Text

Application to Revise Technical Specifications to Adopt TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, Using the Consolidated Line Item Improvement Process
	ML19204A240
Person / Time
Site:	Hatch
Issue date:	07/23/2019
From:	Gayheart C; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-19-0355
	Download: ML19204A240 (38)
	v • d • e

~ Southern Nuclear Cheryl A. Gayheart Regulatory Affairs Director 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 tel 205 992 7795 fax JUL 2 3 2019 cagayhea@ southernco.com Docket Nos.: 50-321 NL-19-0355 50-366 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Application to Revise Technical Specifications to Adopt TSTF-566, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems,"

Using the Consolidated Line Item Improvement Process Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) is submitting a request for amendments to the Technical Specifications (TS) for Edwin I. Hatch Nuclear Plant (HNP),

Units 1 and 2.

SNC requests adoption of TSTF-566, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems," which is an approved change to the Improved Standard Technical Specifications (ISTS), into the HNP Unit 1 and Unit 2 TS. The proposed amendment for each unit revises the TS actions applicable when a residual heat removal (RHR) shutdown cooling subsystem is inoperable.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. Attachment 2 provides revised (clean) TS pages. Attachment 3 provides existing TS Bases pages marked to show the proposed changes for information only.

Approval of the proposed amendments is requested by January 31, 2020 to support implementation of the amendments prior to the HNP Unit 1 refueling outage scheduled for mid-February 2020. It is noted that Traveler TSTF-566, Revision 0, is approved as a consolidated line item improvement process (CLIIP) traveler. Once approved, the amendments shall be implemented within 30 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Georgia Official.

There are no regulatory commitments in this submittal.

U.S. Nuclear Regulatory Commission NL-19-0355 Page2 If you should have any questions regarding this submittal, please contact Jamie Coleman at 205.992.6611.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 7,3 day of July 2019.

Respectfully submitted, Director, e latory Affairs Southern Nuclear Operating Company CAGffLE/scm

Enclosure:

Description and Assessment Attachments: 1. Proposed Technical Specifications Changes (Mark-Up)

2. Revised Technical Specifications Pages

3. Proposed Technical Specifications Bases Changes (Mark-Up) for Information Only cc: Regional Administrator, Region II NRR Project Manager- Hatch Senior Resident Inspector- Hatch Director, Environmental Protection Division - State of Georgia RType: CHA02.004

Edwin I. Hatch Nuclear Plant

Units 1 and 2 Application to Revise Technical Specifications to Adopt TSTF-566, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems,"

Using the Consolidated Line Item Improvement Process Enclosure Description and Assessment

Enclosure to NL-19-0355 Description and Assessment

1.0 DESCRIPTION

Southern Nuclear Operating Company (SNC) requests adoption of Technical Specifications Task Force (TSTF) traveler TSTF-566, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems," which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Edwin I. Hatch Nuclear Plant (HNP)

Unit 1 and Unit 2 Technical Specifications (TS). The proposed amendments revise the TS actions applicable when a residual heat removal (RHR) shutdown cooling subsystem is inoperable.

2.0 ASSESSMENT 2.1 Applicabilitv of Safetv Evaluation SNC has reviewed the safety evaluation for TSTF-566 provided to the Technical Specifications Task Force in a letter dated February 21, 2019. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-566. As described herein, SNC has concluded that the justifications presented in TSTF-566 and the safety evaluation prepared by the NRC staff are applicable to HNP Units 1 and 2 and justify these amendments for the incorporation of the changes to the HNP Unit 1 and Unit 2 TS.

2.2 Variations SNC is proposing the following variations from the TS changes described in TSTF-566 or the applicable parts of the NRC staff's safety evaluation:

The HNP TS utilize different numbering than the Standard Technical Specifications on which TSTF-566 was based. Specifically:

Specification 3.4.8, "RHR Shutdown Cooling System - Hot Shutdown" is Specification 3.4.7 in the HNP TS.

Specification 3.4.9, "RHR Shutdown Cooling System -Cold Shutdown" is Specification 3.4.8 in the HNP TS .

These differences are administrative and do not affect the applicability of TSTF-566 to the HNP TS.

