Text

Proposed Tech Specs Re Rev B to Conversion to Improved STS
	ML20236Q064
Person / Time
Site:	Cooper
Issue date:	07/13/1998
From:	; NEBRASKA PUBLIC POWER DISTRICT
To:	;
Shared Package
ML20236Q061	List: ML20236Q059; ML20236Q064;
References
	NUDOCS 9807170296
	Download: ML20236Q064 (100)
	v • d • e

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 1 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERE:4CED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVE!LLANCE ALLOWABL E i TUNCil0N CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE I

1. Core Spray System

a. Reactor Vessel Wathr 1,2,3, 4(b) 3.3.5.1.1 Level -Low Low Low B SR 1 -113 inches SR 3.3.5.1.2 (Level 1) 4(a) 5(a)

, SR 3.3.5.1.4 SR 3.3.5.1.5

b. Drywell 1,2,3 4(b) B SR 3.3.5.1.2 5 1.84 psig Pressure -High SR 3.3.5.1.4 SR 3.3.5.1.5

c. Reactor Pressure -Low 1,2,3 4 C SR 3.3.5.1.2 1 291 psig n (Injection Permissive) 3.3.5.1.4 SR SR 3.3.5.1.5 and 1 436 psig ]

/A 4(a) $(a)

, 4 8 SR 3.3.5.1.2 1 291 psig SR SR 3.3.5.1.4 3.3.5.1.5 and 5 436 psig h

d. Core Spray Punp 1,2,3, 1 per pump E SR 3.3.5.1.2 1 1370 gpm Discharge Flow -Low SR 3.3.5.1.4 (Bypass) 4(a) 5(a)

, gg 3,3,5,3,5

e. Core Spray Pump 1,2,3, 1 per puno C 3.3.5.1.2 Start-Time Delay Relay SR 1 9 seconds SR 3.3.5.1.4 and 4(a), $(a) SR 3.3.5.1.5 f. 11 seconds

2. Low Pressure Coolant injection (LPCI) System

a. Reactor Vessel Water 1,2,3, 4 8 3.3.5.1.1 Level - Low Low Low SR 1 113 inches SR 3.3.5.1.2 (Level 1) 4("), 5(a) SR 3.3.5.1.4 SR 3.3.5.1.5 (continued)

(a) When associated subsystem (s) are required to be OPERABLE.

(b) Also required to initiate the associated diesel generator (DG).

Cooper 3.3-37 Amendment No.

9007170296 980713 PDR ADOCK 05000290 p PDR

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 2 of 3)

Primary Containment isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED I OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.1 REQUIREMENTS VALUE

3. High Pressure Coolant injection (HPCI) System Isolation

a. HPCI Steam Line 1,2,3 1 F SR 3.3.6.1.2 5 250% rated Flow -High SR 3.3.6.1.4 steam flow SR 3.3.6.1.6

b. HPCI Steam Line 1,2,3 1 F SR 3.3.6.1.2 3 6 sconds flow-Time Delay Relays SR 3.3.6.1.4 SR 3.3.6.1.6

c. HPCI Steam Supply Line 1,2,3 2 F SR 3.3.6.1.2 5 107 psig Pressure ~ Low SR 3.3.6.1.4 SR 3.3.6.1.6

d. HPCI Steam Line Space 1,2,3 2 per 3.3.6.1.2 T emperature - High F SR 5 195'F location SR 3.3.6.1.4 SR 3.3.6.1.6

4. Reactor Core Isolation Cooling (RCIC) System Isolation

a. RCIC Steam Line 1,2,3 1 3.3.6.1.2 F low - Hi gh F SR 5 288% rated SR 3.3.6.1.4 steam flow SR 3.3.6.1.6

b. RCIC Steam Line 1,2,3 1 3.3.6.1.2 Flow-Time Delay F SR 5 6 seconds SR 3.3.6.1.4 Relays SR 3.3.6.1.6

c. RCIC Steam Supply 1,2,3 2 3.3.6.1.2 5 61 psig Line Pressure -Low F SR SR 3.3.6.1.4 /$

SR 3.3.6.1.6

d. RCIC Steam Line Space 1,2,3 2 per 3.3.6.1.2 Temperature -High F SR 5 195'F location SR 3.3.6.1.4 SR 3.3.6.1.6

5. Reactor Water Cleanup (RWCU) System Isolation

n. RWCU Flow - digh 1,2,3 1 F SR 3.3.6.1.2 5 191% of SR 3.3.6.1.4 Rated SR 3.3.6.1.6

b. RWCU System Space 1,2,3 2 per 3.3.6.1.2 Temperature -High F SR 5 195'F location SR 3.3.6.1.4 SR 3.3.6.1.6

c. SLC System Initiation 1,2 1 H SR 3.3.6.1.6 NA

d. Reactor Vessel Water 1,2,3 4 F SR 3.3.6.1.1 g 3 inches Level -Low SR 3.3.6.1.2 (Level 3) SR 3.3.6.1.4 SR 3.3.6.1.6 (continued)

Cooper 3.3-52 Amendment No.

_ -__---- - ---- -- ~

OA 'b*

fOn oA m ollD+$ M r i

~

[30TES W AULE 3.2.3) a of 0.S.~ ci (IiCQ k cl l $ "$* A N 7/b.d ggg 1.

