Text

Proposed Tech Specs Chapters 3.4,3.5,3.6,3.7,4.0 & 5.0, Converting to ITS
	ML20209B816
Person / Time
Site:	Farley
Issue date:	06/30/1999
From:	; SOUTHERN NUCLEAR OPERATING CO.
To:	;
Shared Package
ML20209B813	List: L-99-024, Responds to NRC RAI Re Conversion to ITS for Chapters 3.4, 3.5,3.6,3.7,3.9 & 5.0,per 990419-20 Meetings with NRC; ML20209B816;
References
	NUDOCS 9907080150
	Download: ML20209B816 (102)
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e FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS 4

1 CTS 3/4.4.1.2 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION HOT STANDBY :

FNP ITS 3.4.5 RCS LOOPS - MODE 3 )

DOC NO SJiE DISCUSSION ,

STS. CTS 4.4.1.2.2 verifies the required RCS loops in operation. The i phrase "and circulating reactor coolant" is removed from the surveillance. !

The circulation of reactor coolant is inherent in the operation of an RCS loop. The STS bases description for this surveillance contains an explanation for verifying a loop is operating which includes the l confirmation of RCS flow. CTS surveillance 4.4.1.2.3 specifies a l verification of steam generator level. The surveillance wording is revised by removing "shall be determined operable" which results in the j requirement to simply verify level. Statements regarding the operability of the steam generators are contained in the STS bases. Placement of this information in the bases is acceptable based on the level of change control j provided by the bases control program in the administrative controls section of the STS.

i 8 M The

footnote to CTS 3.4.1.2 LCO which allows both reactor coolant 1 pumps to be de-energized for 1 bour is revised consistent with the STS.

The footnote is moved up into the LCO, reworded and formatted according to the STS. Additionally the note is revised to add the STS restriction "per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period" to the 1 bour allowance for both required reactor coolant i pumps to not be in operation. The STS restriction of once per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provides assurance that the allowance provided by the note is limited and the required reactor coolant pumps are not stopped too frequently. As such l g}

this STS restriction is appropriate and applicable to FNP. Since the addition of this provision of the STS introduces a restriction in the TS, it is

((QM considered a more restrictive change.

9 M The requirement for secondary side water level in CTS surveillance 4.4.1.2.2 is revised from 10% wide range to 28% narrow range consistent with FNP-specific calculations. The STS Bases for SR 3.4.5.2 state that the purpose of the requirement for SG secondary side water level is to provide an alternate heat sink. If the SG tubes become uncovered, the associated

- _ = _ , _ _

m . - - = loop may not be capable of providing this. heat sink._T.o. maintain - __,

consistency with the Bases for STS SR 3.4.5.2, calculations were performed to determine the SG water level necessary to ensure that the tubes remain covered in Modes 3,4, and 5. Due to the fact that the narrow range SG level transmitters are hot calibrated and the wide range SG level transmitters are cold calibrated, a single level value related to a single Chapter 3.4 E2-3-D June,1999

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.1.2 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION HOT STANDBY FNP ITS 3.4.5 RCS LOOPS - MODE 3 DOC HQ .SHE DISCUSSION indicator cannot be used through all Modes. The change in temperature and density of the fluid introduces significant inaccuracies in the indicated level as the actual fluid conditions deviate from the conditions at which the transmitters were calibrated. Therefore, the required SG water level is pb based on the narrow range indication in Mode 3 and on the wide range Fj h indication in Modes 4 and 5. The wide range value associated with ITS LCOs 3.4.6 and 3.4.7 is 74% as discussed in the associated DOCS. Since geW 28% narrow range level is greater than the current level in the CTS, this change, to conform with the intent of the STS, is seen as more restrictive.

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E2-4-D June,1999 i Chapter 3.4 l

M RCS Loops - MODE 3 3.4.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.5.2 Verify steam or secondary side water 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months levels are a: 17] or required RCS loops.

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SR 3.4.5.3 Verify correct breaker alignment and Z 7 days indicated power are available to the required pump that is not in operation.

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FNP TS Conversion Enclosure 5 - JD from STS j Chapter 3.4 - RCS STS 3.4.5 RCS LOOPS - MODE 3 l FNP ITS 3.4.5 RCS LOOPS - MODE 3 JD NUMBER JUSTIFICATION i

1 The word " required"is inserted in Condition D of LCO 3.4.5 RCS Loops Mode 3 to modify the two RCS loops inoperable condition. The addition of the word

" required"in the Condition D statement is consistent with the Condition A statement and use of" required RCS loop". Since only two of the three total RCS j loops are required operable by the LCO statement, the Conditions in this LCO g should specify " required RCS loops" (one loop may be inoperable without entering an LCO Condition). The addition of the word " required" provides a clarification to 4 Condition D consistent with the intent of the LCO and the use and application of f

2 The requirement for secondary side water level in SR 3.4.5.2 is revised from the CTS value of 10% wide range to 28% narrow range consistent with FNP-specific calculations. The STS Bases for SR 3.4.5.2 state that the purpose of the requirement for SG secondary side level is to provide an alternate heat sink. If the SG tubes become uncovered, the associated loop may not be capable of providing this heat sink. To maintain consistency with the Bases for STS SR 3.4.5.2, calculations were performed to determine the SG water level necessary to ensure that the tubes remain covered in Modes 3,4, and 5. Due to the fact that the narrow range SG level transmitters are hot calibrated and the wide range SG level transmitters are cold calibrated, a single level value related to a single indicator l cannot be used through all Modes. The change in temperature and density of the fluid introduces significant inaccuracies in the indicated level as the actual fluid i conditions deviate from the conditions at which the transmitters were calibrated.

Therefore, the required SG water level is based on the narrow range indication in Mode 3 and on the wide range indication in Modes 4 and 5. The wide range value associated with ITS LCOs 3.4.6 and 3.4.7 is 74% as discussed in the associated JDs. Since 28% narrow range level is greater than the current level in the CTS, this change, to conform with the intent of the STS, is seen as more conservative.

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ES-1-D June,1999 Chapter 3.4

Sih RCS Loops - MODE 3 8 3.4.5 BASES SURVEILLANCE SR 3.4.5.2 U REQUIREMENTS (continued) SR 3.4.5.2 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensul ng that the secondary side riarrow range. water level is a 17 % for required RCS loops. .

If th SG secondary side < narrow range water level is 7 %, the tubes may beEome uncovered and the associated loo may not be capable of providing the heat sink for removal of the decay heat. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available T5c.-2 in the control room to alert the operator to a loss of SG level.

g SR 3.4.5.3 l W Verification that the required RCPs are OPERABLE ensures that safety analyses limits are met. The requirement also i 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.

REFERENCES None. l l

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WOG STS B 3.4-26 Rev 1, 04/07/95

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Associated Package Changes for RAI- 11 Revised Response l

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F FNP TS Conversion

. Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.4 PRESSURIZER FNP ITS 3.4.9 PRESSURIZER DOC HQ SiiE DISCUSSION 5 A. The CTS

footnote to LCO 3.4.4 that provides exceptions for the pressurizer level limit is revised consistent with the STS. The

footnote is moved into a note in the applicability of the TS to conform with the presentation and format of such information in the STS. The technical --

' intent of the note remains unchanged. As such, this change is considered administrative.

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i Chapter 3.4 E2-2.J June,1999

9 FNP TS Conversion

. Enclosure 3 - Significant Hazards Evaluations Chapter 3.4 - RCS III. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS CTS 3/4.4.4 PRESSURIZER FNP ITS 3.4.9 PRESSURIZER b-L Deleted 0

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Chapter 3.4 E3-1-0 June,1999

l g Pressurizer 3.4.9 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Pressurizer ,

I LCO 3.4.9 The pressurizer shall be OPERABL with:

a. Pressurizer water level :s; 92) ; and ,

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[' > b. Two groups of pressurizer heat sO RABL with the capacity of each group 2 125 kW and able of being powered from an emergency power supply .

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heaur #4ed \e.ei bM Aoes no+of@fT APPLICABILITY: MODES 1, 2, and 3. o . THEAmA PoWsR. eq > 5% AP pen enhj er

b. Tr4EArne P*WEA s+e

, ___. ---.. .P >10%- - RT-ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressurizer water A.1 Be in MODE 3 with 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months level not within reactor trip breakers limit. open.

E A.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B. One required group of B.1 Restore required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months pressurizer heaters group of pressurizer inoperable. heaters to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion...

Time of Condition B E not met.

C.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

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SURVEILLANCE REQUIREMENTS SURVEILLANCE [ FREQUENCY SR 3.4.9.1 Verify pressurizer water level is :s; 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.9.2 Verify capacity of each r uir d group of 92 days pressurizer heaters is a 125 kW.

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FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.4 - RCS STS 3.4.9 PRESSURIZER FNP ITS 3.4.9 PRESSURIZER JD NUMBER JUSTIFICATION 1 TSTF-94 not incorporated. This TSTF is meant to address the licensing basis of older plants which only required minimum capacity and no minimum number of groups. This does not apply to FNP and has therefore not been incorporated.

2 TSTF-93 not incorporated. The reviewers note for TSTF states that for dedicated safety related heaters, which do not normally operate,92 days is applied. The purpose of this TSTF is to allow plants with non-dedicated safety related heaters, which normally operate, to extend the frequency of the surveillance to 18 months. l At FNP, heater groups A and B are dedicated safety related heaters, therefore, the 92 day frequency is maintained and the TSTF has not been incorporated.

3 The ITS LCO 3.4.9 Applicability is revised by the addition of a note based on the CTS 3/4.4.4, Pressurizer,

footnote to the LCO. This note is specific to FNP, and provides an exception to the LCO requirement of s 63.5% indicated pressurizer level for Thermal Power ramp change in excess of 5% Rated Thermal Power per minute or a Thermal Power step change in excess of 10% of Rated Thermal Power. !

The allowance provided by the CTS note is necessary since the ITS LCO requirement is very close to the maximum programmed pressurizer level which is affected by changes in power. Maintaining the allowance provided by the CTS footnote for power changes maintains the Farley current licensing basis.

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Chapter 3.4 E5-1-G June,1999

l Pressdrizer B 3.4.9 w%n.% st sures -Suk~ <>~ SW BASES T5TF-L2_ bv%k ud W 4ke. pmsau BACKGROUND egt 6 a loss of single phase natural circulation and decreased (continued) capability to remove core decay heat.

APPLICABLE In MODES 1, 2, and 3, the LCO requirement for a steam bubble SAFETY ANALYSES is reflected implicitly in the accident analyses. Safety. f analyses performed for lower MODES are not limiting. All analyses performed from a critical reactor condition assume 6gp the existence of a steam bubble and saturated conditions in the pressurizer. In making this assumption, the analyses

/,5 neglect the small fraction of noncondensible gases normally j present.

/ Safety analyses presented in the FSAR (Ref.1) do not take credit for pressurizer heater operation; however, an implicit initial condition assumption of the safety analyses is that the RCS is operating at normal pressure.

y' The maximum pressurizer water level limitkatisfies Criterion 2 of the NRC Folicy Statement. Although the A*#. heaters are not specifically used in accident analysis, the ,

@c need to maintain subcooling in the long term during loss of 1

0 offsite power, as indicated in NUREG-0737 (Ref. 2), is the

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LCO The LCO requiremen e pressurizer to be OPERABLE with 3,57, s wate volume :s; 12401 cubic feet, which is equivalent to n yuded 92 , ensures tha steam bubble exists. Limiting the LC0 max mus operating water level preserves the steam space for pressure control. The LCO has been establ.ished to ensure the capability to establish and maintain pressure control 0 for steady state operation and to minimize the consequences

(/ of potential overpressure transients. Requiring the presence of a steam bubble is also consistent with analytical assumptions.

p.11N The LCO requires two gr ps f OPERABLE pressurizer heaters, each with a capacity ;a: 12 kW, capable of being powered

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.,20. g + ~ from:either-the offsit power source.or the, emergency _ power- =

g ll, ad-u. supply. The minimum heater capacity required is sufficient gleif# to maintain the RCS'near normal operating pressure when g,98~ W accounting for heat losses through the pressurizer insulation. By maintaining the pressure near the operating (continued)

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sah e a THEA% PoWEA eq > h RTP per minok' er.

o MWAL PoWEA shp 5 go"h r<pp, The$8 c.FdbSS N PrWN skod- krm per4A&s.

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L0 conditions, a wide margin to subcoolin an be obtain in h'

'94h8 (continued) the loops. The exact design value of/ 25 kW is der ed P '

p3g6 from the use of seven heaters rated at 17.9 kW eae .

amount needed to maintain pressure is dependent on he heat The

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./5 losses.

PPLICABILITY The need for pressure control is most pertinent when core heat can cause the greatest effect on RCS temperature, resulting in the greatest effect on pressurizer level and RCS pressure control. Thus, applicability has been designated for MODES I and 2. The applicability is also provided for MODE 3. The purpose is to prevent solid water RCS operation during heatup and cooldown to avoid rapid pressure rises caused by normal operational perturbation, such as reactor coolant pump startup.

W- I In MODES 1, 2, and 3, there is need to maintain the availability of pressurizer heaters, capable of being powered from an emergency power supply. In the event of a loss of offsite power, the initial conditions of these MODES give the greatest demand for maintaining the RCS in a hot pressurized condition with loop subcooling for an extended period. For MODE 4, 5, or 6, it is not necessary to control pressure (by heaters) to ensure loop subcooling for heat transfer when the Residual Heat Removal (RHR) System is in service, and therefore, the LC0 is not applicable.

ACTIONS A.1 and A.2 Pressurizer water level control malfunctions or other plant evolutions may result in a pressurizer water level above the T37 th t. nominal upper limit, even with the plant at steady state conditions. Normally the plant will trip in this event since the upper limit of this LCO is the same as the 4k Pressurizer Water Level - High Trip.

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pA o. . If the pressurizer water level is not within the limit, N'E

action must be taken gto restore the plant to operatio

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Mnb e'= Itnin-theebounas or-tne= safety anelyseseTo.ashieve-this~ - -

go do e6 status, the unit must be brought to MODE 3, with the reactor trip breakers open, within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within g o,N t1, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This takes the unit out of the applicable MODEg (continued)

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FNP TS Conversion l Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.5 RELIEF VALVES FNP ITS 3.4.11 PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs)

DOC N_Q .SBE DISCUSSION STS. In the STS exceptions to LCO 3.0.4 are staced in Notes. This change 3

I is an administrative revision made to conform with the format and g presentation of this information in the STS.

b 5 A CTS suiveillance 4.4.5.1.a is revised by the addition of a Note that allows entry into Mode 3 in order to perform this surveillance, consistent with the STS, as modified by TSTF-288, Rev.1. The CTS surveillance requires this surveillance to be performed in Modes 3 or 4. Performance of the surveillance in these Modes ensures the uncertainty that would be introduced by testing the PORVs at lower system temperatures is limited.

The addition of this note is consistent with the STS and the intent of the CTS (i.e., performance of this surveillance in Mode 3 or 4). Therefore, the addition of this note is considered an administrative change made to l conform with the format and presentation of this information in the STS.

Sa L CTS surveillance 4.4.5.2 is revised by the addition of a Note that allows entry into Mode 3 in order to perform this surveillance, consistent with the STS, as modified by TSTF-288, Rev.1. Performance of the surveillance in Mode 3 ensures the uncertainty that would be introduced by testing the PORVs at lower system temperatures is limited. The addition of this note is consistent with the STS. The addition of this Note allows startup into Mode 3 if the SR has not been performed during the normal frequency but limits the exception to prior to entering Mode 2. As the addition of this note provides for consistency with similar requirements for the PORVs in the CTS, this change is applicable to FNP. However, the addition of this note provides an allowance not currently available in the CTS and therefore is considered a Less Restrictive change.

6 L The CTS surveillance 4.4.5.1.c which requires a Channel Calibration of the PORV actuation instrumentation be performed every 18 months is deleted from the TS consistent with the STS. This surveillance serves to confirm operation of the PORV automatic actuation instrumentation. However, automatic actuation of the PORVs is not an assumption of the applicable

-._-.,_ . , , . , ~

design basis accidents or-transients.-PORV operability;for the TS is--

dependent on manual actuation, which continues to be verified every 18 months by required surveillance testing (FNP ITS SR 3.4.11.2). As such, the CTS Channel Calibration requirement is not required in the TS to confirm PORV operability and is removed.