In addition, the HNP TS have minor differences in some wording from the ISTS, such as the word "the" sometimes not included in the HNP TS in certain locations and use of the phrase "less than" instead of the symbol "<". These differences exist in wording unaffected by the TSTF changes, are administrative, and do not affect the applicability of TSTF-566 to the HNP TS.

The traveler discusses the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General Design Criteria (GDC). HNP Unit 2 was licensed to the 10 CFR 50, Appendix A, GDC. However, HNP Unit 1 was not licensed to the 10 CFR 50, Appendix A, GDC. HNP Unit 1 was licensed E-1

Enclosure to NL-19-0355 Description and Assessment to the applicable Atomic Energy Commission (AEC) preliminary general design criteria identified in Federal Register 32 FR 10213, published July 11 , 1967 (ADAMS Accession No. ML043310029). The applicable AEC proposed criteria were compared to the 10 CFR 50, Appendix A, GDC, as documented in the Hatch Updated Final Safety Analysis Report (UFSAR), Appendix F, "Conformance to the Atomic Energy Commission (AEC) Criteria," as discussed below.

TSTF-566 references 10 CFR 50, Appendix A, GDC 34, "Residual Heat Removal," which states:

A system to remove residual heat shall be provided. The system safety function shall be to transfer fission product decay heat and other residual heat from the reactor core at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded.

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

A design evaluation of GDC 34 is included in Section F.3 of the HNP Unit 1 UFSAR, "Evaluation with Respect to 1971 General Design Criteria."

Following implementation of the proposed change, HNP Unit 1 will remain in compliance with applicable AEC design criteria as described in the HNP Unit 1 UFSAR. Therefore, this difference does not alter the conclusion that the proposed change is applicable to HNP Unit 1.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Southern Nuclear Operating Company (SNC) requests adoption of Technical Specifications Task Force (TSTF) traveler TSTF-566, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems," which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Edwin I.

Hatch Nuclear Plant (HNP), Unit 1 and Unit 2, Technical Specifications (TS).

The proposed amendment revises the TS actions applicable when a residual heat removal (RHR) shutdown cooling subsystem is inoperable.

SNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

E-2

Enclosure to NL-19-0355 Description and Assessment (1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change revises the actions to be taken when an RHR shutdown cooling subsystem is inoperable. The RHR System in the shutdown cooling mode performs the important safety function of removing decay heat from the reactor coolant system during shutdown. The RHR System in the shutdown cooling mode is not an initiator of any accident previously evaluated or assumed to mitigate any accident previously evaluated . The design and function of the RHR System are not affected by the proposed change.

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

(2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change revises the actions to be taken when an RHR shutdown cooling subsystem is inoperable. The proposed change does not affect the design function or operation of the RHR shutdown cooling subsystems. No new equipment is being installed as a result of the proposed change. The proposed change only affects the actions taken when an RHR shutdown cooling subsystem is inoperable, so no new failure mechanisms are created.

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 amendment involve a significant reduction in a margin of safety?

Response: No The proposed change revises the actions to be taken when an RHR shutdown cooling subsystem is inoperable. The proposed change does not change any specific values or controlling parameters that define margin in the design or licensing basis. No safety limits are affected by the proposed change. The RHR System in the shutdown cooling mode removes decay heat from the reactor coolant system during shutdown . The proposed change does not affect any design or safety limits associated with the RHR System.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

E-3

Enclosure to NL-19-0355 Description and Assessment Based on the above, SNC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusion 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

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

E-4

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Application to Revise Technical Specifications to Adopt TSTF-566, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems,"

Using the Consolidated Line Item Improvement Process Attachment 1 Proposed Technical Specifications Changes (Mark-Up)

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4. 7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3 with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown /\.1 Initiate astian to restore Immediately cooling subsystems RHR shutdown oooling inoperable. subsystem(s) to OPERABLE status.

(continued)

HATCH UNIT 1 3.4-13 Amendment No. 299

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME II

n. (oontinued) A.~1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months method of decay heat removal is available for AND each inoperable RHR shutdown cooling Once Qer 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem . thereafter ANG A.J Be in MGQ~ 4. 24 AOUFS B. Reguired Action and B.1 Initiate action to restore Immediate!~

associated ComQietion RHR shutdown cooling Time of Condition A not subs~stem(s) to met. OPERABLE status.