When any ECCS system is required t6 be operable, there shall oe two operable g# ,, trip systems except as noted. If a requirement of the fourth column is re- l

.I duced by one, the indicated action shall be taken. If the same function is

' 2,8' f< l inoperable in more than one trip system or the fourth column reduced by gp more than one, action B snall be taken.

Ac

,[$e ,,, ohde f.Lt d. 2 J b . Dh t o ao N s'or Y ' S'"

J M n 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If the function is not operapie la 44 tio d take g ,, .

heye a b __.

.. actton B j ,,,) p , ,, , s ,) , , g. ,

, g , ,, ,

, T Id @ 1 occ#iare the system or component inoperaste. ,

E ,{.l>

C.

Immediately take action B until power is verified on the trip systh fg y , ,.d. The high point vent shall be vented weekly upon failure of PS 73A or B.

g,g PS 266. PS 26d, PS 269, PS 270.

l E. Repair as soon as possible. It does not directly effect system

(. ope rations.

2. In only 94tripsystem]

37 , lot considered in a trip system.

3

'4 1:equires one channel .from each physical location in the steam line space.

5. One relay sunses each phase of MCC-S and the Ce relay ir a transfer permisstve relay, i d

L

~ See TTS:

3.3, 5. I

) .

e 2/23/81 Page 4 CE 7

[fQ o,asa ie o .t a 2'- p ly fu o //

A e e of l C

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e ECCS Instrumentation c / a,,y e ,L eo /s,,,,,. , er,,/p n o f /p ,t.y,s..e a e /d. 3.3.5.1 febte 3.3.5.1 1 (pose 1 of 6)

Emergency Core Costing systee tratrumentation APPLICABLE COW!T10Ns MODES REfUltED REFERENCED OR OTNER CNANNELs FRON SPECIFIES PER REeutkED SURVE!LLANCE ALLOW 48LE FUNCTION CONDifl0Ns FUNCTION ACTION A.1 REQUIREMENTS VALUE

,. C -., ,, t cy afg1 or

a. Reector Wessel Weter 1,2,3, 8 sa 3.3.5.1.1 Level-Low Low Leg /4/(b) SR 3.3.5.1 t/113/

inches Level 4(*I,5(83 ) 3.3.5.1 M.2 sa 3.3.5.1.5

,. .-t t Pressure - Nigh

,.2., y, ,

co w m m _ 3.3.5.1.2 5 es ...

SR m,,

e pt 3.3.5.1 5 9 sa 3.3.5.1.5

$1

/ c. teactor W 1,2,3 Pressure -Low (Injection Permissive)

/6/ c Q ionsa m ii'!

3.3.5.1.,

a and 5 35001 pelo is 4<e>, Sce> y . g st -, . M ,si.

3.3.5.1.2 and s A, Ie

$sa 3.3.5.1J 3.3.5.1S mr my g g

( j f.. C.,e 3,r., ,L.,,

Discharse Flow-tow (sypass) 1,2,3, 4('>, 5(a) m fper E

@ ~3.3.5.1 sa u .b, .-

piaggf sa 3.3.5.1 s /

1

_ 'sa 3.3.5.1

-1

e. Manuet initlation 1,2,3, C SA 3.3.5.1.6 WA (1 per 4I *3, stesystes0 A _

r r

2. Low Pressure Coolant Injection (LPCI) system

e. Aesctor Wessel Water 1,2,3, Levet -Low Low Log [4/b 3 st 3.3.5.1.1 sa 3.3.5.1.2 t/-113[

inches Levet 1 4(a), $(a) jst 3.3.5.1 sa 3.3.5.1.5_

h 5 N5 .b (continued)

(e) men assocleted stesystem(s) are required to be OPERA 8tt.

_A_tse required to initiate th

[3] (b) < service we, mv>-,. e associatedurrone E, m.diesel is. . ponerator n en (DC)/ ens 16etetepssociated pLg ess.

BWR/4 ST'S 3.3-42 Rev 1, 04/07/95 b > 2 ]> ! ter C Sn 3, 3.s. ),4 g %<h. ~ . \

F .>

)~~'\ 2.sw C4.Twe ort S '* 19>'}*>t~!'

>v "f-sg 3 3' 3* ;j

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.4

i ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating LC0 .3.5.1 Each ECCS injection / spray subsystem and the Automatic Depressurization System (ADS) function of six safety / relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure 5 150 psig.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection / spray ECCS injection / spray :

subsystem inoperable. subsystem to OPERABLE i status.

b B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months i associated Completion Time of Condition A AND not met.

B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months -

C. HPCI System C.) Verify by I hour I$h inoperable. administrative means RCIC System is OPERABLE.

AND C.2 Restore HPCI System 14 days (kh to OPERABLE status.

l l (continued)

Cooper 3.5-1 Amendment No.

l l

C_ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ . _ _ _ _ . - _ _ . . . _

l l

ECCS - Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. HPCI System inoperable.

D.1 Restore HPCI System to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months b l AND 0_R One low pressure ECCS D.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months injection / spray ECCS injection / spray subsystem is subsystem to OPERABLE inoperable. status.

E. One ADS valve inoperable.

E.1 Restore ADS valve to OPERABLE status.