Chapter 3.4 - E2-2-K June,1999

FNP TS Conversion

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Enclosure 3 - Significant Hazards Evaluations j

Chapter 3.4 - RCS III. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS l CTS 3/4.4.5 RELIEF VALVES 4< FNP ITS 3.4.11 PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs) la-L

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

The proposed change allows entry into the mode of applicability of the TS prior to performing the PORV block valve surveillance, while ensuring that the surveillance is performed prior to Mode 2 entry. Neither the affected surveillance nor the allowed time to complete it are assumed to be precursors or initiators of any analyzed event. As such, the proposed change does not affect the probability of any of the initiating events assumed in the accident analyses. The proposed change will continue to maintain an acceptable level of safety by ensuring that the surveillance is performed prior to Mode 2 entry while allowing performance of the surveillance at conditions which are close to operating conditions, thus reducing the uncertainty that would be introduced by testing the PORV block valves at lower system temperatures. Evaluated accident dose levels are unaffected by this change.

Consequently, the proposed change will not have any effect on the consequences of any accident previously evaluated. Therefore, the proposed change does not involve a significant increase in the probability or consequences of any accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident fron.

any accident previously evaluated?

The proposed change involves upgrading the Pressurizer PORV TS to more closely agree ;

with the STS and does not introduce any new equipment into the plant or alter the manner in 1 which existing equipment will be operated. Therefore the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated. 1

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

The proposed change, which upgrades the Pressurizer PORV TS to be consistent with the STS does not involve a significant reduction in a mr*,in of safety. Although the proposed change allows entry into the mode of applicability W e TS prior to performing the PORV block valve surveillance, it ensures that the surveih, a is performed prior to Mode 2 entry.

'--- Thu most likely outcome of an Turveillanc~e is'that it demonstratef5pefability." Allowing ~

entry into Mode 3, while prohibiting entry into Mode 2, has no impact on any safety analysis.

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

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Chapter 3.4 E3-3-H June,1999

Pressurizer PORVs 73 3.4.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME F. (continued) F.2 Restore one block 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months i valve to OPERABLE og i statusj[if three I i

@ lock valves are linoperable]I c 3

'AND 1

F.3 Restore rem 'ng 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months block valv s to OPERABLE sta us.

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

G.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SVRVEILLANCE REQUIREMENTS

,$ SURVEILLANCE FREQUENCY d 2 M ab I SR 3.4.11.1 -------------------NOTE--------------------

Not required to be met with block valve be d closed in accordance with the Required pri~6c%

ing g,ge 3'

, Action of Condition B or E. s s------------------------------------------

GTF-2R?,

i Perform a complete cycle of each block 92 days Rev.)

valve.

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.y 3.4.11.2 'Pe rm a complete-cycle of each PORV months

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"$C Pressurizer PORVs B 3.4.11

' BASES (continued)

L SURVEILLANCE SR 3.4.11.1 REQUIREMENTS j Block valve cycling verifies that the valve (s) can be closed if needed. The basis for the Frequency of 92 days is the ASME Code,Section XI (Ref. 3). If the block valve is closed to isolate a PORV that is capable of being manually 97f g' cycled, the OPERABILITY of the block valve is of importance,

, because opening the block valve is necessary to permit the PORV to be used for' manual control of reactor pressure. If T65 SR. s's moASd the block valve is closed to isolate an otherwise inoperable y % weg PORV, the maximum Completion Time to restore the PORV and open the block valve is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , which is well within the l allowable limits (25%) to extend the block valve Frequency of 92 days. Furthermore, these test requirements would be I

/ completed by the reopening of a recently closed block valve upon restoration of the PORV to OPERABLE status (i.e.,

completion of the Required Actions fulfills the SR).

9- Not odifies 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. g

% e ' 9 o R V d e- rugey n 5 E#'I 54f*h 165f8A Add 3 SR 3.4.11.2 3 S 3 *# N SR 3.4.11.2 requires a complete cycle of each PORV. '" 4

@M Aito, M momOperating a PORV rough one complete cycle ensures that the

" {i.% clos,A in - ,PORV can be manu y*> actuated for mitigation of an SGTR.

gp .b hht}- "The Frequency of 85 months is based on a typical refueling TM-22,

. cycle and industry accepted practice 48 l 4

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[0kra on the air accumu a enoid air control valves a res control system valves actuates properly whe The Frequency of f

by b aM [18] months i Frequ

. on a typical re the other Surveillances used to cycle and th trate h, g _

OPERABILITY.

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This Surveillance is no trifed o with permanent

_ IE power suppli e valves. __y_

(continued)

WOG STS B 3.4-56 Rev 1, 04/07/95 f

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CHAPTER 3.4 j ~T37F 28),

M INSERT NA kpy#* TO STS BASES PAGE B 3.4-56 SR 3.4.11.1 NOTE Note 2 modifies this SR to allow entry into and operation in MODE 3 prior to performing the SR. This allows the test to be performed in MODE 3 under operating temperature conditions, prior to entering MODE 1 or 2. ,

l INSERT OA TO STS BASES PAGE B 3.4-56 SR 3.4.11.2 NOTE The Note modifies this SR to allow entry into and operation in MODE 3 prior to performing the SR. This allows the test to be performed in MODE 3 under operating temperature conditions, prior to entering MODE 1 or 2.

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Associated Package Changes for RAI- 23 Revised Response i

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.2 OPERATIONAL LEAKAGE UNIT 1 AND 2 FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3114 RCS PRESSURE ISOLATION VALVE LEAKAGE FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW DOC HQ .SJE DISCUSSION ,

3 A The CTS 3/4.4.7.2 Mode of applicability is revised for the new PIV LCO 3.4.14 consistent with the STS. A clarification is made for Mode 4 regarding those PIVs in the RHR flow path during or when transitioning to or from the RHR mode of operation. This note provides the clarification that if the RHR system is in operation, or being placed in or taken out of operation, the associated valves are not expected to meet the leakage limits of the PIV LCO. This STS clarification conforms to normal operating practice and the operational requirements for the RHR system and maintaining reactor decay heat removal. It is also consistent with the

footnote to CTS Table 3.4-1 which serves as an exception to the PIV leak test requirements (4.4.7.2.2.c) following actuation or flow through the valves for valves used in the RHR flow path. The clarification provided by this note conforms to existing operational and TS requirements as currently implemented at FNP. As such, this change is considered administrative.

4 A The CTS 3/4.4.7.2 actions applicable to the PIVs are modified by two Notes consistent with the STS. The CTS actions for PIV leakage not within limit allow 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to isolate the affected flow path. Consistent with the format and presentation of the STS for actions that may be applied to a number of items, the proposed STS note 1 clarifies that the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months completion time is applied separately to each PIV flow path. The proposed note 1 only clarifies current FNP practice and interpretation of this CTS requirement in STS terms. The proposed Note 2 requires the applicable conditions and actions for the systems made inoperable by an inoperable PIV to be entered. The requirement for this note is a result of the STS LCO 3.0.6 (which limits cascading inoperabilities between systems) and the STS conventions resulting from the implementation of LCO 3.0.6. As such, the m, _incoipgration of these notes in tpe FNP ITS,is considered an administrative change to conform with thEformat and presentation of this uifodilation m the STS.

5 M The CTS 3/4.4.7.2 Action c for an RCS PIV that does not meet the leakage limits is modified by a note consistent with the STS. The STS note in corresponding STS 3.4.14 Condition A is revised by the deletion of the Chapter 3.4 E2-2-N March,1998

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.2 OPERATIONAL LEAKAGE UNIT 1 AND 2 FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE f FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE LEAKAGE FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW DOC 1 HQ SHE DISCUSSION portion of the note that requires the valves used to isolate the leaking PIV be previously tested. If Required Action A is entered, the valves will be tested at that point via the methodology of SR 3.4.13.1 (RCS water inventory balance) with the leakage limits of SR 3.4.14.1 applied. The portion of the STS Note which specifies that the valves used to meet Required Actions A.1 and A.2 be valves in the RCS pressure boundary or in the high pressure portion of the system is retained in the FNP ITS. As such, the resulting FNP ITS 3.4.14 Condition A Note restricts the valves which may be used to meet the isolation requirements of the Actions to those valves capable (pressure rated) ofisolating the high pressure of the RCS boundary and shown upon use to meet the leakage criteria. As the requirement is an addition to the CTS requirements, it is therefore considered a more restrictive change to the TS.

6 L The CTS 3/4.4.7.2 action for an RCS PIV that does not meet the leakage limits is revised consistent with the STS. The CTS actions require that the affected flow path be isolated by two valves within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The STS actions require that the flow path be isolated by one valve within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and a second valve within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The STS allowance of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to isolate the flow path by a second valve is reasonable and provides an acceptable level of safety given tb flow path is isolated by a single valve and the low likelihood of failure of a second valve during the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months interval.

7 L The CTS 34 4.7.2 action for an RCS PIV that does not meet the leakage limits is revised consistent with the STS. The CTS actions require the use of cloced manual or deactivated automatic valves to isolate the affected flow path.' The STS provides for the explicit use of check valves in

- maddition to the CTS specified manual and deactivated automatic. valves. .- - , '

The allowance to use check valves for isolation purposes is acceptable based on the fact that 16 of the 20 RCS Pressure Isolation Valves listed on CTS Table 3.4-1 are check valves. The use of these valves to isolate the affected flow path is acceptable due to the fact that dual isolation valves are required by the action and that the check valve (s) used will have been Chapter 3.4 E2-3-N June,1999

RCS PIV Leakage

~

7qg l 3.4.14 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.14 RCS Pressure Isolation Valve.(PIV) Leakage LC0 3.4.14 Leakage from each RCS PIV shall be within limit.

APPLICABILITY: ' MODES 1, 2, and 3, MODE 4, except valves in the residual heat removal (RHR) flow path when in, or during the transition to or from, the RHR mode of operation.

ACTIONS

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

1. Separate Condition entry is allowed for each flow path.

2. Enter applicable Conditions and Required Actions for systems made inoperable by an inoperable PIV.

CONDITION REQUIRED ACTION COMPLETION TIME

~A. One or more flow paths ------------NOTE----- -------

be with leakage from one Each valve used to satisfy '

or more RCS PIVs not Required Action A.1 and within limit.- Requ Action A.2 must e erified to' meet SR.3.4.14.1 and be in the reactor c

[43 g,g bc M boundaryholantpressure re the high portion of the q

(continued)

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FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.4 - RCS l STS 3.4.14 RCS PRESSURE ISOLATION VALVE (PIV) LEAKAGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE (PIV) LEAKAGE JD ~

NUMBER JUSTIFICATION 1 The STS LCO 3.4.14 Condition A actions allow a choice of actions to be made for Required Action A.2. The FNP CTS allow continued operation when the affected flow path is isolated by two valves. As such the first A.2 Required Action is applicable to FNP and more consistent with the CTS than the second Required Action A.2.

la The STS 3.4.14 Note in Condition A is revised consistent with the corresponding CTS requirements. The STS note requires that valves used to satisfy Required Action A.1 or A.2 must have been verified to meet SR 3.4.14.1 and be in the reactor coolant pressure boundary or the high pressure portion of the system. The corresponding CTS requirements do not specify that valves used to isolate the high pressure portion of the system from the low pressure portion be previously tested.

The FNP CTS Actions and the corresponding STS Actions require that the valves used to meet the Action isolate the PIV leakage. Failure to isolate the leakage (meet the requirements of the LCO)is failure to meet the Action requirements of p Condition A and would result in entry into Condition B and a plant shutdown.

9'-

p th[4isolation Since valves are closed and verified to be within the LCO limits, the FNP in order current practice effectively to meet verifies the isolation capability ofthe isolation the valves when they A are actually used to meet the Action requirements. Therefore, the Note is revised to state that the valves used to satisfy Required Action A.1 or A.2 must be verified to meet SR 3.4.14.1. This is accomplished by using the methodology of SR 3.4.13.1 (RCS water inventory balance) with the leakage limits of SR 3.4.14.1 applied. The 1 FNP current practice and CTS requirements are adequate to address PIV leakage and the deletion of the STS requirement to only use valves previously tested per SR 3.4.14.1 is consistent with the FNP current licensing basis.

2 The STS SR 3.4.14.2 (FNP ITS 3.4.14.3) is revised consistent with FNP terminology for the RHR isolation valve open permissive interlock function. 'Ibe i FNP-specific RCS pressure range for the open permissive interlock is inserted in place of the single value in the STS.

. ~ . . . . _ . -

3 The S.TS SR 3.4.14.1,.frequenc.ies on p, age 3.4-37 of.the PIV Leakage TS are revised ,

on page 3.4-37 are revised to be consistent with the CTS surveillance req 1irements of 4.4.7.2.2.a and 4.4'7.2.2.d.

4 The STS surveillances 3.4.14.2 and 3.4.14.3 (FNP ITS SR 3.4.14.3 and 3.4.14.2),

which verify the operability of the RHR/RCS open permissive and autoclosure Chapter 3.4 ES-1-K June,1999

)

RCS PIV Leakage N 2 3.4.14 BASES o - ACTIONS degraded the ability of the interconnected system to perform (continued) its safety function.

Q fe p* A.1 and A.2 The flow path must be isolated by two valves. Required Actions A.I' and A.2 are modified by a Note that the valves used for isolation must meet thi sanfe'leakag'e requirements asthePIVsandmustbewithintheRCP8qprthehigh ,

l pressureportionofthesystem%j p

\ b"> b " Required Action A.1 requires that the isolation with one M % dod & valve must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Four hours provides

% p5% ddStj time tr' reduce leakage in excess of the allowable limit and to isolate the affected system if leakage cannot be reduced.

g' 3 g fe.p The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time allows the actions and restricts bypedoFc+'N the operation with leaking isolation valves.

Onen A a enh,J RgM J M[9Required Action A.2 specifies that the double isolation

[barrieroftwovalvesberestoredbyclosingsomeother

& Mad valve qualified for isolation or restoring one leaking PIV. i dadd, 4h6 The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time after exceeding the limit '

vdus Ju b6 ; considers the time required to complete the Action and the (

y;ggg loQrobability of a second valve failing during this time Q .{.;n 4. md t I '

(wH '

4?

I The 72 hou Completion Time /t er exceeding the imit allo sg 3N.W.). for the r storation of the aking PIV to OPE LE status

$i , ;3 ,

/ This ti fram'e considers t time required to omplete t s Action nd the low probab' ity of a second v ve failin d 6 /

durinc this period. (Re ; ewer Note: Two o ions are me[mAdo prov ed for Required A ion A.2. The sec d option ofr sR,34,g o, (72 our restoration) s appropriate if i lation of a g Ac se and valve would pl ce the unit in an analyzed c ndition.)

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,g3gg7 - ,..If~1eakagecannotbereduced,d he_ system. isolated, or,the mw m.m.,

other Required Actions accompl'shed, the plant must be -

"??g

brought to a MODE in which the requirement does not apply.

To achieve this status, the plant must be brought to MODE 3 (continued)

WOG STS B 3.4-82 Rev1,04/07/95

hmx -tk w.bes eeA 4o Isod -h-Clao p :4 to W3 379 Pqd Aub M M A.2.% nd kne, h be. pre-g.-Med S PIV Leakage bat perioM. 4edig. A ghJ Ah g ,3 e&@ .a-k 3.4.14 cMew FA l'oldd % w.\ves wHl be vedad d A+ Ge 4e med %c yg BASES jyyg l.Atj v3i % n4 9zy$)

1%gy,g,,gej ve h ods J 5R 3.

gg,3g,33,,ggc3 w,4 ,.,,, 4 w .l. % h ou. w %4,3_q, ,3 =

ACTIONS es_dSg74M g) = -

B.1 and B.2 (continued M.3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This Action may pW reduce the leakage and also reduces the potential for a LOCA outside the containment. 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.

OT'6C4 we e<.Wiy J M. F.R open permhee Alo

% g% ss.aaa asa -s m a y

W. 4de\t. }

g. g The inoperabil a'u toc osure nterTtrek Tewders.

the*RHR suction isolation valves incapabl of isolating in i reventing' response to a high pressure condition, t o,rt \ inadvertent opening of the valves at RCS press ~ures'in excess ..

of the RHR s ems design pressure. If the RHR autoclosure interloc inoperable, operation may continue as long as opofenpvmdne .

the_ affecfed'RHR suctioppiinetration is closed by _at leas ygne closed manuai nr nanctivated automatic valve /Within isha tthe DSELT FA 1

('4autoclosuriWTunction.

hours. This Action a pdoP #54' purpose of the M7 Mes ne closeA a. # mh oAUt cadrols .se in pb.ce cw%

SURVEILLANCE S icy! Y ) room % swM %em c% sed. (e.g.ps REQUIREMENTS Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 and Required Action A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. e leakage limit of 0.5 gpm per inch of nominal valve diameter cc 3 # up to*5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition.