QR No RHR shutdown cooling QR 1 Initiate action to restore Immediately subsystem in operation. one RHR shutdown cooling subsystem or AND one recirculation pump to operation .

No recirculation pump in operation . AND CS.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery circulation by an of no reactor coolant alternate method . circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND QR 3 Monitor reactor coolant Once per hour temperature and pressure.

HATCH UNIT 1 3.4-14 Amendment No. 299

RHR Shutdown Cooling System- Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE4.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months cooling subsystems method of decay heat inoperable. removal is available for AND each inoperable RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Reguired Action and B.1 Initiate action to restore Immediately Associated ComQietion RHR shutdown cooling Time of Condition A not subsystem(s} to met. OPERABLE status.

(continued)

HATCH UNIT 1 3.4-16 Amendment No. 299

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME CB. No RHR shutdown cooling CB. 1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery subsystem in operation . circulation by an of no reactor coolant alternate method. circulation No recirculation pump in operation . Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter C8 .2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR shutdown cooling subsystem or In accordance with recirculation pump is operating. the Surveillance Frequency Control Program SR 3.4.8.2 ------------------------------NOTE-----------------------------

An operating RHR shutdown cooling subsystem will meet this requirement for the RHR shutdown cooling subsystem running unless the RHR shutdown cooling subsystem is in a low flow system operation.

Verify required RHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program HATCH UNIT 1 3.4-17 Amendment No. ;gg

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System- Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3 with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Initiate action to restore Immediately cooling subsystems RHR shutdown cooling inoperable. subsystem(s) to OPERABLE status.

/, ~\

(continued)

HATCH UNIT2 3.4-13 Amendment No. 2-+0

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME nA . (continued) A. ~1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months method of decay heat removal is available for AND each inoperable RHR shutdown cooling Once Qer 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter ANQ A.J Be in MGQe 4. 24 ROUFS B. Reguired Action and B.1 Initiate action to restore Immediately associated ComQietion RHR shutdown cooling Time of Condition A not subsystem(s} to met. OPERABLE status.

CQ. No RHR shutdown cooling CQ. 1 Initiate action to restore Immediately subsystem in operation. one RHR shutdown cooling subsystem or AND one recirculation pump to operation .

No recirculation pump in operation. AND

.QR 2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery circulation by an of no reactor coolant alternate method. circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C8 .3 Monitor reactor coolant Once per hour temperature and pressure.

HATCH UNIT 2 3.4-14 Amendment No. ~

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation .

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

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 4.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months cooling subsystems method of decay heat inoperable. removal is available for AND each inoperable RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Reguired Action and B.1 Initiate action to restore Immediate!~

Associated ComQietion RHR shutdown cooling Time of Condition A not subs~stem(s} to met. OPERABLE status.

(continued)

HATCH UNIT 2 3.4-16 Amendment No. 24-0

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME CB. No RHR shutdown cooling Q8. 1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery subsystem in operation. circulation by an of no reactor coolant alternate method. circulation No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter C8. 2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR shutdown cooling subsystem or In accordance with recirculation pump is operating . the Surveillance Frequency Control Program SR 3.4.8.2 -----------------------------NOTE----------------------------

An operating RHR shutdown cooling subsystem will meet this requirement for the RHR shutdown cooling subsystem running unless the RHR shutdown cooling subsystem is in a low flow system operation.

Verify required RHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program HATCH UNIT2 3.4-17 Amendment No. ~

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Application to Revise Technical Specifications to Adopt TSTF-566, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems,"

Using the Consolidated Line Item Improvement Process Attachment 2 Revised Technical Specifications Pages

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4. 7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3 with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months cooling subsystems method of decay heat inoperable. removal is available for AND each inoperable RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action to restore Immediately associated Completion RHR shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

HATCH UNIT 1 3.4-13 Amendment No.

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling C.1 Initiate action to restore Immediately subsystem in operation. one RHR shutdown cooling subsystem or one recirculation pump to operation .

No recirculation pump in operation. AND C.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery circulation by an of no reactor coolant alternate method. circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.3 Monitor reactor coolant Once per hour temperature and pressure.