14 days b l

F. One ADS valve F.1 Restore ADS valve to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. OPERABLE status.

AND OR One low pressure ECCS injection / spray F.2 Restore low pressure ECCS injection / spray 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months b subsystem inoperable. subsystem to OPERABLE status.

i b l G. Required Action and G.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition C, AND

~~

D, E, or F not met.

G.2 Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR dome pressure to s 150 psig.

Two or more ADS valves inoperable.

(continued) l Cooper 3.5-2 Amendment No. !

L___-.-.-_-----.-___

l ECCS - Operating l

3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. Two or more low H.1 Enter LC0 3.0.3. Immediately /E\

~

pressure ECCS injection / spray subsystems inoperable. g 0_R HPCI System and one or i\

more ADS valves E inoperable.

SURVEILLANCE REQUIREMENTS 4

SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection / spray 31 days-subsystem, the piping is filled with water from the pump discharge valve to the injection valve.

(continued) i 1

l l

l i

1 Cooper 3.5-3 Amendment No. ,

l l

l L_ _ __ _ - - _ _ - - - - _ _ _ - _ _ - _ _ - - _ - - - _ _ - - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - - - __ __o

\

ECCS-Operating 3.5.1 i

SURVEILLANCE REQUIREMENTS' (continued) j SURVEILLANCE FREQUENCY SR 3.5.1.2 -------------------NOTE--------------------

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the shutdown cooling l permissive pressure'in MODE 3, if capable of being manually realigned and not l- otherwise inoperable.

L Verify each ECCS injection / spray subsystem 31 days manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

1

.SR 3.5.1.3 Verify ADS pneumatic supply header pressure 31 days is > 88 psig.

SR -3.5.1.4 Verify the RHR-System cross ' tie shutoff 31 days valve is closed.

l l

SR 3.5.1.5 -----------------

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

r Not required to be performed if performed I

within the previous 31 days.

Verify each recirculation pump discharge. Once each valve cycles through one complete cycle of startup prior full travel or is de-energized in the to exceeding l, closed position. 25% RTP l

(continued)

(

. Cooper. 3.5-4 Amendment No.

]

_ _ -__ .___________J

l ECCS - 0perating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY j i

SR 3.5.1.6 Verify the following ECCS pumps develop the In accordance specified flow rate against a system head with the corresponding to the specified reactor Inservice j pressure. Testing SYSTEM HEAD Program N0. CORRESPONDING 0F TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF Core Spray 2 4720 gpm 1 2 113 psig LPCI 2 15,000 gpm 2 2 20 psig SR 3.5.1.7 -------------------NOTE--------------------

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

Verify, with reactor pressure s 1020 and 92 days 1 2 920 psig, the HPCI pump can develop a flow rate 2 4250 gpm against a system head corresponding to reactor pressure.

SR 3.5.1.8 -----

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

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

Verify, with reactor pressure s 165 psig, 18 months the HPCI pump can develop a flow rate 2 4250 gpm against a system head corresponding to reactor pressure.

(continued) l l

Cooper 3.5-5 Amendment No.

l

- _ _ _ _ - _ _ _ _ - - - - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ __ ._. ._. __ ________-________-____-________A

i l

ECCS - 0perating l i

3.5.1 i 1

l l

l SURVEILLANCE REQUIREMENTS (continued) i SURVEILLANCE FREQUENCY q

SR 3.5.1.9 -------------------NOTES-------------------

l 1. For HPCI only, not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate A to perform the test.

2. Vessel injection / spray may be excluded.

Verify each ECCS injection / spray subsystem 18 months actuates on an actual or simulated automatic initiation signal.

SR 3.5.1.10 -------------------NOTE--------------------

Valve actuation may be excluded.

Verify the ADS actuates on an actual or 18 months simulated automatic initiation signal.

SR 3.5.1.11 -------------------NOTE----------------- --

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

Verify each ADS valve opens when manually 18 months ;

actuated. '

l l

Cooper 3.5-6 Amendment No.

ECCS-Operating B 3.5.1 BASES (continued)

APPLICABILITY All ECCS subsystems are required to be OPERABLE during MODES 1, 2, and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent {

fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure l is $ 150 psig, ADS and HPCI are not required to be OPERABLE l

, because the low pressure ECCS subsystems can provide l l

sufficient flow below this pressure. ECCS requirements for l MODES 4 and 5 are specified in LCO 3.5.2, "ECCS-Shutdown." l

\

ACTIONS A.1 If any one low pressure ECCS injection / spray subsystem is inoperable, the inoperable subsystem must be restored to '

OPERABLE status within 7 days. In this condition, the

, remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is !

reduced, because a single failure in one of the re;naining OPERABLE subsystems, concurrent with a LOCA, may result in l the ECCS not being able to perform its intended safety function. The 7 day Completion Time is consistent with the l recommendations provided in a reliability study (Ref. 11) ,

that evaluated the impact on ECCS availability, assuming !

various components and subsystems were taken out of service. !

The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed Completion Times.

B.1 and B.2 If the inoperable low pressure ECCS subsystem cannot be b

restored to OPERABLE status within the associated Completion lime, 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 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 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 nanner and without challenging plant systems.