(' For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by

.i~.-_.....~.....~-.

redundant valves would be lost. fh .

. . . . . , . , , c.,

Testing is to be performed eve /y $180 months, a tvoical refueling cycle. Af ttre plant does not 00' inth M00E/5 f#r at)

C Qq'astg dayyy.ffhe 18 mont frequency is consistent with (continued)

WOG STS B 3.4-83 Rev1,04/07/95

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.5 - ECCS CTS 3/4.5.1 ACCUMULATORS FNP ITS 3.5.1 ACCUMULATORS DOC NO .SEE DISCUSSION (accumulator isolation valve being closed). CTS action statement b is l deleted. The net effect of this change results in the allowed outage time for I a closed isolation valve being increased to I hour from immediately. This change is consistent with the STS policy to apply a reasonable allowed outage time where possible to avoid requiring the initiation of a plant {

shutdown and therefore limit the risk introduced by unnecessary plant transients. The proposed change allows a reasonable time to take corrective j actions such as closing a breaker or replacing fuses prior to requiring a plant to commence a shutdown. In addition, the proposed completion time of 1 ,

hour is a sufficient restriction, considering the small likelihood of a severe {

transient occurring in this time, to avoid an undue risk to public health and i safety.

l 4 L CTS 3.5.1 action statement a is further revised consistent with the STS to more precisely specify the required action to remove the unit from the j applicability of the TS. The CTS action requires the unit to ultimately be placed in Mode.4. The definition of each operating Mode is based on temperature not pressure. The applicability of this CTS is based on pressurizer pressure (above P-11 setpoint,2000 psig) in Mode 3. To be

- 4'[

f consistent with the CTS limit and STS format, the action to place the unit in Mode 4 would be replaced with the action to reduce pressurizer pressure to s 2000 psig. However, WCAP -12476, " Evaluation of LOCA during Mode 3 and Mode 4 Operation for Westinghouse NSSS," which is applicable to l

FNP, assumes that the accumulators are unisolated and operable down to 1000 psig. FNP has elected to change the limit of applicability from 2000 l psig to 1000 psig in keeping with the STS and the assumptions of this WCAP. Therefore, the proposed action removes the unit from the applicability of the TS (Mode 3 with RCS pressure > 1000 psig). This l

change is consistent with the general rules of TS regarding the applicability of TS actions. Once the unit is removed from the applicability of the affected TS, further action under that TS is not required. This change, although consistent with the general rules of TS and the assumptions of

- _ . _ . s .

~~ WCAP-12476, represents a less restrictive change for FNP as the unit may m~ '

remain in Mode 3.

5 M A new Condition (STS Condition D) and actions are added to CTS 3.5.1 consistent with the STS. The new actions address the condition when more than one accumulator is inoperable. In the STS, each Condition specified in E2-2-A June,1999 Chapter 3.5

f

\

FNP TS Conversion j

' Enclosure 2 - Discussion of Changes to CTS Chapter 3.5 - ECCS l

CTS 3/4.5.1 ACCUMULATORS ,

1 FNP ITS 3.5.1 ACCUMULATORS l DOC F_Q SHE DISCUSSION the TS may be entered independently of the other Conditions in the TS.

Therefore, it is possible that two accumulators may be inoperable at the same time, one under STS Condition A, and one under STS Condition B.

In this situation, even the relatively short completion time of Condition B (1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) is not appropriate. The proposed STS Condition D addresses this situation by requiring immediate entry into LCO 3.0.3. Although a new requirement for FNP, and therefore, more restrictive, the addition of this l action is consistent with the importance of the accumulators in the FNP safety analyses and represents an appropriate action applicable to FNP.

6 M The CTS

footnote to the applicability is revised and moved into the applicability consistent with the STS. The CTS footnote specifies the applicable pressurizer pressure of the TS (above the P-11 setpoint). As such, and in conformance with the STS presentation and format of this information, the footnote is incorporated directly into the applicability of the TS. In addition, in order conform with the assumptions of WCAP-47 ,

y[if 12476," Evaluation of LOCA during Mode 3 and Mode 4 Operation for Westinghouse NSSS," which is applicable to FNP, and the STS, the setpoint of P-11 (or 2000 psig) is replaced by the value of 1000 psig. The FNP pressurizer pressure narrow range instrumentation range is 1700 to 2500 psig. The RCS wide-range 0 to 3000 psig pressure instruments are used for monitoring system pressure below approximately 1700 psig.

Therefore, since the applicability now extends down to 1000 psig, the note is also revised to indicate RCS pressure instead of pressurizer pressure.

This is consistent with TSTF-117. Incorporating these changes, the proposed applicability becomes Modes 1 and 2, and Mode 3 with RCS pressure > 1000 psig. As this change extends the applicability from Mode 3 above 2000 psig down to 1000 psig, it is considered a more restrictive change.

7 A CTS surveillance 4.5.1.1.b is revised consistent with the STS. This CTS surveillance verifies the boron concentration of the accumulators every 31 days and within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after-a specific addition is made to an accumulator.._

The STS contains a note that modifies the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months frequency part of this surveillance. The STS note explains that the requirement to verify boron I

I concentration 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after an addition is made to an accumulator is applicable only to the affected accumulator. This note provides a clarification consistent with the intent of the CTS (accumulators that do not E2-3-A June,1999 Chapter 3.5

3 6y A

hC Accumulators 3.5.1 f W )90$p@

O G 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.1 Accumulators Three J._

LC0 3.5.1 ((Four[ ECCS accumulators shall be OPERABLE. .

~B rF - Il'1 c5 ,

l APPLICABILITY: MODES 1 and 2, f

.,.. , 00 3 with 3 ur.i e res u e > 1000 psig.

' ow - _ _ _ _. _ __ ,

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ACTION J*_P_O*3 wHbRC.5gemre_ >, @ icoo_ esis,

,p I"_%{o m12 a n ethe oo

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-~sw v-e- vw CONDITION REQUIRED ACTION COMPLETION TIME A. One accumulator A.1 Restore boron 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable due to concentration to boron concentration within limits.

not within limits.

B. One accumulator B.1 Resto're accumulator 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months N -

inoperable for reasons to OPERABLE status, other than Condition A.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion T57-IO Time of Condition A MQ 8,C5 or B not met.

C.2 Redu e gressurng#[ _

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months pre sur to -

s 1000 psig.

D. Two or more D.1 Enter LC0 3.0.3. Immediately accumulators inoperable.

. _ , ~ ~.. _ ._ _ _ ._ _ . ~ . _ . ,. . _ _ . _ ______ -. -. j i

O l WOG STS 3.5-1 Rev 1, 04/07/95 i i

T hk Accumulators 3.5.1 SURVEILLANCE REQUIREMENTS (continued) _

SURVEILLANCE FREQUENCY SR 3.5.1.5 Ve'rify power is removed fro each 31 days l accumulator,tsolation valv oper tor,when i dFressurizeAressure is i 2000 psig.

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WOG STS 3.5-3 Rev 1, 04/07/95

FNP TS Conversion Enclosure 5 - JD from STS

< Chapter 3.5 - ECCS STS 3.5.1 ACCUMULATORS FNP ITS 3.5.1 ACCUMULATORS i JD NUMBER JUSTIFICATION l 1 An FNP specific note is added which is necessitated by the adoption of the 1000 psig applicability limit. The 1000 psig applicability limit has been adopted to conform to the assumptions of WCAP-12476," Evaluation of LOCA during Mode 3 and Mode 4 Operation for Westinghouse NSSS," which is applicable to FNP. The l

,l CTS Applicability of the Accumulator LCO in Mode 3 was P-11 or 2,000 psig.

Under the CTS requirement, routine RCS P1V leakage testing was performed on the 3 accumulator check valves which required the accumulator isolation valves to be ;

closed between 1,000'and 2,000 psig. In addition, the accumulators are cross- ]'

connected via small bore lines and the pressure adjusted to establish a differential l

pressure between accumulators. This differential pressure is used to test for leakage past the discharge check valves. The proposed FNP specific note modifying the Applicability of the Accumulators allows testing of the accumulator isolation valves I in Mode 3, with RCS pressure above 1000 psig, to continue to be performed in the I same manner as under the CTS. This note, including the time limitation, is consistent with the current RCS PlV leakage testing performed at FNP but j represents a restriction on the performance of this testing that was not in the CTS. l l

2 In the STS, SR 3.5.1.4 directs the verification of boron concentration in an accumulator based on a change in indicated level. CTS surveiliance 4.5.1.1.b uses percent of tank volume. To conform with the STS and to enhance the operators ability to easily determine when to verify accumulator boron concentration, a calculation was performed to determine what percent ofindicated level corresponded to a 1% change in tank volume. A change of 1% tank volume corresponds to a 13.3% indicated level change. Since the MCB indicator is divided into 2 % increments,12% indicated level change is used as the level at which to verify accumulator boron concentration. This number is slightly more conservative than the current 1% of tank volume. Since the CTS is based on a change in tank l volume and the number in the ITS markup is based on that change, the wording was revised to read as follows: "Once per 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after each solution volume increase of > or =: 12 % level, indicated, that is the result of addition from the refueling water i

storage tank." to clarify that it is speaking of an indicated level change of 12% vs. a change of 12% of the previously indicated level, Delete = ~

- - " ~ - -

m- _ _

3 P- ,

Chapter 3.5 E5-1-A June,1999

Ill

. CHAPTER 3.5 INSERT K TO STS BASES PAGE B 3.5-5 FNP SPECIFIC BASES FOR THE NOTE MODIFYING THE ACCUMULATOR LCO APPLICABILITY

@k The Accumulator Applicability is modified by a note which takes exception to the LCO requirements for the Accumulators to be OPERABLE in MODE 3, with RCS pressure above 1,000 psig for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months during the performance ofisolation valve testing required by SR 3.4.14.1. The applicability of the Note is restricted solely to the isolation valve testing required by SR 3.4.14.1. In order to perform the required isolation valve testing, the Accumulators must be isolated and various parameters (e.g., pressure, level) must be adjusted. The exception l

provided by this Note allows operation in MODE 3 with RCS pressure above 1,000 psig for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with Accumulators not configured per the requirements of the LCO such that the Actions for an inoperable Accumulator are not applicable.

_.m__,__m.. --m._. , _ . .m ;,, ._._.__._._.m.. .___,.;.

Chapter 3.5 Insert Page

IIB M

h -= -

Accumulators B 3.5.1 15A,l. 2. An o.vevge bonm caceMb @~ Sy- mjkfed wo.W ,s oswed in 4-e Sed-Ed4Lo ,4gg BASES ACTIONS M - (continued) D D,

j g reduced. Jhe oron i' the a cumulato s cont butes tofthe' Tssump ion th t the mbine ECCS wa r in e partia ly y

v Gs recov red co durin the rly ref1 oding ase of large p#g brea LOCA i suffi ent t keep th t portian of th cores M

dg .subc itical f One accumulato below the minimum boron 1d tD concentration limit, howeve will have no _effect on available

' ECCS water and an insignifi teffectonkoresuberiticality f P y,g jdn;_ r:f! red. f Bo' ling a tccs wa er in L core dJrin I

,rf t 1 d nc trat s bor.o ...in the. tur,a.te.d 1.iquid ,1at !

sec-RsA-tm-c.) /em ns n t e co l'In ddition current analisi tec iq es I de nst ate that ~ he acc mulator do not ischarg fol w.i g 'a 1 ain stea line b eak for he ma1 ity of ant . ve I k gethey do discharge) their impact is minor and not a design I

' limiting event. Thus, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to return the boron l concentration to withi limits. i

%e b.v.g. m4., sb.m Me k<eak .

~gh cam 4 % .+ b y. W

,s p* u we @ T C Q p M ' " " m * * +-

AL, If one accumula r is inoperable for a reason other than boron C/ concentration, the accumulator must be returned to OPERABLE status within hour. In this condition, the required contentsofq1re accumulators cannot be assumed to reach the core during a L CA. Due to the severity of the consequences should a LOCA occur in these conditions, the I hour Completion Time to open the valve, remove power to the valve, or restore the proper water volume or nitrogen cover pressure ensures that prompt action will be taken to return the inoperable accumulator to OPERABLE status. The Completion Time minimizes the potential for exposure of the plant to a LOCA under these conditions.

C.1 and C.2 If the accumulator cannot be returned to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant mjpt- be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and cressurizeopressure reduced to

.--i-.-- ,

,C . . - - . - . -

1 n-

'T4TF-1 O (continued)

WOG STS B 3.5-6 Rev1,04/07/95

MO .

Accumulators B 3.5.1 BASES (E7

=!ng!

(continued) sa35i4 The boron concentration should be verified to be within "

n. wh

~

required limits for each accumulator every 31 days sin the static design of the accumulators limits the ways in w ich the concentration can be changed. The 31 day Frequency i adequate to identify changes that could occur from mer hanisms pM1!

such as stratification or inleakage. Samplinythe af"ected I'24 J accumulator within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after aG% volumRncrease/ wills # l h identify whether inleakage has caused a reduction in baron concentration to below the required limit. It is not necessary to verify boron concentration if the added water Ts c-pWMn inventory is from the refueling water storage tank (RWST),

y k u.un the water contained in the RWST is within the accumulator boron concentration requirements. This is consistent with the recommendation of NUREG-1366 (Ref. .

SR 3.5.1.5 Verification every 31 days that power is removed from each

@ accumulator isolation valve operator when the pressurizer pressure is 2: 2000 psig ensures that an active failure could on not result in the undetected closure of an accumulator motor l

1 g' B[Q ecadnoperated isol ion valve. If this were to occur, only wo 0 fve. would be available for injection given a s ng e 150 - accumulato of6Ng#k'. failure coincident with a LOCAN Sin'ce power is removed under chS2 o ' administrative control, the 31 day Frequency will provide a Led 8 V# ~~' adequate assurance that ' wer emoved.

I cb M . This SR allows power to bs,su p

e W.O o the motor operated isolation valves whensressurize ressure is < 2000 psig, thus allowing operational flexibility by avoiding unnecessary 3f d,y delays to manipulate the breakers during )lant startuos or 6

N 6 % shutdowns.Evenwithpowersuppliedtotievalves,inaavertent clos associated with the valves;J P

Should c.losure of a valve occurtn spite of the interloch the SI signal provided to the valverYould open a closed valve in the event of a LOCA. -

,m ,

a, _b -e lo us 2. 6 f J

s , .: .

,. t.

(continued)

WOG STS B 3.5-8 Rev 1, 04/07/95 i

Chapter 3.6

- _ . _ - - , . - . . = . _ ,_ .=..==..=.- . . . . - - - - . - . = = .. = ~ . -....-

l l

l

Associated Package Changes for RAI-3.6.1-3 Revised Response I

l l

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.6 - Containment Systems CTS 3/4.6.1 CONTAINMENTINTEGRITY FNP ITS 3.6.1 CONTAINMENT DOC NQ SHE DISCUSSION 1 ~A The CTS 3/4 6.1 Containment Integrity LCO and Action Statements are revised consistent with the STS. The defined term of" Containment Integrity"is not used in the STS and has been deleted from the LCO and Actions. The term Operable is used in place ofintegrity. The LCO requirement for the system, structure, or component to be Operable is consistent with all STS LCO statements. As with other STS LCOs, specific operability considerations are discussed in the TS bases. The disposition of ,

the defined term " Containment Integrity" is discussed in Enclosure 2 of TS definitions section 1.0. The CTS defined term " Containment Integrity"is effectively retained in the STS surveillance requirements and the operability discussions in the STS bases. This change substitutes an STS term for a CTS term and is not intended to reduce the operability requirements for Containment. As this change is part of a re-organization of the presentation and format of the Containment section TS, it is considered an administrative change.

la A CTS 3/4.6.1 is revised to reflect the addition of a Farley-specific Condition l A in the FNP ITS LCO 3.6.1 consistent with the action statement of CTS 3/4.6.1.6. The DOC associated with this change to CTS 3/4.6.1.6 discusses 3 the addition of this new Condition. Since this change merely reflects the

@N7) p movement of current requirements to another location consistent with the F/b STS format and presentation (i.e., covering the requirement to maintain containment operable, including the structural integrity, in the containment specification) the associated change is considered an administrative change.