HATCH UNIT 1 3.4-14 Amendment No.

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE4.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months cooling subsystems method of decay heat inoperable. removal is available for AND each inoperable RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action to restore Immediately Associated Completion RHR shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(contmued)

HATCH UNIT 1 3.4-16 Amendment No.

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery subsystem in operation . circulation by an of no reactor coolant alternate method. circulation AND AND No recirculation pump in operation . Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR shutdown cooling subsystem or In accordance with recirculation pump is operating . the Surveillance Frequency Control Program SR 3.4.8.2 ---------------------------NOTE----------------------------

An operating RHR shutdown cooling subsystem will meet this requirement for the RHR shutdown cooling subsystem running unless the RHR shutdown cooling subsystem is in a low flow system operation.

Verify required RHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program HATCH UNIT 1 3.4-17 Amendment No.

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System- Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3 with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

N0 T E----------------------------------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months cooling subsystems method of decay heat inoperable. removal is available for AND each inoperable RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem . thereafter B. Required Action and B.1 Initiate action to restore Immediately associated Completion RHR shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

HATCH UNIT2 3.4-13 Amendment No.

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling C.1 Initiate action to restore Immediately subsystem in operation. one RHR shutdown cooling subsystem or one recirculation pump to operation.

No recirculation pump in operation . AND C.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery circulation by an of no reactor coolant alternate method. circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.3 Monitor reactor coolant Once per hour temperature and pressure.

HATCH UNIT2 3.4-14 Amendment No.

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System- Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE4.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months cooling subsystems method of decay heat inoperable. removal is available for AND each inoperable RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action to restore Immediately Associated Completion RHR shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

HATCH UNIT2 3.4-16 Amendment No.

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery subsystem in operation . circulation by an of no reactor coolant alternate method. circulation No recirculation pump in operation . Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR shutdown cooling subsystem or In accordance with recirculation pump is operating . the Surveillance Frequency Control Program SR 3.4.8.2 ---------------------------NOTE-------------------------

An operating RHR shutdown cooling subsystem will meet this requirement for the RHR shutdown cooling subsystem running unless the RHR shutdown cooling subsystem is in a low flow system operation.

Verify required RHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program HATCH UNIT2 3.4-17 Amendment No.

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Application to Revise Technical Specifications to Adopt TSTF-566, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems,"

Using the Consolidated Line Item Improvement Process Attachment 3 Proposed Technical Specifications Bases Changes (Mark-Up) for Information Only

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 BASES (continued)

ACTIONS A Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition . Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure ,

with Completion Times based on initial entry into the Condition.

However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such , a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem .

A.1 .*a..2. and A.3 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, Ule inoperable subsystem must be restored to OPERABLE status without delay. In this condition, the remaining OPERABLE subsystem can pro*;ide the necessary decay heat removal. T1he overall reliability is reduced , hO'Never, because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability.

Therefore, an alternate method of decay heat removal must be provided.

With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability.

This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore. verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will provide assurance of continued heat removal capability.

The required cooling capacity of the alternate method should be sufficient to ensured by verifying (by calculation or demonstration) its capability to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability. Alternate methods that can be used include (but are not limited to) the Condensate/Main Steam Systems.. aRG-the Reactor Water Cleanup System. or an inoperable but functional RHR shutdown cooling subsystem.

(continued)

HATCH UNIT 1 B 3.4-31 REVISION 49

RHR Shutdown Cooling System - Hot Shutdown 8 3.4 .7 BASES ACTIONS .A..1. A.2. and A.3 (continued )

(continued)

However, due to the potentially reduced reliability of the alternate methods of decay heat removal, it is also required to reduce the reactor coolant temperature to the point 1Nhere MODE 4 is entered.

8.1 If the required alternate method(s) of decay heat removal cannot be verified within one hour. immediate action must be taken to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The Required Action will restore redundant decay heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

CB. 1, CB.2. and CB.3 With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, reactor coolant circulation by the RHR shutdown cooling subsystem or recirculation pump must be restored without delay.

Until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation. Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR shutdown cooling subsystem or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This Surveillance verifies that one RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant.