(continued)

Cooper B 3.5-6 Revision 0

ECCS - Operating B 3.5.1 BASES ACTIONS (continued)

C.1 and C.2 k If the HPCI System is inoperable and the RCIC System is verified to be OPERABLE, the HPCI System must be restored to OPERABLE status within 14 days. In this condition, adequate h core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection / spray subsystems in conjunction with ADS. Also, the RCIC System will automatically provide makeup water at most reactor operating pressures. Verification of RCIC OPERABILITY within I hour is therefore required when HPCI is inoperable. This may be b performed as an administrative check by examining logs or other information, to determine if RCIC is out of service for maintenance or other reasons. It does not mean to perform the Surveillance needed to demonstrate the OPERABILITY of the RCIC System. If the OPERABILITY of the RCIC System cannot be verified, however, Condition G must be B immediately entered. If a single active component fails concurrent with a design basis LOCA, there is a potential, depending on the specific failure, that the minimum required ECCS equipment will not be available. A 14 day Completion Time is consistent with the recommendations provided in a reliability study cited in Reference 11 and has been found to be acceptable through operating experience.

D.1 and D.2 h, if any one low pressure ECCS injection / spray subsystem is inoperable in addition to an inoperable HPCI System, the inoperable low pressure ECCS injection / spray subsystem or the HPCI System must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this condition, adequate core cooling is ensured by the OPERABILITY of the ADS and the remaining low pressure ECCS subsystems. However, the overall ECCS reliability is significantly reduced because a single failure in one of the remaining 0PERABLE subsystems concurrent with a design basis LOCA ray result in the ECCS not being able to perform its intended safety function. ,

Since both a high pressure system (HPCI) and a low pressure i

! subsystem are inoperable, a more restrictive Completion Time l

l ;

l (continued) j Cooper B 3.5-7 Revision 0 L _ - - - . - - - - - - - - --___-----_---------o

ECCS - Operating B 3.5.1

-BASES 1 ACTIONS p.1 and 0.2 (continued) ,

i of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is required to restore either the HPCI System or the low pressure ECCS injection / spray subsystem to OPERABLE status. This Completion Time is consistent with the l recommendations provided in a reliability study cited in L Reference 11 and has been found to be acceptable through operating experience.

L1- b The LC0 requires six ADS valves to be OPERABLE in order to provide the ADS function. Reference 9 contains the results of an analysis that evaluated the effect of one ADS valve being out of service. This analysis shows that, assuming a failure of the HPCI System, operation of.only five ADS valves will provide the. required ~depressurization. However, overall reliability of the ADS is reduced, because a single failure in the OPERABLE ADS valves could result in a reduction in depressurization capability. Therefore, operation is only allowed for a limited time. The 14 day.-

Completion Time is consistent with the recommendations provided 'in a reliability study cited in Reference 11 and has been found to be acceptable through operating experience.

F.1 and F.2 b' If any one low pressure ECCS injection / spray subsystem is inoperable in addition to one ADS valve inoperable, adequate core cooling is ensured by the OPERABILITY of HPCI and the remaining low pressure ECCS injection / spray subsystem.

However, overall ECCS reliability is reduced because a single active component failure concurrent with a design basis LOCA could result in the minimum required ECCS equipment not being available. Since both a high pressure .

system (ADS) and a low pressure subsystem are inoperable, a more restrictive Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is required to restore either the low pressure ECCS subsysten or the ADS valve to OPERABLE status. This Completion Tiue is consistent with the recommendations provided it. a reliability study cited in Reference 11 and has been found L to be acceptable through operating experience.

b

( (continued)

Cooper B 3.5-8 Revision 0

ECCS-Operating B 3.5.1 I BASES L

ACTIONS (continued)

G.1 and G.2 h If any Required Action and associated Completion Time of Condition C, D, E, or F is not met, or if two or more ADS valves are. inoperable, the plant must be brought to a b

condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reactor steam dome pressure reduced to 1 150 psig 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.

H.1 g When multiple ECCS subsystems are inoperable, as stated in Condition H, the plant is in a condition outside of the accident analyses. Therefore, LC0 3.0.3 must be entered g

immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the HPCI System, CS System, and LPCI subsystems full of water ensures that the ECCS will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent a water' hammer following an ECCS initiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points. The ;

31 day Frequency is based on the gradual nature of void buildup in the ECCS piping, the procedural controls governing system operation, and operating experience.

SR 3.5.1.2 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR applies only to valves affecting the direct flow path. This SR excludes valves that, if mispositioned, would not affect system or subsystem l (continued) l Cooper B 3.5-9 Revision 0

l ECCS - Operating l B 3.5.1 BASES l

l ACTIONS G.1 and G.2 (continued) d s 150 psig 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.

H.1 g When multiple ECCS subsystems are inoperable, as stated in Condition H, the plant is in a condition outside of the accident analyses. Therefore, LC0 3.0.3 must be entered h

immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the HPCI System, CS System, and LPCI subsystems full of water ensures that the ECCS will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent a water hammer following an ECCS initiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points. The 31 day frequency is based on the gradual nature of void buildup in the ECCS piping, the procedural controls governing system operation, and operating experience.