CTS 3/4.6.1 surveillance requirement 4.6.1.1.a is revised consistent with I 2' A i

the STS. The CTS surveillance ' verifies the status of containment penetrations and the position of the associated isolation devices outside of containment every 31 days. The requirements of this surveillance pertain to isolation devices and therefore have been moved to the Containment Isolation Valve TS (STS LCO 3.6.3). The requirements of this CTS surveillance, except for the requirements resulting from required actions gg95gj;,d'ih'SR 3.'6:3:2."The-~

i-~gggggg requirements of this CTS surveillance regarding deactivated automatic valves (inoperable valves deactivated in accordance with action requirements) are effectively retained in the STS LCO 3.6.3 Actions A.1 and A.2. As automatic valves are deactivated and secured in the closed E21-A June,1999 Chapter 3.6

FNP TS Conversion l

' Enclosure 2 - Discussion of Changes to CTS ]

Chapter 3.6 - Containment Systems CTS 3/4.6.1.2 CONTAINMENT LEAKAGE I FNP ITS 3.6.1 CONTAINMENT DOC j SiiE DISCUSSION NQ 1 A All the requirements of CTS 3/4.6.1.2, " Containment Leakage" are effectively incorporated into STS LCO 3.6.1 " Containment" consistent with the STS. In the STS, the leakage requirements of this CTS are considered ;

1 part of the containment operability requirements. The markup of CTS I 3/4.6.1.2 in Enclosure 1 indicates the corresponding requirements in the STS LCO 3.6.1 " Containment" that effectively address the CTS 3/4.6.1.2 requirements. As this change is part of the STS re-organization of the f presentation and format of the Containment TS section and is not intended {

to introduce a technical revision, it is considered an administrative change.

Ia A CTS 3/4.6.1.2 is revised to reflect the addition of a Farley-specific Condition A in the FNP ITS LCO 3.6.1 consistent with the action statement l of CTS 3/4.6.1.6. The DOC associated with this change to CTS 3/4.6.1.6 discusses the addition of this new Condition. Since this change merely g

Ad,3 reflects the movement of current requirements to ancther location consistent with the STS format and presentation (i.e., covering the requirement to gj maintain containment operable, including the structural integrity, in the containment specification) the associated change is considered an administrative change.

I l

l l

June,1999 Chapter 3.6 E2-1-B

i FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.6 - Containment Systems CTS 3/4.6.1.6 CONTAINMENT STRUCTURAL INTEGRITY FNP ITS -N/A DOC N_Q SHE DISCUSSION Surveillance Program," be reported to the NRC within 30 days. This STS reporting requirement constitutes an additional NRC notification beyond the current requirements of the CTS. Therefore, the requirements that remain in the TS effectively ensure the containment structural integrity continues to be determined in an acceptable manner. The removal of the details from CTS 3/4.6.1.6 and placement in a program outside of the technical specifications is acceptable based on the control provided by the associated surveillance requirements retained in LCO 3.6.1 and the surveillance program and reporting requirements in the administrative controls section of the TS.

2 A CTS 3/4.6.1.6 contains actions which allow 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore any non-conforming conditions before requiring a plant shutdown to Mode 5. These j CTS actions have been incorporated into a Farley-specific Condition A in y3 the FNP ITS LCO 3.6.1. Since this change merely moves current f+pg gc requirements to another location consistent with the STS format and presentation (i.e., covering the requirement to maintain containment pts operable, including the structural integrity, in the containment specification) the associated change is considered an administrative change.

3 A The shutdown requirements of CTS 3/4.6.1.6 are incorporated into the ITS LCO 3.6.1, Containment, Condition C consistent with Condition B of the STS. Since this change merely moves current requirements to another location consistent with the STS format and presentation, the associated change is considered an administrative change.

i I

i E2-2-F June,1999 Chapter 3.6

l47 ,,

Containment (Atmospheric,Subatmospheric,IceCondenser,andDual))

4.b.1 3.6 CONTAINMENT SYSTEMS L

3.6.1 Containmenthtmospheric,Subatmospheric,IceCondenser,andDualh LC0 3.6.1 Containment shall be OPERABLE.

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

ACTIONS REQUIRED ACTION COM ETION TIME CONDITION [

6' A Containment 1 Restore containment I hour inoperable. to OPERABLE status. 4 Required Action and associated Completion 4

[ Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months g

Time not met. 6.@

Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months A, S h uc. d in N 7k A.l Aesfort 4h6Shv M 2Y hovr3 d uec.m 6n'etd ingn'h io wen D

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~

l 2a5 Containment gtmospherico' i

o .s.o.1 BASES APPLICABLE The containment satisfies Criterion 3 of the NRC Policy SAFETY ANALYSES Statement, j (continued) !

TSTF-61 .n6nmenH.e%e. P4e Tedngrop

=; --

l

/

LCO Containment OPERABILIT is maintained by limiting leakage to s I.0 L , except prio o the firsts tartup after performing

_7 a required G0 CFR 50. Anoendix J.Tleakage test. At this o#

the, gplade.,( Etithe combined Type B and C leakage must be < 0.6 L.,1 q e, }{dds -Mand the overall Type A leakage must he < 0.75 L.I _

roust e h Compliance with this LCO will ensure a containment configuration, including equipment hatches, that is I M F-52 Ts7F-SA structurally sound and that will limit leakage to those leakage rates ssumed in the safety analysis. pho

~

Individual le age ates specified for th ontainment air lock (LCO 3. 2) and purge valves wi resilient seals (LCO 3.6.3) are not specifically t of the acceptance criteria of 10 CFR 50, Appendix . Therefore, leakage rates exceeding these individual limits only result the 1 containment being inoperable when the leakage - esults in i exceeding the acceptanca criteria of @ppendix JJ r T6TF-52.

QiveGQ .

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material into containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive M Y material from containment. The requireme s for containment during MODE 6 are addressed in LC0 3.9. , " Containment Penetrations."

3 )

ACTIONS (Cam (Am A; In the event containment is inoperableWontainment must be I 3

a.V restored to OPERABLE status within I hour. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 7 ' " Complet' ion" Time providera seriod of time-to correct"the-F-- -~

problem commensurate with t1e importance of maintaining f N[4 containment during MODES 1, 2, 3, and 4. This time period (continued)

WOG STS B 3.6-8 ., Rev 1, 04/07/95

1 2.2% j CHAPTER 3.6

- 1 INSERT V l NEW ACTION B BASES PAGE B 3.6-8 l Al i i

If the requirements of SR 3.6.1.2 are not met, the structural integrity of the containment is in a degraded state. SR 3.6.1.2 ensures that the structural integrity of the containment will be I maintained in accordance with the provisions of the Containment Tendon Surveillance Program.

l If a limit of the Program is not met, Condition A allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the structural integrity to within limits. The 24-hour Completion Time allows for the correction of minor problems while providing a limit to the amount of time that the structural integrit of containment may be in a degraded condition during at-power conditions.

p 3,WO Q,tH' \

W l

1 l

1 4

Chapter 3.6 Insert Page

I 9t h h [p Containment (Atmos)hericD 5 3.6.

f g,g ,

BASES g ACTIONS (continued) also ensures that the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal.

1 and If containment 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 l 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed i Completion Times are reasonable, based on operating l experience, to reach the required plant conditions from full {

power conditions in an orderly manner and without I challenging plant systems.

Revigsc> 3b TETF 51- AppJ CPtMB ;

SURVEILLANCE SR 3.6.1.1 l REQUIREMENTS ,

g Maintaining the containment OPERABLE requires compliance 1 with the visual _ examinations and leakaae rate test V A l

-f3p:-62 requirements ofyl0 CFR 50, Appendix J (Ref. 1? , as Jnodified) '

4Dy approved exemotions. f Failure to meet air 'ock gand purge valve wit esilient seal eakage limits specified in 1

oes not invalidate the 3.6.2 nd LCO 3.6.

acce abil ty of these overall leakage determinations unless

%n a.n edge. their stribution to overall Type A, B, and C leakage 737F- 52_ ,

or sk n bk, .causes t t to exceed limits. As left leakaae orior o the indu T te. B Rfirst star ' after performing a req ed D CFR 50 g M b it 1 (Appendix A eakage test is requir be < 0.6 L, for -

combined Type B and C leakage,, ard .75 L, for overall

, Type A leakagg At all other times etween required leakage hellownj sn outafE rate tests, the acceptance criteria is based on an overall

( ar ddotwnM Type A leakage limit of s 1.0 L,. At s 1.0 L, the offsite I inctoded.7,qpe. 6 dose. consequences are bounded by the assumptions of the J fe.5hn V safety analysis. SR Freouencies are as required by

}fius, f%J

'Appen91x J, as/ modified p9 approvyd exemptiAns.SR 3.4.2 iwhilh These per1 odic testing requirements verify that ;he '

f -m# .

__ . . ="-containment-leakage rate-does not exceed the-leakage + ate - ~

assumed in the saf_ety analysis.

C.enLnthenf f.a}aqe MTech (continued)

WOG STS B 3.6-9 Rev 1, 04/07/95

Associated Package Changes for RAI- 3.6.1-7 Revised Response 1

1 l

k 4

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. p =- :- = u .:-- - -- ...a,=.-. . --- .--

1

E hhh Containment @tmossheric6 3 3.6.

BASES ACTIONS (continued) also ensures that the probability of an accident (requiring I containment OPERABILITY) occurring during periods when )j containment is inoperable is minimal.

I and -

1 If containment 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 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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 3.6.1.1 REQUIREMEN Maintaining the containment OPERABLE requires compliance with the visual examinations and leakace rate test V N 13p:-92., requirements ofV10 CFR 50, Appendix J (Ref 1?, as Jnodified) gby approved exemotions.f failure to meet air lock and purge valve wit esilient seal eakage limits specifi in 3.6.2 nd LC0 3.6. oes not invalidate the acce abil ty of these overall 1:.akage determinations unless

. their 1tribution to overall Type A, B, and C leakage 73m sz.

1 causes t t to exceed limits. As left leakaae orior the !

R 'irst after performing a req p[y star Mopendix Jh eakage test is requir ed [0 CF_R 50 be < 0.6 L, for g l combined Type B and C leakage., and .75 L, for overall ;

g Type A leakage,. At all other timesletween required leakage l

' rate"fests, th' acceptance e criteria is based on an overall Type A leakage limit of s 1.0 L,. At s 1.0 L, the offsite i dose consequences are bounded by the assumptions of the l safety analysis. SR Freauencies are as required by l TAppen91x 0, as/modifiedfy approvyu exempt 1Ans. }fius, /W SR 3.4.2 Jwhif.h allows hyeauency/extensioM) doef not @ ply)

These perlodic testing requirements verify that 3he '

,-. . m. _ _ . . _ ._ containment. leakagemrate _does,not , exceed Jhe_le.akage_ rate . . .

assumed in the safety analysis.

Cettfontren Lo} ape Q}g hhi (continued)

WOG STS B 3.6-9 ,

Rev 1, 04/07/95

Associated Package Changes for RAI- 3.6.3-8 Revised Response 1

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.6 - Containment Systems CTS 3/4.6.1.7 CONTAINMENT VENTILATION SYSTEM ,

FNP ITS 3.6.3 CONTAINMENT ISOLATION VALVES DOC NQ SHE DISCUSSION requirements must be met. In the STS, information related to the configuration of a system which relate to meeting the operability requirements of the LCO is moved to the Bases. The removal of this type ofinformation from the TS and placement in the bases is consistent with the format and presentation of the STS. Reliance on the information A contained in the STS bases for guidance in defining the OPERABILITY of

%g the associated system is acceptable since changes.to the information in the f (

4 bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.

10 A CTS 3/4.6.1.7 action statement c is revised consistent with the format of the STS. The CTS action statement c provides specific actions for the purge supply and exhaust penetration leakage limit verified by CTS surveillance 4.6.1.7.3.b. CTS surveillance 4.6.1.7.3.b requires verification of purge supply and exhaust penetration leakage to be less than or equal to 0.05 L. .

The disposition of CTS surveillance 4.6.1.7.3.b is discussed in DOC 13-A.

This Farley-specific action will be retained in STS format in ITS LCO 3.6.3 as Condition F. As this change merely retains the current licensing basis in STS format, it is seen as an administrative change.

I1 L The CTS 3/4.6.1.7 surveillance 4.6.1.7.1 which requires the 48 inch containment purge supply and exhaust isolation valves to be deactivated in the closed position is revised consistent with the STS SR 3.6.3.1 An exception to this requirement is added that would allow one valve in a penetration flow path to be open while in STS LCO 3.6.3 Conditiori D.

Condition D is applicable when the containment purge supply or exhaust penetration leakage exceeds the limit. The allowance to open one valve provided in the STS surve.illance exists to facilitate repairs required to reduce the containment purge supply or exhaust penetration leakage to within limit. This STS allowance is acceptable based on the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit to isolate the penetration to reduce leakage to within the limit imposed by the actions of Condition D, the low probability of an event occurring in this

- . time t)at would. challenge.the containment boundary, and.the fact that one_.__,_

valve in the penetration always remains deactivated (sealed) in the closed position. In addition, this allowance will minimize the risk associated with plant transients resulting from a shutdown required by TS if the purge supply or exhaust penetration leakage could not be reduced to within limits.

Chapter 3.6 E2-7-G June,1999

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.6 - Containment Systems CTS 3/4.6.1.7 CONTAINMENT VENTILATION SYSTEM l

FNP ITS 3.6.3 CONTAINMENT ISOLATION VALVES DOC NQ SHE DISCUSSION

\

12 L The CTS 3/4.6.1.7 surveillance requirement frequency for containment purge supply and exhaust valves with resilient seals is revised consistent with the STS. The CTS surveillance for these valves is required to be j performed every 92 days. In the STS, the test interval for these valves is l every 184 days and within 92 days of opening the valve. The 184 day STS j test interval only applies to valves that have not been opened. The extension of the FNP 92 day test interval to the STS 184 days for valves not opened is acceptable based on the fact that the most likely cause of damage to resilient seals results from operation of the valve. If the valves have not been repositioned since the last leakage test, there is little chance of a seal failure occurring between the 184 day STS test intervals. In the STS, a 92

]

day frequency (same as CTS) continues to apply to any valves which are 1 opened.

13 A The CTS 3/4.6.1.7 surveillance requirements 4.6.1.7.2 and 4.6.1.7.3 are revised consistent with the STS. The CTS surveillances contain

' descriptions which specify the applicable leakage rate limit to be applied for the valves being tested. These statements are removed from the CTS A surveillances consistent with the STS. However, the applicable leakage rate (3'3 limits (total Type B and C s 0.6 L. and containment purge penetration s

/'d O.05 L.) stated within each of these surveillances continues to be specified in the Containment Leakage Rate Testing Program,5.5.17. In the STS, this limit is only specified in the Containment Leakage Rate Testing Program in the administrative controls section of the TS. As such, the essential technical requirements of the information removed from the CTS surveillances is retained within the FNP TS. As this change does not remove the required leakage limit specified in the TS and is made to conform with the format and presentation of this information in the STS, this change is considered administrative.

.. 7wy,ml4 ._ .,_ A _ The CTS 3/4.6.1.7, surveillance requirement 4.6.l_.7.3 frequency of" prior to

. ~

startup after each Cold Shutdown, if not pr clormed in the previous 92 days" is deleted from the TS consistent with the STS. This surveillance frequency is essentially redundant to the general rules of TS (STS section 3.0) which require that surveillances be current when entering the Mode of applicability for a TS. Since the containment isolation valves are required E2-8-G June,1999 Chapter 3.6

I Containment isolation Valves [(Atmospheric,

. gubatmospheric, ice Loncenser, and Du 3.6.3 i

\

ACTIONS, O [ CONDITION REQUIRED ACTION COMPLETION TIME I.l.

o D E '(continued)

D 2 --------NOTE---------

Isolation devices in

)

high radiation areas l may be verified by l use of administrative means.

Verify the affected Once per

penetration flow path 31 days for is isolated. isolation devices outside containment 50 .

Prior to )

entering MODE 4 from MODE 5 if not performed

- M within the 9 previous 3

92 days for isolation g devices inside r containment MQ Perform SR 3.6.3. nce per p for theiresilient y92 days seal purge valve closed to compi ith Required Action .1.

fA u equired Action and Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 9pfs associated Completion' Tim not met. MQ CooM,A A, B, C, or D Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

- - - - .i-- -. .r. . ~ < . - i n. ,= .,

f LAS6kT d WOG STS 3.6-11 .

Rev 1, 04/07/95

I5% h A CHAPTER 3.6 i

I o

[ _g;M d INSERT W p g NEW ACTION F FOR ITS LCO 3.6.3 CONDITION REQUIRED ACTION COMPLETION TIME F. One or more penetration F.1 Reduce leakage to within limit. Prior to entering flow paths containing MODE 4 from MODE containment purge 5 if the existing valves, with penetration leakage is determined leakage not within the during quarterly penetration limits.

testing per SR 3.6.3.5.