The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

HATCH UNIT 1 8 3.4-32 REVISION W

RHR Shutdown Cooling System - Cold Shutdown B 3.4.8 BASES ACTIONS discovered to be inoperable or not within limits, will not result in (continued) separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition.

However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

With one of the two required RHR shutdown cooling subsystems inoperable, except as permitted by LCO Note 2, the remaining subsystem is capable of providing the required decay heat removal.

However, the overall reliability is reduced. Therefore, an alternate method of decay heat removal must be provided. With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability. This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will provide assurance of continued heat removal capability.

The required cooling capacity of the alternate method should be sufficient ensured by verifying (by calculation or demonstration) its capability to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability. Alternate methods that can be used include (but are not limited to) the Condensate/Main Steam Systems (feed and bleed).._-ami-the Reactor Water Cleanup System . or an inoperable but functional RHR shutdown cooling subsystem.

If the required alternate method(s) of decay heat removal cannot be verified within one hour. immediate action must be taken to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The Required Action will restore redundant decay heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

(continued)

HATCH UNIT 1 B 3.4-39 REVISION ~

RHR Shutdown Cooling System - Cold Shutdown B 3.4 .8 BASES ACTIONS C8. 1 and CR 2 (oontinued)

(continued)

With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, and until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation.

Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR shutdown cooling subsystem or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This Surveillance verifies that one RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant.

The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.8.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information ,

including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

(continued)

HATCH UNIT 1 B 3.4-40 REVISION ~

RHR - High Water Level B 3.9.7 BASES (continued)

ACTIONS A.1 With no RHR shutdown cooling subsystem OPERABLE, an alternate method of decay heat removal must be established within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In this condition, the volume of water above the RPV flange provides adequate capability to remove decay heat from the reactor core.

However, the overall reliability is reduced because loss of water level could result in reduced decay heat removal capability. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on decay heat removal function and the probability of a loss of the available decay heat removal capabilities.

Furthermore, verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will ensure continued heat removal capability.

Alternate decay heat removal methods are available to the operators for review and preplanning in the unit's Operating Procedures. The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to. the alternate method capability. Alternate methods that can be used include (but are not limited to) the Spent For mcample , this may include the use of the Fuel Pool Cooling System, the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystemoperating

'Nith the regenerative heat exchanger bypassed, or any other subsystem that can remove heat from the coolant. The method used to remove the decay heat should be the most prudent choice based on unit conditions.

B.1, B.2. B.3. and B.4 If no RHR shutdown cooling subsystem is OPERABLE and an alternate method of decay heat removal is not available in accordance with Required Action A.1, actions shall be taken immediately to suspend operations involving an increase in reactor decay heat load by suspending loading of irradiated fuel assemblies into the RPV.

Additional actions are required to minimize any potential fission product release to the environment. This includes ensuring:

1) secondary containment (at least including the common refueling floor zone) is OPERABLE; 2) sufficient standby gas treatment subsystem(s) are OPERABLE to maintain the secondary containment at a negative pressure with respect to the environment (dependent on secondary containment configuration, refer to Reference 2; single failure protection is not required while in this ACTION) ; and

3) secondary containment isolation capability is available in each secondary containment penetration flow path not isolated that is assumed to be isolated to mitigate radioactive releases (i.e., one secondary containment isolation valve and associated instrumentation are OPERABLE or other acceptable administrative controls to assure isolation capability. The administrative controls can consist of (continued)

HATCH UNIT 1 B 3.9-21 REVISION RHR- Low Water Level B 3.9.8 BASES (continued)

APPLICABILITY Two RHR shutdown cooling subsystems are required to be OPERABLE, and one must be in operation in MODE 5, with irradiated fuel in the RPV and the water level < 22 ft 1/8 inches above the top of the RPV flange, to provide decay heat removal. RHR shutdown cooling subsystem requirements in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS). RHR shutdown cooling subsystem requirements in MODE 5 with irradiated fuel in the RPV and the water level ~ 22 ft 1/8 inches above the RPV flange are given in LCO 3.9.7, "Residual Heat Removal (RHR)- High Water Level."