SR 3.5.1.2 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR applies only to valves affecting the direct flow path. This SR excludes valves that, if mispositioned, would not affect system or subsystem '

OPERABILITY. Also, this SR does not apply to valves that are locked, sealed, or otherwise secured in position since these were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the (continued) l Cooper B 3.5-10 Revision 0 j

ECCS - Operating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.2 (continued)

REQUIREMENTS OPERABILITY. Also, this SR does not apply to valves that are locked, sealed, or otherwise secured in position since b

these were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are I

in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. for the HPCI System, this SR also includes the steam flow path for the turbine and the flow controller position.

The 31 day frequency of this SR was derived from the Inservice Testing Program requirements for performing valve testing at least once every 92 days. The frecuency of 31 days is further justified because the valms are operated ;

under procedural control and because improper valve position would only affect a single subsystem. This frequency has been shown to be acceptable through operating experience.

In Mode 3 with reactor steam dome pressure less than the actual shutdown cooling permissive pressure, the RHR System may be required to operate in the shutdown cooling mode to i remove decay heat and sensible heat from the reactor. !

Therefore, this SR is modified by a Note that allows LPCI )

subsystems to be considered OPERABLE during alignment and ,

l operation for decay heat removal, if capable of being l manually realigned (remote or local) to the LPCI mode and not otherwise inoperable. Alignment and operation for decay i heat removal includes when the required RHR pump is not operating or when the system is realigned from or to the RHR shutdown cooling mode. At the low pressures and decay heat loads associated with operation in MODE 3 with reactor steam dome pressure less than the shutdown cooling permissive pressure, a reduced complement of low pressure ECCS subsystems should provide the required cooling, thereby allowing operation of RHR shutdown cooling, when necessary.

(continued) l Cooper B 3.5-10 Revision 0 f

L -. . - - - - . - - - - - _ - - - - - - - _ - - - - - - - - - -

l ECCS - Operating B 3.5.1 BASES' lC SURVEILLANCE SR 3.5.1.3 l REQUIREMENTS l (continued) Verification every 31 days that ADS pneumatic supply header

! pressure is 2 88 psig ensures adequate pneumatic pressure for reliable ADS operation. Prior to startup, the normal pneumatic supply is from instrument air, and'after startup, the normal supply is from instrument nitrogen. The accumulator on each ADS valve provides pneumatic pressure for valve actuation. The design pneumatic supply pressure requirements for the accumulator are such that, following a failure of the pneumatic supply to the accumulator, at least two valve actuations can occur with the drywell at 70% of:

design pressure (Ref. 12). The ECCS safety analysis assumes only one actuation to achieve the depressurization required for operation of the low pressure ECCS. This minimum required pressure of 2 88 psig is provided by the ADS instrument pneumatic supply. The 31 day Frequency takes into consideration administrative controls over operation of the pneumatic system and alarms for low pneumatic pressure.

SR 3.5.1.4 Verification every 31 days that the RHR System cross tie shutoff valve is closed ensures that each LPCI subsystem

remains independent and a failure of the flow path in one subsystem will not affect the flow path of the other LPCI-subsystem. If the RHR System cross tie shutoff valve is open, both LPCI subsystems must be considered inoperable.

The 31 day Frequency has been found acceptable, considering that the valve is under strict administrative controls that will ensure the valve continues to remain closed.

SR 3.5.1.5 ;

Cycling the recirculation pump discharge valves through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will close when required.

Upon initiation of an automatic LPCI subsystem injection signal, these valves are required to be closed to ensure full LPCI subsystem flow injection in the reactor via the l recirculation jet' pumps'. De-energizing the valve in the

! closed position' will also ensure the proper flow path for l

(continued) i Cooper- B 3.5-11 Revision 0 !

L_ _ _ . _ _ _ _ _

ECCS - Operating B 3.5.1 BASES' l SURVEILLANCE SR 3.5.1.5 (continued) l REQUIREMENTS the LPCI subsystem. Acceptable methods of de-energizing the valve include de-energizing breaker control power, racking

out the breaker or removing the breaker.

The specified frequency is once during reactor startup before THERMAL POWER is > 25% RTP. However, this SR is modified by a Note that states the Surveillance is only required to be performed if the last performance was more than 31 days ago. -Therefore, implementation of this Note requires this test to be performed during reactor startup before exceeding 25% RTP. Verification during reactor startup-prior to reaching > 25% RTP is an exception to the normal Inservice Testing Program generic valve cycling frequency of 92 days, but is considered acceptable due to

=the demonstrated reliability.of these valves, if the valve is' inoperable and in the open position, the associated LPCI subsystem must be declared. inoperable.

SR 3.5.1.6. SR 3.5.1.7. and SR 3.5.1.8 The performance requirements of the low pressure ECCS pumps are determined- through application.of the 10 CFR 50, Appendix K criteria (Ref. 7). This periodic Surveillance is performed (in accordance with the ASME Code,Section XI, requirements for the ECCS pumps) to verify that the ECCS pumps will develop the flow rates required by the; respective analyses. The low pressure ECCS pump flow rates ensure that adequate core cooling is provided to satisfy the acceptance criteria'of Reference 8. The pump flow rates are verified against a system head equivalent to the RPV pressure expected during a LOCA. ~ The total system pump outlet pressure is adequate to overcome the elevation head pressure between the pump suction and the vessel discharge, the piping friction losses, and RPV pressure present during a LOCA.