DE Prior to entering MODE 4 if excess leakage is determined during MODE 5 per SR 3.6.3.5.

I

. = , _ . - . _ _ = , = , _ , . _ _ _ _ _ . , , _ ,

r i-=-~_.--

Chapter 3.6 Insert Page

r FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.6 - Containment Systems l

STS 3.6.3 CONTAINMENT ISOLATION VALVES FNP ITS 3.6.3 CONTAINMENT ISOLATION VALVES JD NUMBER JIJSTIFICATION 1 Not used.

2 The STS 3.6.3 surveillance 3.6.3.2 has been deleted consistent with FNP CTS requirements. FNP CTS allow for continuous operation of the mini-purge system for safety related reasons. The FSAR states that the mini-purge system operates i during power cperation to continuously purge the containment atmosphere. The l STS Bases discussion for SR 3.6.3.2 states that the mini-purge valves are required to be closed. This is in direct conflict with the FNP current licensing basis and has 3

been deleted consistent,with FNP current licensing basis.

3 The STS 3.6.3 surveillance 3.6.3.4 is revised by the addition of Note 2 consistent with the CTS allowance for the blind flange installed on the fuel transfer canal flange. The allowance provided in this Note to the STS surveillance corresponds to the

footnote to 4.6.1.1 in CTS 3/4.6.1 Containment Integrity. The allowance to verify the position of this blind flange only after each draining of the fuel transfer canal is justified since misposition of this flange at other times during normal operation is highly unlikely.

4 The STS 3.6.3 surveillance 3.6.3.5 (ITS 3.6.3.4) has been revised consistent with FNP CTS requirements. FNP CTS 4.6.3.3 requires that the isolation time of each power operated or automatic valve of Table 3.6-1 be determined to be within its limit when tested pursuant to Specification 4.0.5. The IST Program contains the testing requirements for the valves listed in Table 3.6-1. Therefore, STS 3.6.3 surveillance 3.6.3.5 (ITS 3.6.3.4) has been revised consistent with the deletion of Specification 4.0.5 in the STS and the FNP current licensing basis as stated in CTS 4.6.3.3.

5 The STS 3.6.3 Conditions A, B, and E (ITS Condition D) and SR 3.6.3.7 (ITS SR 3.6.3.5) have been revised consistent with FNP CTS requirements. The FNP CTS I

o p leakage limit for containment purge valves with resilient seals is based on a total penetration leakage rate, and is related to the total leakage from all Type B and C f)v p

.p tests as opposed to an individual valve leakage rate as indicated in the STS. The above sections of STS 3.6.3 have been revised to reflect this difference and to mgintain theINP, current.. licensing basisjonthese, penetrations., ,,_ . _ . _ . .

6 A new ITS Condition (Condition F) is added consistent with FNP CTS requirements. CTS 3/4.6.1.7 action statement c is applicable to penetration flow paths containing containment purge valves. A specific leakage limit (s 0.05 L.) is applied to those specific penetration flow paths in addition to maintaining the total ES-1-C June,1999 Chapter 3.6 1

FNP TS Conversion Enclosure 5 - JD from STS

. Chapter 3.6 - Containment Systems i STS 3.6.3 CONTAINMENT ISOLATION VALVES FNP ITS 3.6.3 CONTAINMENT ISOLATION VALVES JD NUMBER JUSTIFICATION leakage from all Type B and C tests within limits (s 0.6 L.). If during testing it is determined that a penetration flow path containing containment purge valves has leakage in excess of the individual penetration flow path leakage limit (s 0.05 L.),

leakage must be reduced to within the limit prior to the next time the unit transitions from MODE 5 to MODE 4. However, provided that the penetration flow path leakage does not cause the total leakage from all Type B and C tests to exceed the limits (s 0.6 L.) no additional action is required (i.e., isolation or unit shutdown).

Therefore, ITS Condition E has been revised to specify that it is only applicable to Conditions A, B, C, and D. This change maintains the current licensing basis for Farley.

k.V Y 55 Qw(4 !

1 1

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~-- . . . . _ . . ,-_.._. . _ . _ _ _ _ . . _,

June,1999 Chapter 3.6 ES-2-C i-

1' M7Containment Isolation Valves /(' Atmospheric], p Gbatmospheric, Ice Condenser, and Dual))

B 3.e.3 BASES O ACTIONS

/

.1. .2.and/.3 (continued)

/ /

automatically isolated, will be in the isolation position

! should an event occur. This Required Action does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that those isolation devices outside containment capable of being mispositioned are.in the correct position. For tho isolation devices inside containment, the time period specified as " prior to entering MODE 4 from MODE 5 if not I performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that is tion 5 device misalignment is an unlikely possibility.

eN,

'[ye

~ '

Co ForthOcontainmentpurgevalvewithres1 -

e that y'q

~

isolated in accordance with Required Ac i 1, R 3.6.3 cp must be performed at least once every / 2 ays This o6- assures that degradation of the resilient seal s detected f and confirms that the leakage rate of the cont inment purge valvFdoes not increase during the time the p tion is M,8" isolated. The normal Frequency for SR 3.6.3 184 days, is f based on an NRC (fninauve. henene issue tl-ZU (Ref. 3)R Since more relianc is placed on a single valve while in this Condition, it is prudent to perform the SR more often.

} Therefore, a Freqt ncy of once per days was chosen and has been shown to be acceptable sed on operating experience.

f.2 h If the Required Actions and associated Completion Times not met, the plant must be brought to a MODE in which the y4 LCO does not apply. To achieve this status, the plant must y, ) be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 of within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are rk$ reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manne and without challenging plant systems.

i= i. - - .., a o C n M M A 8 0 - = -

A )

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(continued) j WOG STS B 3.6-38 - Rev 1, 04/07/95 j

- 24~7cs CHAPTER 3.6 INSERT X BASES FOR NEW ACTION F FOR ITS LCO 3.6.3 Ed !

In the event one or more penetration flow paths containing containment purge valves have penetration leakage which exceeds the individual purge valve penetration leakage limit, purge ,

valve penetration leakage must be reduced to within the limit prior to the next time that the unit l transitions from MODE 5 to MODE 4. Provided that the penetration flow path leakage does not I cause the total leakage from all Type B and C tests to exceed the limits, no additional action is required (i.e., isolation or unit shutdown). If the leakage is sufficient to cause the total leakage from all Type B and C tests to exceed the limits, Condition D also applies, y 3' (hH'[4

$6 4

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Chapter 3.6 Insert Page

9 Associated Package Changes for RAI- 3.6.3-20 Revised Response i

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M5 l Containment Isolation Valves f(Atmospheric 7 (Subatmospheric, Ice Condenser, and Dual !

B 3.6.3 I BASES l

ACTIONS C.1 and C.2 (continued)

With one or more penetration flow paths with one containment isolation valve inoperable, the inoperable valve flow path must be restored to OPERABLE status or the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active l failure. Isolation barriers that meet this criterion are a '

closed and de-activated automatic valve, a closed manual' M3 valve, and a blind flange. A check valve may not b'e used to isolate the affected penetration flow path. equired Action C.1 must be completed within the our Completion Time. The specified time period is reasonable considering the relative stability of the closed system (hence, reliability) to act as a penetration isolation boundary and ,

the relative importance of maintaining containment integrity I during MODES 1, 2, 3, and 4. In the event the affected I penetration flow path is isolated in accordance with . l Required Action C.1, the affected penetration flow path must )

be verified to be isolated on a periodic basis. This

. periodic verification is necessary to assure leak tightness of containment and that containment penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying that each affected penetration flow path is isolated is appropriate E -

because the valves are operated under administrative l l Sh.3o3 ,t controls and the probability of their misalignment is low.

Condition C is modified by a Note indicating that this The dom Condition is only applicable to those penetration flow paths l ghrn mE with only one containment isolation valve and a closed system.4This Note is necessary since this condition is i

Mg 4A w'"ritten to specifically address those penetration flow paths

5. d***>

Required Action C.2 is modified by a Note that applies to valves and blind flanges located in high radiation areas and

~

allows these devices to be verified closed by use of FSARTM dministrative means. Allowing verification by 6.2-31 icbMe,5 dministrative means is considered acceptable, since access L Yhe.follou>ms, o these areas is typically restricted. Therefore, the coggnen -=-

, man @tv ~ 3probabilityeen verified of'tomisalignment of'these' be in the proper position, valves, once they-h is small.

oA heln In L ft W ~

lll pen ton (closcels/sniem) h-HVJ095(ccu)to A>p_est lehclown/RCDT"Hede.gdeser) / (continued) cmd. W2. B 63 vm.B (bunter ressure. c;enemf.,y.

3.6-3 N

'7 Rev 1, 04/07/95 W0 W

hh? O2 Containment Isolation Valves /(' Atmospheric,{ !

Qbatmospheric,IceCondenser,andDual]) j B 3.b.3 '

BASES 4

4 ACTIONS .1./.2.andI.3 I r (continued) automatically isolated, will be in the isolation position j should an event occur. 'This Required Action does not 4 require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that those isolation devices outside containment capable of being mispositioned are in the correct position. For the isolation devices inside containment, the time period specified as " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the -inaccessibility of the isolation devices and other administrative controls that will ensure that iso tion device misalignment is an unlikely possibility. p 5 oN, -

Ca For thOcontainment purge valve ~with res 1 e that _

isolated in accordance with Required Ac i 1, R 3.6.3 7 must be' performed at least once every days This A assures that degradation of the resil n seal s detected f and confirms that the leakagesrate of the cont inment purge valvFdoes not increase duri the time the p 'rition is --

isolated. The normal Freq for SR 3.6.3 184 days, &

f M8"

' sea on an nnu initlar,1v ener,ic Is' sue B-20 '(Ref. 3) .- -

, ince more reliance .is placed on a single valve wh'ile in i

/ this Condition, it is prudent to perform the SR more often.

Therefore, a Fregtency of once per days was chosen and W 8M;*g has been shown to be acceptable sed on operating P experience.

theNRC. i j , .1 an j.2

640 .

& If the Required Actions and associated Completion Times re not met, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 1

3g,$p within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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.

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. CO' bi =-n r:

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WOG STS- B 3.6-38 Rev1,04/07/95

3 +8 u i ContainmentIsolationValves[(AtmosphericT, J Qubatmospheric, Ice Condenser, and Dual)}

B 3.6.3 BASES s (continued) f SR 3.6.3.1 SURVEILLANCE I -

REQUIREMENTS Each inch containment purge valveVis required to be verif sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurious opening of a containment purge valve. Detailed analysis of the purge valves failed to conclusively demonstrate their ability to close during a LOCA in time to limit offsite f i doses. Therefore, these valves are required to be in the l sealed closed position during MODES 1, 2, 3, and 4. A i containment purge valve that is sealed closed must have motive power to the valve operator removed. This can be G g ,. accomplished by de-energizing the source of electric power M' or by removing the air supply to the valve operator. In l

, this application, the term " sealed".has no connotati f I 4

3 leak tig . The Frequency..is a result ~o7 h "S*

~ =fLnitiati Generic Issue B-24 (Ref. 4),'related to

, rew A containment purge valve use during plant operations. Insthe

& gpt event purge valve leakage requires entry into Condition @

the Surveillance permits opening one purge valve in a T h Y. ok penetration flow path to perform repairs.

M. i h F

' h .6.3.2 '

This SR e res that the minipurge valves'are clos as required or, open, open for an allowable re n. If a purge valve is o in violation of this S he valve is considered inoperab . If the inoperab valve is not otherwise known to have essive 1 age when closed, it is "f3N not considered to have leaka o ide of limits. The SR is not required to be met when ipurge valves are open for the reasons stated. valves be opened for pressure control, ALA or air quality siderations for personnel entry, o or Surveillances that uire the valves to be o . The minipurge valves are c ble of closing in e environment following a LOCA. Ther re, these v es are allowed to be open for limited perio f tim The 31 day Frequency is consistent with other tainment isolation valve requirements discussed in -

, . SR 3.6.3.3.

. . . L- p -

(continued)

WOG STS B 3.6-39 Rev.1,04/07/95

2 51 Containment Isolation Valvesj(Atmospheric,\

.. p i

. CSubatmospheric. Ice Condenser. and Dual))

B 3.b.3 i BASES

& W SR 3.6.3 2 -

SVRVEILLAt REQUIREW .i (contined) For containment purge valv with resilient seals,

. . l additional leakage rate t ting beyond the test requirements

' of 10 CFR 50, Appendix J, is required to ensure OPERABILITY.

, 70perating experience has demonstrated that this type of seal

/ ha's the-potential to degrade in a shorter time period than do other seal types. Based on this observation and the c importance of maintainin'g this penetration leak tight (due ,

C-T5 %f,72 i

.to the direct path between containment and the[ Environment) I

.a Frequenefy of 184. days was established :ai_p. art _nf. the M l (esblutioT)of Generic Issue B-20, " Con,tainment Leakage Due .

Thee,entajnment '

to Seal Deterioration" (Ref. 3). ..

purse M.qku6t'

. I pen % 3wn o . Addition is SR must be performed within 92 days after '

opening the valve. e 92 day Frequency was chosen 04f is ba. sed.c n recognizing that cyclin he valve could introduce g p eg,,g ge additional seal degradation beyond that occurring to a g g;ng u valve that has not been opene Thus, decreasing the

% ,g g g .

gg7 g \ interval (from 184 days) is a p dent measure after a valve g fe6 tin 'Fhc has been opened. g g ,q g Q

\n S. Soly nh$

Teoit QSf SR 3.6,3.,

Automatic containment isolation valves close on a f

. containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This g SR ensures that each automatic containment isolation valve will actuate to_its isolation position on a containment isolation signalt This surveillance is not required for v ve hat are locked, sealed, or otherwise secured in the fMp r ui ed position under administrative controls. The i

t g ye.h ,' I month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage 4and the potential for an unplanned transient if the Surveillance were performed with the reactor at ow r.

Operating experience has shown that these com n usually pass this Surveillance when performed at the month g Frequency. Therefore, the Frequency was concluded to be j acceptable from a reliability standpoint.

, M.ca.o #.)

r.:- g g g yg, .-.. .- - . . . . . - - . . . . - . . . . . . . . - . - - . - - - . - . .

ge> e r (continued)

WOG STS B 3.6-42 Rev 1, 04/07/95 L

953 Containment Isolation Valves f(AtmosphericT, y l l

C5ubatmospneric, Ice Condenser, and Dual)) '

B 3.6.3 BASES 1

SURVEILLA REQUIREMENTS SR 3.6.3 11 (continued)

Mpd g fSk hkdWh -

l imum pathway leakage (leakage through the worse of e l two olation valves) unless the penetration is is ted by l use of closed and de-activated automatic y e, closed I manual val or blind flange. In this ca , the leakage !

rate of the is ted bypass leakage pa s assumed to be the actual pathway akage through e isolation device. If 1 both isolation valves the p ration are closed, the '..

actual leakage rate is th ser leakage rate of the two I m

.. f f

,va13 s,_!fhis method if 1 ant ing maximum riathway l'ikage' e !

is only to be used this SR (1. , Append.ix J maximum i

, ! pathway leakage mits are to be qua. JC ccordance /

l. '

with Append ,'iniiFrequericy is requ d by 10 CFR 50, -

a' /Appshdi ~ ,~]asjmodifted by p a' proved exemp'tio and

.'lther uency eptensiop's of yR 3.0.2 not be o e, the'Freq/tes_ ting.is an, Append.ix J/ Type

( t est.

, , . .i ed nje_the ~

This SR imply imposes adifition'al acceptance criteria.

[By pass leakage is considered part of L . [ Reviewer's N

_ Note: Unless specifically exempted].] _

REFERENCES 1. FSAR, Section 15 t 2. FSAR,Section$6. .

Generic Issue B-20, " Containment Leakage Due to Seal 3.

9 3/2,0 Deterioraticn." l

A. , , ' ~ .

4. Generic Issue B-24.

5, %"A"A 9ed'* b 2 4 1 l

T5 fF-30, Rt,v, ) !

.,aqae _ _ _* *

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1 l

WOG STS B 3.6-44 Rev 1, 04/07/95 l

1 i

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Chapter 3.7

~s.,ar. __,,= a+;-~=.. _.