ACTIONS With one of the two required RHR shutdown cooling subsystems inoperable, the remaining subsystem is capable of providing the required decay heat removal. However, the overall reliability is reduced. Therefore an alternate method of decay heat removal must be provided. With both required RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability. This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, verification of the functional availability of this alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will ensure continued heat removal capability.

Alternate decay heat removal methods are available to the operators for review and preplanning in the unit's Operating Procedures. The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability. Alternate methods that can be used include {but are not limited to) the Spent Fuel Pool Cooling System, the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystem. For e~<ample , this may include the use of the Reactor Water Cleanup System, operating with the regenerative heat exchanger bypassed . The method used to remove decay heat should be the most prudent choice based on unit conditions.

B.1, B.2, and B.3 With the required RHR shutdown cooling subsystem(s) inoperable and the required alternate method(s) of decay heat removal not available in accordance with Required Action A.1, additional actions are required to minimize any potential fission product release to the environment. This includes ensuring: 1) secondary containment (at least including the common refueling floor zone) is OPERABLE; (continued)

HATCH UNIT 1 B 3.9-27 REVISION 8J

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 BASES (continued)

ACTIONS A Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition . Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition.

However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

A.1 , t\.2. and ,t\.3 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, tfte inoperable subsystem must be restored to OPERABLE status without delay. In this condition, the remaining OPERABLE subsystem can pro¥ide the neoessary decay heat removal. T!he overall reliability is reduced , however, because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability.

Therefore, an alternate method of decay heat removal must be provided.

With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability.

This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore. verification of the functional availability of these alternate method(s) must be reconfirmed everv 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will provide assurance of continued heat removal capability.

The required cooling capacity of the alternate method should be sufficient to ensured by ¥erifying (by calculation or demonstration) its capability to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability. Alternate methods that can be used include (but are not limited to) the Condensate/Main Steam Systems... aRG-the Reactor Water Cleanup System. or an inoperable but functional RHR shutdown cooling subsystem.

(continued)

HATCH UNIT 2 B 3.4-32 REVISION ++

RHR Shutdown Cooling System- Hot Shutdown 8 3.4.7 BASES ACTIONS A 1, A.2, and A.3 (continued)

(continued)

However, due to the potentially reduced reliability of the alternate methods of decay heat removal, it is also required to reduce the reactor ooolant temperature to the point where MODE 4 is entered.

8.1 If the required alternate method(s) of decay heat removal cannot be verified within one hour. immediate action must be taken to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The Required Action will restore redundant decay heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

CB. 1. CB.2. and c g .3 With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, reactor coolant circulation by the RHR shutdown cooling subsystem or recirculation pump must be restored without delay.

Until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation . Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR shutdown cooling subsystem or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This Surveillance verifies that one RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant.

The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

HATCH UNIT2 8 3.4-33 REVISION 79

RHR Shutdown Cooling System - Cold Shutdown 8 3.4.8 BASES ACTIONS discovered to be inoperable or not within limits, will not result in (continued) separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition .

However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

With one of the two required RHR shutdown cooling subsystems inoperable, except as permitted by LCO Note 2, the remaining subsystem is capable of providing the required decay heat removal.

However, the overall reliability is reduced. Therefore, an alternate method of decay heat removal must be provided. With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability. This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore , verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will provide assurance of continued heat removal capability.

The required cooling capacity of the alternate method should be sufficient ensured by *1erifying (by oaloulation or demonstration) its oapability to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to , the alternate method capability. Alternate methods that can be used include (but are not limited to) the Condensate/Main Steam Systems (feed and bleed)... aM-the Reactor Water Cleanup System. or an inoperable but functional RHR shutdown cooling subsystem .

If the required alternate method(s) of decay heat removal cannot be verified within one hour. immediate action must be taken to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The Required Action will restore redundant decay heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

(continued)

HATCH UNIT2 8 3.4-40 REVISION Q4

RHR Shutdown Cooling System - Cold Shutdown 8 3.4.8 BASES ACTIONS Gg,1 and CR 2 (continued)

(continued)

With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, and until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation.

Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR shutdown cooling subsystem or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This Surveillance verifies that one RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant.