The flow tests for the HPCI System are performed at two different pressure ranges such that system capability to provide rated flow against a system head corresponding to reactor pressure is tested at both the higher and lower operating ranges of the system. The required system head (continued) l' Cooper B 3.5-12 Revision 0

ECCS - Operating B 3.5.1 l BASES l SURVEILLANCE SR 3.5.1.6. SR 3.5.1.7. and SR 3.5.1.8 (continued) l REQUIREMENTS should overcome the RPV pressure and associated discharge line losses. Adequate reactor pressure must be available to perform these tests. Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the HPCI System diverts steam flow. Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these tests. Adequate reactor steam pressure must be /$\

2 920 psig to perform SR 3.5.1.7 and 2 150 psig to perform l SR 3.5.1.8. Adequate steam flow is represented by turbine l bypass valves at least 30% open, or total steam flow g{3 2 10" lb/hr. Reactor startup is allowed prior to performing the low pressure Surveillance test because the reactor pressure is low and the time allowed to satisfactorily perform the Surveillance test is short. The reactor

, pressure is allowed to be increased to normal operating I

pressure since it is assumed that the low pressure test has been satisfactorily completed and there is no indication or reason to believe that HPCI is inoperable.

Therefore, SR 3.5.1.7 and SR 3.5.1.8 are modified by Notes that state the Surveillance are not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam pressure and flow are adequate to perform the test. The 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed for the flow tests after required pressure and flow are reached are sufficient to achieve stable conditions for testing and provides a reasonable time to complete the SRs.

The frequency for SR 3.5.1.6 and SR 3.5.1.7 is in accordance with the Inservice Testing Program requirements. The 18 month Frequency for SR 3.5.1.8 is based on the need to perform the Surveillance under the conditions that apply just prior to or during a startup from a plant outage.

Operating experience has shown that these components usually pass the SR when performed at the 18 month frequency, which is based on the refueling cycle. Therefore, the frequency was concluded to be acceptable from a reliability standpoint.

I (continued)

Cooper B 3.5-13 Revision 0

ECCS - Operating B 3.5.1 BASES i

i SURVEILLANCE SR 3.5.1.9 ,

REQUIREMENTS (continued) The ECCS subsystems are raouired to actuate automatically to perform their design functions. This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCI, CS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup and actuation of all automatic valves to their required positions. This SR also ensures that the HPCI System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the ECSTs to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlaps this Surveillance to provide complete tetting of the assumed safety function.

The 18 month Frequency is based on the need to perform the Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by Note 1 that says for HPCI only the Surveillance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam pressure and flow are adequate to perform the test. The time allowed for this test after required pressure and flow are reached is sufficient to achieve stable conditions for testing and provides a reasonable time to complete the SR. Adequate reactor pressure must be available to perform this test.

Additionally, adequate steam flow must be passing through /A the main turbine or turbine bypass valves to continue to 'E control reactor pressure when the HPCI System diverts steam flow. Thus, sufficient time is allowed after adequate pressure and flow are achieved to perform this test.

Adequate reactor steam pressure is > 150 psig. Adequate steam flow is represented by turbine bypass valves at least (continued)

Cooper B 3.5-14 Revision 0 1

_______________________a

I ECCS - Operating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.9 (continued)

REQUIREMENTS 8

30% open, or a total steam flow of 10 lb/hr. Reactor startup is allowed prior to performing this test because the reactor pressure is low and the time allowed to g

satisfactorily perform the test is short.

This SR is modified by Note 2 that excludes vessel injection / spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

SR 3.5.1.10 The ADS designated SRVs are required to actuate automatically upon receipt of specific initiation signals.

A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e.,

solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components. SR 3.5.1.11 and '

, .the LOGIC SYSTEM FUNCTIONAL TEST performed in LC0 3.3.5.1 l overlap this Surveillance to provide complete testing of the assumed safety function.

The 18 month Frequency is based on the need to perform the Surveillance under the conditions that apply during a plant i outage and the potential for an unplanned transient if the l Surveillance were performed with the reactor at power.

I Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency ;

was concluded to be acceptable from a reliability l l standpoint. J This SR is modified by a Note that excludes valve actuation i since the valves are individually tested in accordance with l SR 3.5.1.11. This also prevents an RPV pressure blowdown.

(ccntinued) ;

Cooper. B 3.5-15 Revision 0 I

L____.w______________________ _

1 1

ECCS - Operating L B 3.5.1 i-BASES SURVEILLANCE SR 3.5.1.11 REQUIREMENTS (continued) A manual actuation of each ADS valve is performed to verify that the valve and solenoid are functioning properly and that no blockage exists in the SRV discharge lines. This is demonstrated by the response of the turbine control or bypass valve or by a change in the measured flow or by any other method suitable to verify steam flow. Adequate reactor steam dome pressure must be available to perform this test to avoid damaging the valve. Also, adequate steam flow must be passing through the main turbine or turbine

bypass valves to continue to control reactor pressure when

! the ADS valves divert steam flow upon opening. Sufficient time is therefore allowed after the required pressure and flow are achieved to perform this SR. Adequate pressure at which.this SR is to be performed is 2: 500 psig (consistent with the recommendations of the vendor). Adequate steam b

l flow is represented by turbine bypass valves at least 30%

l open, or total steam flow 2108 lb/hr. Reactor startup is allowed prior to performing this SR because valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME requirements, prior to valve installation. Therefore, this SR is modified by a Note that I states the Surveillance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are 4 adequate to perform the test. The 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed for manual actuation after the required pressure is reached is sufficient to achieve stable conditions and provides adequate time to complete the Surveillance. SR 3.5.1.10 and the LOGIC SYSTEM. FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

The Frequency is based on the need to perform the Surveillance under the conditions that apply just prior to l or during'a startup from a plant outage. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1. USAR, Section VI-4.3.