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Associated Package Changes for RAI- 3.7.1.1 Revised Response 1

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. .- _ c . n a , ~ -. . . . . . - - . . - . _ . . - . . . . . . , .- . ...-- ----.--

L

ig g T5 TF ~235-CHAPTER 3.7 R#V' /

INSERT LL TO STS LCO 3.7.1 PAGE 3.7-1 CONDITION REQUIRED ACTION COMPLETION TIME A. One or more steam generators A.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with one MSSVinoperable POWER to s 87 % RTP.

and the Moderator Temperature Coefficient (MTC) zero or negative at all power levels.

B. One or more steam generators B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with two or more MSSVs POWER to less than or inoperable. equal to the Maximum Allowable % RTP specified DE in Table 3.7.1-1 for the number of OPERABLE One or more steam generators MSSVs.

with one MSSV inoperable I and the MTC positive at any AND Power level. _ ______

Onlyrequired in MODE 1 B.2 Reduce the Power Range 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Neutron Flux-High reactor trip setpoint to less than or equal to the Maximum Allowable % RTP specified in Table 3.7.1-1 for the number of OPERABLE MSSVs.

C. Required Actionand C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. M i

gg C.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months i One or more steam generators

= -= " *- - ~ ~ ~ ~ ' ~ ~ ~'

____.__ -] -- with 2 4 MSSVs inoperable /= --

l g 3 7,1.\

wWY RtY Chapter 3.7 Insert Page

1 I

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Chapter 3.9 l l

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Associated Package Changes for RAIs -3 and 4 Revised Response I

I

. . _ , - . . . ~ ._. . =- .---. ,.=.. ., -. .. ..,,.,...,..;.

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.9 - Refueling Operations CTS 3/4.0.4 CONTAINMENT BUILDING PENETRATIONS FNP ITS 3.9.3 CONTAINMENT PENETRATIONS DOC NO SHE DISCUSSION 1 A The LCO requirements a and b for the equipment door to be held in place by a minimum of 4 bolts and a minimum of one door in each air lock is closed are revised consistent with use STS. The phrase "a minimum of" L 53 deleted. This phrase is not required and redundant to the intent of the LCO fgp.) E statement. The elimination of this phrase is acceptable since the LCO requirements always state the minimum requirements that must be met.

2 Not Used.

3 L The term "or equivalent" is added to the list of acceptable isolation devices in the containment building penetrations LCO statement c.l. This change is consistent with the STS. This allows the use of alternate containment sealing methods, such as silicone sealant, to isolate /close a containment penetration which provides direct access from the containment atmosphere to the outside atmosphere. The use of temporary alternate containment sealing methods during refueling operations and Core Alterations is acceptable because fuel handling accidents will not result in an elevated pressure in containment. Therefore, other types ofleakage control may provide reliability equivalent to that of a closed or operable automatic containment isolation valve.

4 A The containment building penetrations LCO statement c.2 is revised consistent with the STS. The term containment purge and exhaust isolation valve is revised to ontainment purge and exhaust isolation system. The system is described in the bases for the containment penetrations TS and includes two operable automatic isolation valves in each penetration. The CTS required isolation capability by an automatic isolation valve. However, this change is consistent with the CTS 3.9.9 requirements for maintaining a containment purge and exhaust isolation system operable in this Mode. The STS does not contain a separate LCO in refueling for the containment purge and exhaust isolation system. The CTS requirements in LCO 3.9.9, containment purge and exhaust isolation system, are effectively retained in

.m....

e n&c5HtsihhrehtyeTietratibus LCO"The16fnbining=of these"--

requirements in a single LCO is consistent with the STS and achieves greater consistency within the TS. Since this change involves the movement of existing TS requirements within the TS it is considered an administrative change.

June,1999 Chapter 3.9 E2-1-D -l l

1 l

FNP TS Conversion f

Enclosure 2 - Discussion of Changes to CTS Chapter 3.9 - Refueling Operations CTS 3/4.9.8.1 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION - ALL WATER LEVELS FNP ITS.- 3.9.4 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION - HIGH WATER LEVEL DOC NO SBE DISCUSSION 7 A The CTS action statement "c" regarding the provisions of specification I

3.0.3 being not applicable is deleted ce nsistent with the STS. This statement is no longer required as the STS LCO 2 .0.3 clearly states that it is only applicable in Modes 1 through 4. This change is administrative made to conform with the STS format and presentation of this information.

8 M The CTS action statement "b"is revised consistent with the STS. An additional restriction is added to the CTS allowance to remove the required RHR loop from service for up to one hour per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The new restriction prohibits operations that would cause a reduction of the RCS boron concentration during the time the required RHR loop is removed from service. The circulation of the reactor coolant provided by.the RHR assists in maintaining a uniform boron concentration in the RCS. During the period that the required RHR loop is removed from service and no forced circulation exists, a uniform boron concentration in the RCS can not be assured. Therefore, the restriction to prohibit operations that would cause a reduction of the RCS boron concentration during the time the required RHR loop is removed from service is appropriate and applicable to FNP.

Since this change represents a new requirement, it is considered more restrictive.

9 L The requirement in CTS 3.9.8.1 Action Statement "a" to "close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months " is revised consistent with the STS (as revised by TSTF-197, Rev. 2). The CTS Action is revised l

y to require actions consistent with the existing ITS LCO 3.9.3 requirements for containment penetrations. LCO 3.9.3 specifies the required status of the

@/F [ containment penetrations and does not require all penetrations be closed.

LCO 3.9.3 requirements may be met by a penetration " capable of being '

_________ _ _ closed bygOPERABLESontainment Purge ta and_ Exhaust Isolation ._ ,___ _

System." An operable containment purge and 5xhaust isolabon system monitors the containment radioactivity and is capable of closing the purge and exhaust penetrations to prevent the release of radioactivity to the environment. As such, LCO 3.9.3 allows the purge and exhaust valves to be open if the associated isolation system is operable. This is acceptable E2-3-I June,1999 Chapter 3.9

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.9 - Refueling Operations CTS 3/4.9.8.1 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION - ALL WATER LEVELS FNP ITS - 3.9.4 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION - HIGH WATER LEVEL DOC N_Q S_HE DISCUSSION based on the fact that the purge and exhaust isolation valves will be closed automatically to mitigate the consequences of an event which releases radioactivity to the containment atmosphere. In addition, LCO 3.3.6, Containment Purge and Exhaust Isolation Instrumentation, provides appropriate remedial Actions for an inoperable purge and exhaus' isolation system. The STS Action, by requiring actions consistent with the existing ITS LCO 3.9.3 requirements for containment penetrations, eliminates any confusion or conflict which may be caused by different requirements being specified in the same Mode for the same equipment. As such, the STS Action maintains the consistency of containment penetration requirements within the TS.

. - , - , - , ~ , - _ . _ - _ _ _ = . , . = , . . . . , . . . . ,. _ _. _ . _ _ ,, _ _ .,,_ ,

Chapter 3.9 E2-4-I April,1999

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.9 - Refueling Operations CTS 3/4.9.8.2 - RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION - LOW WATER LEVEL FNP ITS - 3.9.5 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION - LOW WATER LEVEL DOC NO SHE DISCUSSION the functional requirements of Mode 6 operation.

7 A The CTS 3.9.8.2 actions are revised consistent with the STS. Additional actions (Condition B, Actions B.1 and B.2) are added to CTS 3.9.8.2 for the condition of no RHR loop in operation. The additional actions are not new, but are consistent with the actions of CTS 3.9.8.1 and 3.9.8.2 for no RHR loop in operation. CTS 3.9.8.1 was applicable for all refueling cavity water levels in Mode 6. Since CTS 3.8.9.1 has been revised to apply only when the water level is 2 23 feet above the reactor vessel flange it is necessary to add the requirement and actions for the RHR loop in operation to CTS 3.9.8.2 (water level < 23 feet above vessel flange) to preserve the existing TS requirement and actions for the RHR loop required to be in operation in Mode 6 at all water levels. Since this change is made to conform with the l presentation and format of the STS (two separate water level TS) and has no technical impact, it is considered administrative.

7a L The CTS 3.9.8.2 actions are revised consistent with the STS (as revised by TSTF-197, Rev. 2) by the addition of Actions B.3, B.4, B.S.1, and B.S.2.

l The CTS is revised to require actions consistent with the existing ITS LCO 4

h

[k # 4 3.9.3 requirements for containment penetratioris. LCO 3.9.3 specifies the required status of the containment penetrations and does not require all ;

penetrations be closed. LCO 3.9.3 requirements may be met by a penetration " capable of being closed by an OPERABLE Containment Purge ,

and Exhaust Isolation System." An operable containment purge and !

exhaust isolation system monitors the containment radioactivity and is j capable of closing the purge and exhaust penetrations to prevent the release l of radioactivity to the environment. As such, LCO 3.9.3 allows the purge j and exhaust valves to be open if the associated isolation system is operable.

This is acceptable based on the fact that the purge and exhaust isolation valves will be closed automatically to mitigate the consequences of an event l '"Fvhich~relsises iidi6activitFto theT6iitalifment ~ atmosphere.'In additioti,""""

l LCO 3.3.6, Containment Purge and Exhaust Isolation Instrumentation, provides appropriate remedial Actions for an inoperable purge and exhaust isolation system. The STS Action, by requiring actions consistent with the j existing ITS LCO 3.9.3 requirements for containment penetrations, l eliminates any confusion or conflict which may be caused by different Chapter 3.9 E2-3-J June,1999 !

L l

. . . . . .,. - . .. - . . ~ - .

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.9 - Refueling Operations CTS 3/4.9.8.2. RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION - LOW WATER LEVEL FNP ITS - 3.9.5 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION - LOW WATER LEVEL DOC N_Q SHE DISCUSSION requirements being specified in the same Mode for the same equipment. As such, the STS Action maintains the consistency of containment penetration requirements within the TS. As this change adds an attemative to " closing all containment penetrations ... within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months " as contained in CTS 3.9.8.1, it is considered less restrictive.

8 A The CTS

footnote regarding the status of the normal or emergency power l source for the RHR is deleted consistent with the STS. The footnote specified that one of the power sources for the RHR may be inoperable.

Since in the STS, the definition of operability is revised to state that only one (normal g emergency) power supply is necessary, the allowance provided by the CTS

footnote is no longer required. Since this change is made to conform with the presentation and format of the STS and has no technical impact, it is considered administrative.

The FNP specific CTS

footnote to LCO 3.9.8.2 is revised to clearly state 9 L the required exception and conform with the changes made to the LCO by the STS. The current CTS footnote provides an exception to the LCO requirement for two operable RHR loops for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for RHR surveillance testing. This CTS note is revised to also include an exception to the additional STS LCO requirement for one RHR loop to be in service (decay heat removal mode of operation) for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for RHR testing.

In addition, the FNP specific CTS footnote is moved up to the LCO in the FNP ITS consistent with the STS presentation of LCO exception notes.

This FNP surveillance test exception is retained in the FNP ITS to ensure accurate and complete testing of the RHR system in the ECCS injection mode of operation while the unit is shutdown.

The Farley design minimum calculated flow rate for the Resikal Heat Removal / Low Head Safety Injection (RHR/LHSI) System in use cold leg

- - = - -- - ainjection mode considers the worst case single failure of an entire ECCS " -

train and therefore, requires a flow of 3981 gpm from one RHR pump. This single pump performance requirement is currently specified in CTS surveillance 4.5.2.i and must be performed during shutdown conditions. In order to verify the required flow for a single RHR pump, the pumps must be tested one at a time.

Chapter 3.9 E2-44 April,1999

p 1

. 1 l

Containment Penetrations l 3.9./

3 3.9 REFUELING OPERATIONS 3

l 3;9.f Containment Penetrations 3 ,

l LCO 3.9.f The containment penetrations shall be in the following status: >

a. The equipment hatch closed and held in place by four g bolts; j 3 b. Une door in each air lock closed; and - " '

r gh os c. Each penetration providing direct access lfrom.the Y p,,q containment atmosphere to thetoutside atmosphere either:

1. closed by a manual or automatic isolation valve, blind flange, or equivalent, or 4

l 2. capable of being closed by an OPERABLE Containment

' Purge and Exhaust Isolation System.

APPLICABILITY: During CORE ALTERATIONS, During movement of irradiated fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend CORE Immediately containment ALTERATIONS.

penetrations not in required status. AN1 A.2 Suspend movement of Immediately irradiated fuel assemblies within

! containment.

mrm - -

y. . , - _ = .- -.- - .- . , = = = = - - w----

/

l i

-iiGG 3T3 3.9-6 Rev 1, 04/97/95 FN P umts 14 2.

~

170 RilR and Coolant Circulation - High Water Level 3.9./ j ACTIONS .

CONDITION REQUIRED ACTION 7 COMPLETION TIME st ,

A. (continued) A.4 Cioseallcontainmen2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ggU penetrations /

providing direct A". 2 l[3) .

bp [

ges

@ access from fcontainment atmosphere.to outside

'It4 @ _' '

.. l i

atmosphere. je SURVEILLANCE REQUIREMENTS l SURVEILLANCE FREQUENCY SR 3.9. 1 Verify one RHR loop is in operation and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months circulatina reactor coolant at a flow rate of 2: ) gpm. -

e l 1

l i- - = = , - .= - ,. ~., ...- =-=.===__==...==.=--l:=-=.

W9G4T4 3.9-9 Rev 1, 04/07/95 Fn P un1+s t Q 2-

n.o x

~

CHAPTER 3.9 4 INSERT L TO STS PAGE 3.9-9

' ACTIONS A.4, A.5, A.6.1 and A.6.2 CONDTTION REQUIRED ACTION COMPLETION TIME A. (continued) A.4' Close equipment hatch and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months secure with four bolts.

M A.5 Close one doorin each air 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months lock.

M 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months A.6.1 Close each penetration j providi'ig direct access " rom l I

the containment atmosphere 3 to the outside atmosphere l

with a manual or automatic

%dlh f$g d isolation valve, blind flange, or equivalent.

I DE A.6.2 Verify each penetration is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months capable ofbeing closed by an OPERABLE Containment Purge and Exhaust Isolation System.

l l

.,,.m.-,___-_...mmm. _ m . _1_ _. m

._ f., _. _ _ _ . g.. _

g, ;-_ __

/

Chapter 3.9 Insert Page

l'LV RHR and Coolant Circulation - Low Water Level 3.9.g s

i ACTIONS l

CONDITION COMPLETION TIME REQUIRED ACTION B. (continued) B.2 Initiate action to Immediately restore one RHR loop to operation.

r 1 b.NQ l

B.3 (Closeallcontainmen 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetrations providing direct access from l

containment

, atmosphere to outside mosphere. j l

1. ~

l@ 'p '

g >{

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY s-SR 3.9./.1 Verify one RHR loop is in operation and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months circulating reactor coolant at a flow rate of 2 gpm.

3000 5

SR 3.9.f.2 Verify >reaker alignment and 7 days indic- pc. available to the required

that is not in operation.

l

~~ -

"~

l.____.___...,.,_.,-- .- . , _ _ _

f_ -.m_ - ~ Jm - _ .__ _1_E:TE._____ ___ , -

/

l

= Si5 3.9-11 Rev 1, 04/07/95 Ft4P Onits i M2.

\7%

CHAPTER 3.9 l

INSERT M TO STS PAGE 3.9-11 ACTIONS B.3, B.4, B.5.1 and B.S.2 1

CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.3 Close equipment batch and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months secure with four bolts.

AND B.4 Close one doorin each air 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months lock.

AND l

B.5.1 Close each penetration 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months providing direct access from f

I 4 the containment atmosphere !

l [g 6 j 4 to the outside atmosphere with a manual or automatic ,

isolation valve, blind flange, I or equivalent.

98 B.S.2 Verify each penetrationis 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months capable ofbeing closed by an OPERABLE Containment Purge and Exhaust Isolation System.

I i .,_ = . . - : n . . -, _______.____;_.____ . _ ,_ i. , , _. _

Chapter 3.9 Insert Page

Ib Containment Penetrations B3.9./J B 3.9 REFUELING OPERATIONS 3

83.9./ Containment Penetrations BASES BACKGROUND During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, a release of fission product radioactivity within containment will be restricted from escaping to the environment when the LC0 requirements are met. In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LCO 3.6.1, 4 " Containment." In MODE 6, the potential for containment

/ pressurization as a result of an accident is not likely; therefore, requirements to isolate the containment from the fp '

74#y/

outside' atmosphere requirements are referred to canas " be contless The LCO f stringent.

Mmenyc<osure rather

'^ b b ]

VP$ than " containment OPERABILITY." QnJtatnmen/te. eans that all potent'ali escape paths are closed or capable o RcFJ+3 ,

being closed. Since there is no potential for containment inbyh pressurization, the Appendix J_ leakage criteria and tests are not required. pg gg g The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within the requirements of 10 CFR 100.