The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.8.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

(continued)

HATCH UNIT 2 8 3.4-41 REVISION ~

RHR - High Water Level B 3.9.7 BASES (continued)

ACTIONS A.1 With no RHR shutdown cooling subsystem OPERABLE, an alternate method of decay heat removal must be established within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In this condition, the volume of water above the RPV flange provides adequate capability to remove decay heat from the reactor core.

However, the overall reliability is reduced because loss of water level could result in reduced decay heat removal capability. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on decay heat removal function and the probability of a loss of the available decay heat removal capabilities.

Furthermore, verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will ensure continued heat removal capability.

Alternate decay heat removal methods are available to the operators for review and preplanning in the unit's Operating Procedures. The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to. the alternate method capability. Alternate methods that can be used include (but are not limited to) the Spent For example, this may include the use of the Fuel Pool Cooling System, the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystemoperating with the regenerative heat exchanger bypassed , or any other subsystem that can remove heat from the coolant. Tho method used to remove tho decay heat should be the most prudent choice based on unit conditions.

B.1. B.2, B.3. and B.4 If no RHR shutdown cooling subsystem is OPERABLE and an alternate method of decay heat removal is not available in accordance with Required Action A.1, actions shall be taken immediately to suspend operations involving an increase in reactor decay heat load by suspending loading of irradiated fuel assemblies into the RPV.

Additional actions are required to minimize any potential fission product release to the environment. This includes ensuring:

1) secondary containment (at least including the common refueling floor zone) is OPERABLE; 2) sufficient standby gas treatment subsystem(s) are OPERABLE to maintain the secondary containment at a negative pressure with respect to the environment (dependent on secondary containment configuration, refer to Reference 2; single failure protection is not required while in this ACTION); and

3) secondary containment isolation capability is available in each secondary containment penetration flow path not isolated that is assumed to be isolated to mitigate radioactive releases (i.e., one secondary containment isolation valve and associated instrumentation are OPERABLE or other acceptable administrative controls to assure isolation capability. The administrative controls can consist of (continued)

HATCH UNIT 2 B 3.9-21 REVISION +

RHR- Low Water Level B 3.9.8 BASES (continued)

APPLICABILITY Two RHR shutdown cooling subsystems are required to be OPERABLE, and one must be in operation in MODE 5, with irradiated fuel in the RPV and the water level< 22ft 1/8 inches above the top of the RPV flange , to provide decay heat removal. RHR shutdown cooling subsystem requirements in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS). RHR shutdown cooling subsystem requirements in MODE 5 with irradiated fuel in the RPV and the water level~ 22ft 1/8 inches above the RPV flange are given in LCO 3.9.7, "Residual Heat Removal (RHR)- High Water Level."

ACTIONS With one of the two required RHR shutdown cooling subsystems inoperable, the remaining subsystem is capable of providing the required decay heat removal. However, the overall reliability is reduced. Therefore an alternate method of decay heat removal must be provided. With both required RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability. This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, verification of the functional availability of this alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will ensure continued heat removal capability.

Alternate decay heat removal methods are available to the operators for review and preplanning in the unit's Operating Procedures. The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as. or contributing to, the alternate method capability. Alternate methods that can be used include (but are not limited to) the Spent Fuel Pool Cooling System, the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystem. For e~mmple , this may include the use of the Reactor Water Cleanup System , operating with the regenerative heat exchanger bypassed . The method used to remove decay heat should be the most prudent choice based on unit conditions.

B.1, B.2, and B.3 With the required RHR shutdown cooling subsystem(s) inoperable and the required alternate method(s) of decay heat removal not available in accordance with Required Action A.1, additional actions are required to minimize any potential fission product release to the environment. This includes ensuring: 1) secondary containment (at least including the common refueling floor zone) is OPERABLE; (continued)

HATCH UNIT 2 B 3.9-27 REVISION 94

v t e Letter Sequence Request
EPID:L-2019-LLA-0156, TSTF-566 (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers Results Approval Other:
MONTHYEAR2019-11-13 [Table View]

NL-19-0355, Application to Revise Technical Specifications to Adopt TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, Using the Consolidated Line Item Improvement Process

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3.0 REGULATORY ANALYSIS

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NL-19-0355, Application to Revise Technical Specifications to Adopt TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, Using the Consolidated Line Item Improvement Process

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Enclosure:

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL CONSIDERATION

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