazards consideration: As required by 10 CFR 50.91 (a), the Duke Energy analysis of the issue of no significant hazards consideration is presented below:
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No. The proposed change relocates the specified frequencies for periodic surveillance requirements to licensee control under a new Surveillance Frequency Control Program . Surveillance frequencies are not an initiator to any accident previously evaluated . As a result, the probability of any accident previously evaluated is not significantly increased. The systems and components required by the technical specifications for which the surveillance frequencies are relocated are still required to be operable, meet the acceptance criteria for the surveillance requirements and be capable of performing any mitigation function assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly increased . Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No. No new or different accidents result from utilizing the proposed change. The changes do not involve a physical alteration of the plant (that is, no new or different type of to RNP-RA/18-0015 Page 3 equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated .
- 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No. The design, operation , testing methods and acceptance criteria for systems, structures and components (SSCs) , specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plant licensing basis (including the final safety analysis report and bases to the TS) , since these are not affected by changes to the surveillance frequencies. Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis. To evaluate a change in the relocated surveillance frequency, Duke Energy will perform a probabilistic risk evaluation using the guidance contained in NRC approved Nuclear Energy Institute (NEI) 04-10, Revision 1, in accordance with the TS Surveillance Frequency Control Program . NEI 04-10, Revision 1 methodology provides reasonable acceptance guidelines and methods for evaluating the risk increase of proposed changes to surveillance frequencies consistent with Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk Informed Decisionmaking : Technical Specifications." Therefore, the proposed change does not involve a significant reduction in a margin of safety. Based upon the reasoning presented above, Duke Energy concludes that the requested change does not involve a significant hazards consideration as set forth in 10 CFR 50.92(c) , Issuance of Amendment.}}