Additionally, the containment provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a.means for moving large equipment and components into and out of containment.

During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, the equipment hatch must be held in place by at least four bolts. Good engineering practice dictates that the bolts required by this LCO be -

approximately equally spaced.

The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel

. access.during MODES.1, 2, 3, and 4 unit. operation.in. ._

, = .-accordance with-LCO-3.6 2,7 " Containment ~ Air Locks."- Each- =--"

air lock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of unit shutdown (continued)

WOG STS B 3.9-11 Rev1,04/07/95 u . .. . . . . . .. )

ID Containment Penetrations .

B3.9./

3 BASES ccEvo\h M'fh &

7

I. BACKGROUND

[ [

when(EshraMmfent/cTotste is not required, th'e door interlock (continued) mechanism may be disabled, allowing both doors of an air !

lock to remain open for extended periods when frequent !

containment entry is necessary. During CORE ALTERATIONS or movement of irradiate fuel assemblies within containment, .

G YET5iH W FTF! Rife s' required; therefore, the door I interlock mechanism may remain disabled, but one air lock door must always remain closedu- 4W9 g,g The requirements for f56t'iifFMnVMMtutductosww ensure c.

. . that a release of fission product radioactivity within containment will be restripted from escaping to the environment. The anosurorestrictions are sufficient to pMeh, restrict fission product radioactivity release from

~

psc ontainment due to a fuel han a_acr a nt during refueling. qg n pg, egg % ~,,,q3 A &g .

The Containment Pt ge and Exhaust subsystems. The r ormal subsystem 'includeysa em in ch ude tw purge lofheSt MODES penetration and a W inch exhaust' penetr ion. The second in ou.o h 74 minipurge . system, include an 8 inch purge M CNtD[enN$ /Lg subsystem,iband hn 8 irich exhaustiten '

enevrart6 rations. During ya.g DES 1, 2, 3, and 4, the two valve in each of the normal purge and exhau rations are secured in the closed nes position. ~The twoga n each of the two minipurge ..

. semnavinnsv.a belopene ...............1. but are closed Y utomatically,by

& the Engineered Safety Features'Actu,ation 3,3 instruentidb,n

'JSystem '(ESFAS)e Neither of the subsystems is subject to a ynp<e

{g spec m can on in MODE 5.

g 8 cad bd 1 In MODE 6, large air ex6 hang r necessary to conduct l rs onInshment-L. refueling operations. The normal Kinch purge system is e, n . -r us or this purpose, and all four valyes are closed by the

, u. SF tc rsac with go 3.].z, grytjineerpd saf ty

-f _

Act[ tion fystem/(ESFA7) Instdmentafion." h fourminva/

lvespurge are a' Isosysfem remaird

_closef! by tKe ESFAS. oper/tional 1/ MODE /6, .a'nd

@ n sed in H0DE.6.@fgur/8 /ng!)-

pc ' __ The minipurae system is notWaWes,ar/ sep(Iret'ine tpe 940s "

""P 4

g3dg The other containment penetrations that provide direct access from containment atmosphere to outside atmos here n- a

' f h3M Q

lftl26/nin/ U 6 VQ.].#3

/fou.)CVer,doj0 d

( Neon nfd}

yq,,,-

WOG STS B 3.9-12 Rev 1, 04/07/95

l@

Containment Penetrations B3.9./

BASES 1 GI 6 BACKGROUND mu'st be isol ted on a ast one side. Isolation may oeM

_ (continued) achieved by QPEftA$LF automatic isolation valve, y a q*gg% -manual isolation valve, blind flanae. or eauivaliant c

_)_ Equivalent isolation methodsgEuht t/e apprdvid/ aMTmay

+he Provi5'on5 inciuoe use or a matertai tnat can provide a t -

of to c5R 50.59 atmospheric pressure, ventilation barrier forhem orary other E containment enetrations duringguel n /movemenss(Ref,1 66 $ vel Oriedi,oHicFMTovemofeFirradief memW. ce ~ n?.g.t -

APPLICABLE During CORE ALTERATIONS or movement of irradiat h*

SAFETY ANALYSES assemblies within containment, the most s radiological consequences result from a fuel hand accident. The fuel handling accident is a postulat vent that involves damage i to irradiated fuel (Ref._2). uel handling accident @ 3 g,45 I analyzed Gn Reference 3fincluder dropping a single _

ifradiated fuel assemblyfanp handlJng Jool or/a he,4vy Qbjeg foMo oyher ivradiateti fuel /assemb71esh Ine requirements of LCO 3.9.T, " Refueling Cay 1'ty Water Le' vel," and the minimum decay time of 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months prior to CORE ALTERATIONS ensure that the release of fission product radioactivity, subsequent to a fuel handling accident, results in doses <

that are well within the guideline values specified in 10 CFR 100. Standard Review Plan, Section 15.7.4, Rev. 1 ,

(Ref. 3), defines "well within" 10 CFR 100 to be 25% or less '

of the 10 CFR 100 values. The acceptance limits 'for offsite radiation exposure will be 25% of 10 CFR 100 values. r e F6ATA Og TNRf f staff apppbved licenfing% y1/ asis (e.g., a /peciffled

_ractic6of10CFR/00Timit .

d' "

Containment penetrations satisfy Criterion 3 of the NRC Policy Statement.

LC0 -

This LCO limits the consequences of a fuel handling accident in containment by limiting the potential escape paths for ~

4 fission product radioactivity released within containment. i The LCO requires any penetration providing direct access.

63J )I

'kj/ & from the containment atmosphere to the outside atmosphere to be closed except for the OPERABLE containment purge and M- exhaust penetrations. For the OPERABLE-containment purge ~~~'

fm =_

_w,=and exhaust" penetrations,'this- LC0 " ensures;that-these j penetrations are isolable by the Containment Purge and Ex aust Isolation System. The OPERABILITY requirements for his LC0 ensure that the automatic purge and exhaust valve

, _j -

c ,

3.3.4,$demen+Ary e ou&Wst rsold~en rnstrumenU.cn

__- %- - (t d t, M ,' -

WOG STS B 3.9-13 Rev1,04/07/95

. 19 Containment Penetrations B 3.9.$'

3 BASES LCO closure times specified in the FSAR can be achieved and, (continued) therefore, meet the assumptions used in the safety analysis to ensure that releases through the valves are terminated, such that radiological doses are within the acceptance limit.

APPLICABILITY The containment penetration requirements are applicable during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment because this is when there is a potential for a fuel handling accident. In MODES 1, 2, 3, and 4, containment penetration requirements are addressed by LCO 3.6.1. In MODES 5 and 6, when CORE ALTERATIONS or movement of irradiated fuel assemblies within containment are not being conducted, the potential for a fuel handling accident does not exist. Therefore, under these conditions no requirements are placed on containment penetration status.

ACTIONS A.1 and A.2 '

4 64 t j If the containment equipment hatch, air locks, or any containment penetration tha.t provides direct access from the

[$ 33 ) containment atmosphere.to the putside atmosphere'is n'ot in kM9JbI the required status, including the' Containment Purge and Exhaust Isolation System not capable of automatic actuation 1 when the purge and exhaust valves are open, the unit must be placed in a condition wh6re' the isolation function is not .

needed. This is accomplished by immediately suspending CORE ALTERATIONS and movement of irradiated fuel assemblies within containment. Performance of these actions shall not preclude completion of movement of a component to a safe position. _

3 SURVEILLANCE SR 3 . 9 .A'.1 REQUIREMENTS This Surveillance demonstrates that each of the containment- r --

m.<-_

_.... -"--= penetrations = required'to be in its, closed position is in '"~~~~

that position. The Surveillance on the open purge and exhaust valves will demonstrate that the valves are not blocked from closing. Also the Surveillance will (continued)

WOG STS B 3.9-14 Rev1,04/07/95

1%

RHR and Coolant Circulation - High Water Level B3.9./

'l BASES ACTIONS A.3 (continued) water level 2: 23 ft above the top of the reactor vessel

/5.j J flange, corrective actions shall be initiated immediately.

A.4

[ -tF-lT), Rw,1 bf RHR loop requirements are not met, all containment 3 3%EM F penetrations providing direct access from the containment atmosphere to the outside atmosphere must be closed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . With the RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Closing containment penetrations that are open to the outside atmosphere ensures dose limits are not exceeded.

The Com)letion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable, based on the pro) ability of the coolant boiling in that time.

SURVEILLANCE SR 3.9. 1 REQUIREMENTS This Surveillance demonstrates that the RHR loop is in operation and circulating reactor coolant. The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability and to prevent thermal and boron stratification in the core. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, considering the flow, temperature, pump control, and alarm indications available to the operator in the control room for monitoring the RHR System.

REFERENCES 1. FSAR, Section .5.7

=-n,._n-=.--==.==-- ----.= 2 -

/

WOG STS B 3.9-20 Rev1,04/07/95

I5')

CHAPTER 3.9 INSERT F TO ITS BASES PAGES B 3.9-20 AND B 3.9-23 BASES FOR RHR HIGH AND LOW WATER LEVEL ACTIONS (TSTF-197, Rev. 2)

If no RHR is in operation, the following actions must be taken:

a) the equipment hatch must be closed and secured with four bolts; b) one door in each air lock must be closed; and p'$ c) each penetration providing direct access from the containment atmosphere to the outside atmosphere must be either . closed by a manual or automatic isolation valve, blind flange, or b equivalent, or verified to be capable of being closed by an OPERABLE Containment Purge p and Exhaust Isolation System.

With RHR loop requirements not met, tE potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Performing the actions described above ensures that all containment penetrations are either closed or can be closed so that the do'se limits are not exceeded.

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

l l

. = =. ? = = - - - - - - --

- ~ . , -

.= , . . . . , . . ._..=.,_.__ .,=.

/

Chapter 3.9 Insert Page

IM RHR and Coolant Circulation - Low Water Level

'83.9.g 5

BASES

_g- _ _

ACTIONS 3.J.

i

+he. re{uirecWren ccreenMon pS, '

\1n the M4 p-(continued)

If no loop is in operation, there will be no forced circul tion to provide mixing to establish uniform bor

_ conce trations. Reduced boron concentrations ca ot occur Therebre,arh yhan"Inat tt addition of water with a lower boron concen ration J./

containea in tne KC5;. because all of Ine unboratep

%.t emd.res>L+ ,

~

er sources ar'e isolatedJ in +he 6dd.ihon oP u.a.ker to tht M ..

pcs Wth a bomn - ' '

cadra. Mon b5 If no RHR loo

+ba.n the recu' ired, immediately, and continued,p istoinrestore operation, one RHRactions loop to shall 'be initia 1

I boren c.oxerrs' operation. Since the unit is in Conditions A and B l h '6%% m h concurrently, the RHR ne perating restoration of be loop should two OPERABLE accomplished RHR loops and expeditiously.

W d be

_d e d.,l M ff h d Yf no RHR loop is in operation, all containment penetrations]

providing direct access from the containment atmosphere to the outside atmosphere must be closed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . With

.IAJSE# x F the RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Closing containment penetrations T57F-193 that are open to the outside atmosphere ensures that dose ft9. 2, limits are not exceeded.

A The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable, based on the 3 4 tiow probability of the coolant boilina in that time.

s SURVEILLANCE' SR 3.9.g.1 REQUIREMENTS .

This Surveillance demonstrates that one RHR loop is in operation and circulating reactor coolant. The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability and to prevent thermal and boron stratification in the core. In addition, during- "

_ _ .= . .- .-

operation of the-RHR-loop wjth the water level in'the vicinity of the reactor vessel nozzles, the RHR pump suction requirements must be met. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, considering the flow, temperature, pump control, (continued)

WOG STS B 3.9-23 Rev 1, 04/07/95

%2 CHAPTER 3.9 INSERT F TO ITS BASES PAGES B 3.9-20 AND B 3.9-23 BASES FOR RHR HIGH AND LOW WATER LEVEL ACTIONS (TSTF-197, Rev. 2)

If no RHR is in operation, the following actions must be taken:

A a) the equipment hatch must be closed and secured with four bolts; b) one door in each air lock must be closed; and .

. c) each penetration providing direct access from the containment atmosphere to the outside ,

- #g atmosphere must be either closed by a manual or automatic isolation valve, blind flange, or equivalent, or verified to be capable of being closed by an OPERABLE Containment Purge 1

$[\ and ExhaustIsolation System.

With RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Performing the actions described above ensures that all containment penetrations are either closed or can be closed so that the dose limits are not exceeded.

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

,c-.-..,... . . - .-

-.,a_.-._..'. ~

~ - . .

Chapter 3.9 Insert Page

Chapter 4.0 i

l l

- ~ s s'*r -ny._~_ _,

' * " ' " ~-

~ . 7P- 7__. y

]

Associated Package Changes for RAI- 4.0-1 1

1 l

l p.....s .. -- . - - -

~

O Design Features 4.0 4.0 DESIGN FEATURES 4.3

.ruel Storage (continued)

Eb "

'([ A nominal 9.15 inch A

center to center d ance o between fue semb) ;the igh density) fuel storage racksf;[4es placed j o in

' (d. A minal 10.95 inch enter t center istance b ween el a emblie placed n [ low ensity'f el b ,

orage acks ,)

j. New or partially spent fuel assemblies with #aMnLM dischargybur ' V e " acceptable range" of Figure g3.7. myabe allowed unrestricte g{ &c 4 4 torage geitherffuel oragerack(sgand d' New or partially spent fuel assemblies with a i d

[

discnargyburn Vp the " unacceptable range" of l g,o'( Fiqure q3.7 17 will be stored in compliance with 7 the NHL approvedf specific document Containing the date, or specific >

g W6E analytical onfiguration metnods, title,f or figure].]

4.3.1.2 The new fuelhorage racks are designed and shall be-maintained with:

INSEPJF a. Fuel assemblies having a maximum U-235 enrichment of [4.5] weight percent; FNP

$fYG ,flG y

k.,, s 0.95 if fully flooded with unborated watery,

@hich includes an allowance for uncertainties asf Wescribed in (Section 9.1 of the FSARJ; g, k.,, s 0.98 if moderated by aqueous foa w ich includes an allowance ror uncertainues as >

Ldescribedin[Section9.1oftheFSARY;and t o-A nomina 10.95 inch center to center distance e between fue semblies placed in the storage y racks.

_ . _ . _ . _4.3.2 Drain,aoe _ .

=g a ;,

The spent fuel storage pool is designed and shall be maint i d o prevent inadvertent draining of the pool below elevation 2 f .

(continued) 1 l

WOG STS 4.0-2 Rev 1, 04/07/95 l

l

1 l

1 1 1 l

l 1

l l

l Associated Package Changes for RAI- 4.0-2 l

l i

/

.---r.-- . . . : :. . . : . . . . . -. -- . .

I i

l l

L.

1

. L FNP TS Conversion Enclosure 5 - JD from STS Chapter 4.0 - Design Features STS 4.0 DESIGN FEATURES FNP ITS 4.0 DESIGN FEATURES JD NUMBER JUSTIFICATION 1

STS 4.1 is revised to include the required plant specific text description of the site location. The proposed FNP site location description is consistent with the FSAR section 2.1.1 text description of the FNP site location.

2 STS paragraph 4.2.1, Fuel Assemblies, is revised consisteac with the corresponding CTS paragraph 5.3.1. The proposed changes are minor and provide consistency with the current FNP licensing basis as specified in the CTS.

3 STS paragraph 4.2.2, Control Rod Assemblies, is revised consistent with the corresponding CTS paragraph 5.3.2. The proposed changes are minor and provide consistency with the current FNP licensing basis as specified in the CTS.

4 STS 4.3.1.1.a, which specifies the maximum U-235 enrichment for fuel stored in the spent fuel storage racks is revised consistent with the corresponding CTS requirement 5.6.1.1.d. The proposed changes are minor and provide consistency with the current FNP licensing basis as specified in the CTS.

5 STS 4.3.1.1.b, which states the limit for Err when the spent fuel storage racks are !

fully flooded with unborated water is revised consistent with the corresponding CTS requirement 5.6.1.1.a. In addition, Insert B (new FNP ITS 4.3.1.1.c) adds an '

w the spent fuel aorage racks are fully flooded with FNP-specific limit for Err hen water borated to 400 ppm consistent with CTS requirement 5.6.1.1.b. Together, these limits maintain the current FNP licensing basis as specified in the CTS and described in the FSAR.

6 STS sections 4.3.1.1.c, d, e. and f which address the spent fuel storage are revised consistent with the corresponding CTS requirements in CTS 5.6.1.1. These STS ,

requirements concern different types of storage racks (high and low density) and specific storage locations for fuel assemblies depending on the discharge burnup.