.2. USAR, Section VI-4.4. !

l l' (continued) l Cooper B 3.5-16 Revision 0 l

ECCS - Operating ,

B 3.5.1 I i

l BASES REFERENCES 3. USAR, Section VI-4.1.

(continued)

4. USAR, Section VI-4.2.

5. USAR, Section XIV-6,

6. USAR, Appendix G.

7. 10 CFR 50, Appendix K. I

8. 10 CFR 50.46.

9. NEDC-32687P, " Cooper Nuclear Station SAFER /GESTR-LOCA Loss-of-Coolant Accident Analysis," December 1996.

10. 10 CFR 50.36(c)(2)(ii).

11. Memorandum from R.L. Baer (NRC) to V. Stello, Jr.

(NRC), " Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975. ;

1

12. NEDC-24956, "BWR ADS Pneumatic System Comparison to NUREG-0737 Requirement II.K.3.2.8."

1 Cooper B 3.5-17 Revision 0

l0 ECCS - Shutdown B 3.5.2 B 3.5 EMERGENCY CORE C00 LING' SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM t B 3.5.2 ECCS - Shutdown

{

BASES l

BACKGROUND- A description of the Core Spray-(CS) System and the low L

i pressure coolant injection (LPCI) mode of the Residual Heat Removal (RHR) System is provided in the Bases for LC0 3.5.1, "ECCS - Operating . "

~ APPLICABLE The ECCS performance is evaluated for the entire spectrum of SAFETY ANALYSES break sizes for a postulated loss of coolant accident (LOCA). The long term cooling analysis following a design basis LOCA (Ref. 1) demonstrates that only one low pressure ECCS injection / spray subsystem is required, post LOCA, to maintain adequate reactor vessel water level in the event of an inadvertent vessel draindown. It is reasonable to assume, based on engineering judgement, that while in MODES

~4 and 5, one low pressure ECCS injection / spray subsystem can

! maintain adequate reactor vessel water level. To provide.

redundancy, a minimum of two low pressure ECCS l injection / spray-subsystems are required to be OPERABLE in i MODES 4 and 5.

I-The low pressure ECCS subsystems satisfy Cr'iterion 3 of 10 CFR 50.36 (c)(2)(ii)(Reference 2).

LC0 Two low pressure ECCS injection / spray subsystems are required to be OPERABLE. The low pressure ECCS injection /

spray subsystems consist of two CS subsystems and two LPCI L subsystems. Each CS subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or condensate storage tank (CST) to the reactor pressure vessel (RPV). Each LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or CST to the RPV. Only a single LPCI pump is required per subsystem because of the larger injection' capacity in relation to a CS subsystem. In MODES.4 and 5,.the RHR System cross tie shutoff valve is not required to_be closed. The necessary portions of the l

(continued)

CooperL B 3.5-18 Revision 0 L

1 i

ECCS - Shutdown B 3.5.2 I

l BASES l

l LCO Service Water System and the Reactor Equipment Cooling (continued) System are al.so required to each required low pressure ECCS injection / spray subsystem.

l One LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable. Alignment and operation for decay heat removal includes when the required RHR pump is not operating or when the system is realigned from or to the RHR shutdown cooling mode. Because of low pressure and low temperature conditions in MODES 4 and 5, sufficient time ,

will be available to manually align and initiate LPCI '

subsystem operation to provide core cooling prior to postulated fuel uncovery.

l l APPLICABILITY OPERABILITY of the low pressure ECCS injection / spray l

subsystems is required in MODES 4 and 5 to ensure adequate coolant inventory and sufficient heat removal capability for the irradiated fuel in the core in case of an inadvertent draindown of the vessel. Retirements for ECCS OPERABILITY during MODES 1, 2, and 3 are discussed in the Applicability i section of the Bases for LCO 3.5.1. ECCS subsystems are not required to be OPERABLE during MODE 5 with the spent fuel storage pool gates removed and the water level maintained at

> 21 ft above the RPV flange. This provides sufficient coolant inventory to allow operator actnn to terminate the inventory loss prior to fuel uncovery in case of an l inadvertent draindown.

The Automatic Depressurization System is not required to be OPERABLE during MODES 4 and 5 because the RfV pressure is s 150 psig, and the CS System and the LPCI stAsystems can ;

provide core cooling without any depressurization of the ;

primary system.

The High Pressure Coolant Injection System is not required to be OPERABLE during MODES 4 and 5 since the low pressure ECCS injection / spray subsystems can provide sufficient flow to the vessel.