FNP only has one type of spent fuel storage rack and does not need to refer to high and low density racks. Therefore, STS item d is deleted and e is revised accordingly. In addition, the applicable FNP analysis for spent fuel storage _(FSAR _ __ _

~4.3) and CTS 5.6.1.lfand f requirements are hicorporated into sis 4Schl:e and f.-=

y. The proposed changes provide consistency with the current FNP licensing basis 0 . and analysis as specified in the CTS and the FSAR.

k l7 STS 4.3.1.1 is revised by the addition ofInsed E which adds a new FNP-specific ITS statement 4.3.1.1.g consistent with CTS requirements in CTS 5.6.1.1.g. This Chapter 4.0 E5-1-A June,1999

r i

' FNP TS Conversion Enclosure 5 - JD from STS :

Chapter 4.0 - Design Features I l

STS 4.0 DESIGN FEATURES FNP ITS 4.0 DESIGN FEATURES JD NUMBER JUSTIFICATION l addition to the STS is necessary to address the Unit I damaged fuel storage location requirements. The proposed change provides consistency with the current FNP licensing basis as specified in the CTS.

8 STS 4.3.1.2.a, which specifies the maximum U-235 enrichment for fuel stored in the new fuel storage racks is revised consistent with the corresponding CTS requirement 5.6.1.2.c. CTS requirement 5.6.1.1.c specifies the maximum enrichment of each type of fuel used at FNP and also provides a limit for the fuel assembly K.. As such the additional information proposed to be added to the STS maintains consistency with the different fuel types used at FNP and with the current l FNP licensing basis as specified in the CTS.

9 STS 4.3.1.2.b and c, which contain requirements for the Kerr limit of the stored new fuel (when flooded with unborated water or moderated by aqueous foam) are revised consistent with the corresponding CTS requirements. STS 4.3.1.2.b and c contain references to' the uncertainty allowances used in the applicable criticality '

analyses for new fuel storage. The corresponding CTS requirement does not contain such a reference. In addition, the applicable new fuel storage criticality analysis described in FSAR 4.3 does not discuss the uncertainties and biases used in the analysis as is done for the spent fuel storage analysis. Thcefore, consistent with the content of the CTS and applicable FSAR section, the references to uncertainties described in the FSAR is deleted from the new fuel storage requirements in the STS. This change maintains consistency with the FNP current licensing basis as specified in the CTS and described in the FSAR. ,

10 STS Chapter 4.0 is revised by the addition of FNP specific figures related to the storage of burned, fresh, and damaged fuel assemblies. This change maintains consistency with the FNP current licensing basis as specified in the CTS

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Chapter 4.0 ES-2-A March,1998

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Chapter 5.0 l l

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Associated Package Changes for NRC Comment 1 1 1

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Programs and Manuals

/45 5.5 5.5 Programs and Manuals t

5.5.4 Radioactive Effluent Controls Proaram (continued)

1. Limitations on the annual and quarterly doses to a member of I the public from iodine-131, iodine-133, tritium, and all I radionuclides in particulate form with half lives > 8 days l in gaseous effluents released from each unit to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; and

.j. Limitations on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to _

40 CFR 190.

nie s,2.-2a.

5.5.5 Comoonent Cyclic or Transient limit

-]

ThisprogramprovidescontrolstotracktheF.SAR,ISection[ ]} ~

T cyclic and transient occurrences to ensure that components are maintained within the design limits.

5.5.6 Pre-Stressed Concrete Containment Tendon Surveillance Proarant This program provides controls for monitoring any tendon degradatior, in pre-stressed concrete containmente, including effectiveness of its corrosion protection medium, to ensure containment structural integrity. The program shall include

-basaline measurements prior to initia perations. The Tendon Surveillance Program, inspection freq cies, and acceptance criteria shall be n accordance with Regulatory Guide 1.35, Revi ion .

1 The ovisions of SR 3.0.2 and SR 3.0.3 are applicable to the Tendon Surveillance Program inspection frequencies. _

5.5.7 Reactor Coolant Pumo Flywheel Insoection Proaram This program shall provide for the inspection of each reactor coo' ant pump flywheeltger the recommendations or Regulatory.

\ Q tion c.4.b of ReHulatory Guide 1.14, Re'vis on 1, August 1975.

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1I (continued)

WOG STS 5.0-10 ,

Rev1,04/07/95

/YSn CHAPTER 5.0 l l

l INSERT AA j TO STS PAGE 5.0-10 i REACTOR COOLANT PUMP FLYWHEEL INSPECTION PROGRA M l

at least once per 10 years by conducting either:

a. An in-place ultrasonic examination over the volume from the inner bore of the flywheel to the circle ofone-half the outer radius: or

b. A surface examination (magnetic particle and/or liquid penetrant) of exposed surfaces of the disassembled flywheel.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Reactor Coolant Pump FlywheelInspection Program.

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Chapter 5.0 Insert Page L

. FNP TS Conversion Enclosure 5 - JD from STS Chapter 5.0 - Administrative Controls STS 5.0 ADMINISTRATIVE CONTROLS FNP ITS 5.0 ADMINISTRATIVE CONTROLS JD NUMBER JUSTIFICATION with the FNP current licensing basis as specified in the CTS.

I1 The STS 5.5.7 Reactor Coolant Pump Flywheel Inspection Program is revised consistent with the latest approved guidance for performing this inspection. This STS program corresponds to CTS surveillance 4.4.11.2. This change to CTS 4.4.11.2 is documented in section 3.4. CTS 4.4.11.2 has been revised to incorporate the latest approved inspection guidance as follows:

CTS surveillance 4.4.11.2 requires each RCP flywheel to be inspected in accordance with Regulatory Position C.4.b of Regulatory Guide 1.14. This CTS surveillance is revised consistent with the latest NRC appoved guidance for Westinghouse Plant RCP flywheelinspections. WCAP-14535A," Topical Report on RCP Flywheel Inspection Elimination", November,1996 and the associated NRC SER dated September 12,1996 (included in the "A" version of the WCAP) allow the RCP flywheel inspection interval to be once per 10 years in lieu of the RG 1.14 requirements for plants with flywheels made from the SA 533 B material.

WCAP-14535 concludes that continued inspections of RCP flywheels are not necessary and overall plant safety would be increased by eliminating these l inspections due to a reduction in man rem dose and the potential for flywheel I damage during disassembly and reassembly for inspection. The NRC SER for WCAP-14535 however, approves a 10 year inspection interval for all plants with SA 533 B flywheel material. The FNP RCPs have flywheels made from this

\ material and therefore qualify for the generically approved extended interval. Thi:, extended inspection interval continues to conservatively assure the integrity of the RCP flywheels while providing an increase in plant safety by reducing the number ofinspections required which will reduce man rem exposure and the potential for damaging the flywheels during disassembly and reassembly.

The acceptable options for examinations included in WCAP-14535A are specifically delineated in the description of the Reactor Coolant Pump Flywheel Inspection Program in the Farley ITS. This description is consistent with that approved by the Staff for Vogtle in the TS amendment issued by letter dated July 21,1998. This change is acceptable based on the findings of WCAP-14535A and the specific approval of the NRC in the associated SER.

0 -

11a STS 5.5.8, Inservice Testing Program,is revised consistent with the associated FNPa program requirements by the deletion of the words," including applicable supports".

At FNP, the supports for Class 1,2, and 3 components are not included in the Inservice Testing (IST) program. The supports are contained in the Inservice Inspection (ISI) Program. In the STS, the ASME ISI requirements are removed from TS. The requirements in the CTS for ASME ISI duplicate existing regulations Chapter 5.0 E5-4-A June,1999 L

1 1

I Associated Package Changes for NRC Comment ? i I

(Based on Changes Related to RAI 3.6.3-8) i 1

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 5.0 - Administrative Controls CTS 6.0 ADMINISTRATIVE CONTROLS FNP ITS 5.0 ADMINISTRATIVE CONTROLS DOC liq SHE DISCUSSION technical specification changes due to organizational orjob title changes.

As the proposed change still requires supervisory level health physics personnel to specify the frequencies of the required radiation surveillances, the affect of this change on the actual frequencies specified per 6.12.1.c for radiation surveillances is minimal. Considering the small impact of this change, the additional administrative flexibility provided, and the reduction i in the potential for miscellaneous technical specification changes, this change is acceptable.

78 A The leakage rate acceptance criterion for each containment purge penetration flow path from CTS 4.6.1.7.3.b is incorporated into the Containment Leakage Rate Testing Program. As this change merely moves CTS information to another location within the TS consistent with the format of similar information in the STS, this is seen as an administrative change.

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l i . , _ _ _ , .

Chapter 5.0 E2 38-A June,1999

. { cuyo . r r ee pc f-a4 W vwsr s D~ ' M )

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, bMT 5.5. I3 FN P SPEUF'C C.o n 'rWNMENT"L94VAGG RATE NEsvmG PeoG M \

ADMINISTRATIVE. CONTROLS )

6. [5 MAJIReMAMEStobDioAcdytWAs TREAT NT SYS EMS (Li 'id, Gas ous, S lid) his ocif ation leted. Refer o the faite ose ca ulation anual and the oces Contro Progr .

ONTAINMENT t.EAKAGE RATE TESTING PROGRAM si.5,n .

A pro shall be established to implement the leakage rate testing of containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regr.latory guide 1.163, " Performance-Based containment Leak-Test Program," dated september 1995.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 43 psig. l The maximum allowable containment leakage rate, La, at Pa, is 0.15% of y containment air weight per day. -

m Leakage rate acceptance criteria are: SEMic ggoF

a. Containment overall leakage rate acceptance criterion is s 1.0 La- 86 During plant startup fo1*owing testing in accordance with this program, the leakage rate acceptance criteria are S 0.60 La for the combined Type B and C tests, and s 0.75 La for Type A tests;

b. Air lock testing acceptance criteria are:

~

1) overall air lock leakage rate is s 0.05 La when tested at 2 Pa.

2) For each door, leakage rate is 5 0.01 La when pressurized to 2 10 peig.

[

he provisions of fpecification 4.0J do not apply to the test frequencies specified in the Containme a e Rate Testing Program.

l CIIL S.D.

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The provisions of Guecification e.o i are applicable to the Containment Leakage Rate Testing Program.

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\6h ITiGENT SYSTrMS CONTAINMrMT ggyg gg 8 T W CE RrOUTRrxrNTS fCentinu 4.6.1.7.3 Each conta supply and exhaus tration containing isolation valves resilient material seals shall be demo ed CPERAELE prior to up after each COLD SHUTD00GI, if not perforand in the p a 92 d , y verifying thats a) when the measured leakage rate is added to the teamage racee for~ gg, q all other valves and penetrations subject to Type a and C tests, gi the combined leakage rate la less than or equal to 0.60 L a, and b) The leakage rate for each contai-at purge supply and exhaust f penetration is less than or equal to 0.05 La*

W

\

tion, the leakage rate for the contalmeest purge isolation valves !

be compar he previously measared leakage rate (for the cont t purge 1 isolation valves) eet cwcess valve degradation. ring evaluation shall be perf determine what . .ive action, if any, la !

necessary.

4.6.1.7.4 The resil terial valve seals of -

h and the 8-inch ,

containment upply and ezhaust isolation valves shall laced at least per 5 years.

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FNP TS Conversion Enclosure 5 - JD from STS Chapter 5.0 - Administrative Controls STS 5.0 ADMINISTRATIVE CONTROLS FNP ITS 5.0 ADMINISTRATIVE CONTROLS JD NUMBER JUSTIFICATION 16a ASTM D4176, Method B defines " clear and bright" as "a condition in which the fuel contains no visible water drops or particulates, and is free of haze or cloudiness". However, the requirement for " proper color" is ambiguous and not referenced in the FNP procedures or in the ASTM. Therefore, consistent with the FNP current procedures and technical specification requirements, " proper color" is deleted. This change maintains the FNP current licensing basis regarding fuel oil verification.

17 An FNP specific program is added to the STS 5.5 Programs section of Administrative Controls. The FNP specific program 5.5.16, Main Steamline Inspection Program, corresponds to CTS surveillance requirement 4.4.11.3 in the RCS Structural Integrity LCO (section 3.4). The RCS Structural Integrity LCO is eliminated consistent with the content of the STS and the surveillances are retained as programs. The STS includes the RCP Flywheel Inspection Program which corresponds to one of the FNP surveillances associated with the RCS Structural Integrity LCO. However, the FNP specific Main Steamline Inspection requirements associated with the RCS Structural Integrity LCO were not included in the STS. As such, and consistent with the treatment of the more generic RCP Flywheel Inspection requirements, the FNP specific Main Steamline Inspection requirements are also retained as an administrative controls program. The CTS surveillance i requirements are retained without introducing a technical change and therefore, l maintain the current FNP licensing basis for main steamline inspection as specified 1 in the CTS.

18 An FNP specific program is added to the STS 5.5 Programs section of Administrative Controls. The FNP specific program 5.5.17, Containment Leakage j Rate Testing Program, corresponds to CTS 6.16, Containment Leakage Rate j Testing Program. This CTS program is incorporated without technical change into the FNP ITS. The CTS program is renumbered and moved into the programs section of the FNP ITS consistent with the STS format. This CTS program is the result of a previous license amendment which incorporated the TS changes F associated with adopting 10 CFR 50, Appendix J, Option B. The incorporation of f( __ this CTS program into the FNP ITS maintains consistency with the current FNP licensing basis as specified iry the CTS. . _ _ . , . . __ _.

i...-...-...-....--

18a An FNP-specific leakage rate acceptance criterion is added to ITS 5.5.17, Containment Leakage Rate Testing Program. The leakage rate acceptance criterion for each containment purge penetration flow path from CTS 4.6.1.7.3.b is incorporated into the Containment Leakage Rate Testing Program. This CTS acceptance criterion is incorporated without technical change into the FNP ITS.

Chapter 5.0 ES-7-A June,1999

i FNP TS Conversion Enclosure 5 - JD from STS Chapter 5.0 - Administrative Controls q 1

STS 5.0 ADMINISTRATIVE CONTROLS FNPITS 5.0 ADMINISTRATIVE CONTROLS i

JD.

NUMBER JUSTIFICATION The incorporation of this CTS acceptance criterion into the FNP ITS maintains consistency with the current FNP licensing basis as specified in the CTS.

Incorporation of the acceptance criterion in the Containment Leakage Rate Testing Program merely moves CTS information to another location within the TS consistent with the format of similar information in the STS.

'V

[

bg 19 STS 5.6.1, Occupational Radiation Exposure Report, is revised by the deletion of the last bracketed sentence. The deleted sentence provides guidance for the report submittal for new plants following initial criticality. As this STS sentence is applicable only to new plants, it is deleted from the FNP ITS. !

l 20 STS 5.6.2, Annual Radiological Environmental Operating Report, is revised consistent with the corresponding CTS requirement 6.9.1.6 and 6.9.1.7. The second paragraph of this STS reporting requirement is deleted. The second paragraph of this STS requirement contains more detail regarding the content of this report. The corresponding CTS requirement lacks this additional detail. The CTS reporting requirement provides sufficient guidance in order to comply with the intent of the report. The additional detail provided by the STS is not required. This change maintains the current FNP licensing basis as specified in the CTS.

20a STS 5.6.3, Radioactive Effluent Release Report, is revised consistent with the ,

corresponding CTS requirement 6.9.1.8 and 6.9.1.9. 'Ihr note related to this STS /

reporting requirement is revised by changing "shall", as revised by TSTF-152, back to "should". The corresponding CTS requirement contains the word should in the .

?

statement of the requirement. This change maintains the current FNP licensing 1

basis as specified in the CTS.

20b STS 5.6.4, Monthly Operating Report, is revised consistent with a related reporting requirement from CTS 3.4.10.3. The CTS 3.4.10.3 action statement"c"is revised consistent with the format of the STS. The CTS action requires a special report be made in the event an RHR relief valve is used to mitigate an RCS pressure transient. In the STS, the special reports section (CTS 6.9.2) does not exist. As such, it is proposed to move this reporting requirement to the Monthly Operating Report (STS 5.6.4). The STS monthly operating report is required every 30 days -.

and connins related information regarding challenges to. press.urizer relief and_

safety valves. Therefore, the CTS reporting requirement for the RHR relief valves will be adequately addressed by inclusion in the monthly operating report where other safety and relief valve reporting requirements reside. This change maintains the current FNP licensing basis as specified in the CTS.

E5-8-A June,1999 Chapter 5.0

ML20209B816

Text

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