(continued) ,

Cooper B 3.5-19 Revision 0

ECCS - Shutdown B 3.5.2 BASES (continued)

ACTIONS A.] and B.1 If any one required low pressure ECCS injection / spray subsystem is inoperable, the inoperable subsystem must be restored to OPERABLE status in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In this condition, the remaining OPERABLE subsystem can provide sufficient vessel flooding capability to recover from an inadvertent vessel draindown. However, overall system reliability is reduced because a single failure in the remaining OPERABLE I subsystem concurrent with a vessel draindown could result in the ECCS not being able to perform its intended function.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for restoring the required low pressure ECCS injection / spray subsystem to OPERABLE status is based on engineering judgment that considered the remaining available subsystem and the low probability of a vessel draindown event.

1 With the inoperable subsystem not restored to OPERABLE status in the required Completion Time, action must be immediately initiated to suspend operations with a potential for draining the reactor vessel (0PDRVs) to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Actions must continue until 0PDRVs are suspended.

C.1, C.2, 0.1, D.2, and D.3 i

With both of the required ECCS injection / spray subsystems inoperable, all coolant inventory makeup capability may be unavailable. Therefore, actions must immediately be initiated to suspend OPDRVs to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Actions must continue until 0PDRVs are suspended. One ECCS injection / spray subsystem must also be restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time to restore at least one low pressure ECCS injection / spray subsystem to OPERABLE status ensures that prompt action will be taken to provide the required cooling capacity or to initiate actions to place the plant in a condition that minimizes any potential fission product release to the environment.

l l

(continued)

Cooper B 3.5-20 Revision 0 l

L________ _ _ __

ECCS - Shutdown B 3.5.2 BASES C.I. C.2. 0.1. D.2 and 0.3

~

ACTIONS (continued)

If at least one low pressure ECCS injection / spray subsystem 3 is not restored to OPERABLE status within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time, additional actions are required to minimiz'e any potential fission product release'to the environment.

This includes ensuring _ secondary containment is OPERABLE; one standby gas treatment subsystem is OPERABLE; and ,

secondary containment isolation capability is available in I each associated penetration flow path not isolated that is j assumed to be isolated to mitigate radioactivity releases (i.e., one secondary containment isolation valve and associated instrumentation are OPERABLE or other acceptable administrative controls to assure isolation capability.

These administrative controls consist of stationing a dedicated operator, who is in continuous communication with the Control Room at the controls of the isolation device.

In this way, the penetration can be rapidly isolated when a need for secondary containment isolation is indicated).

OPERABILITY may be verified by an administrative check, or by examining logs or other information, to determine whether the components ~are out of service for maintenance _or other:

reasons. It'is not necessary to perform the Surveillance needed to demonstrate the OPERABILITY of the components.

If, however, any required component is inoperable, then it. I

! must be restored to OPERABLE status. In this case, the i Surveillance may need to be performed to restore the component to OPERABLE status.' Actions must continue until all required components are OPERABLE.

i SURVEILLANCE SR 3.5.2.1 REQUIREMENTS . 1 The minimum water level of 12 ft 7 inches required for the suppression pool is periodically verified to ensure that the suppression pool will provide adequate net positive suction ;

head (NPSH) for the CS System and LPCI subsystem pumps, l recirculation volume, and vortex prevention. With the

! suppression pool water level less than the required limit, L all ECCS injection / spray subsystems are inoperable unless they are aligned to the OPERABLE CST A. OAs I

(continued)

Cooper- B 3.5-21 Revision 0

ECCS - Shutdown B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 (continued)

REQUIREMENTS l When suppression pool level is < 12 ft 7 inches, the CS i System and LPCI subsystems are considered OPERABLE only if they can take suction from CST A, and the CST A water level is sufficient to provide the required NPSH for the required b

CS pump and LPCI pumps. (LPCI pumps "A" and "D" are the only LPCI pumps that can be aligned to CST A.) Therefore, a A OD verification that either the suppression pool water level is

> 12 ft 7 inches, or that the required CS and LPCI subsystems are aligned to take suction from CST A and CST A contains 2 150,000 gallons of water, equivalent to 14 ft, %

ensures that the CS System and LPCI subsystems (LPCI pumps "A" and "D") can supply at least 50,000 gallons of makeup '

water to the RPV. The excess 100,000 gallons remains as a supplementary volume and to ensure adequate ECCS pump NPSH.

However, as noted, only one required CS or LPCI subsystem may take credit for the CST option during OPDRVs. During OPDRVs, the volume in CST A may not provide adequate makeup if the RPV were completely drained. Therefore, only one CS M

or.LPCI subsystem is allowed to use the CST option. This ensures the other required ECCS subsystem has adequate makeup volume.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency of these SRs was developed considering operating experience related to suppression pool water level and CST A water level variations and instrument drift during the applicable MODES. Furthermore, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is lk considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal suppression pool or CST A water level condition. h SR 3.5.2.2, SR 3.5.2.4, and SR 3.5.2.5 The Bases provided for SR 3.5.1.1, SR 3.5.1.6, and SR 3.5.1.9 are applicable to SR 3.5.2.2, SR 3.5.2.4, and SR 3.5.2.5, respectively.

SR 3.5.2.3 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS (continued)

Cooper B 3.5-22 Revision 0

, ECCS - Shutdown B 3.5.2 BASES' SURVEILLANCE. SR 3.5.2.3 (continued)

REQUIREMENTS operation. This SR applies only to valves affecting the direct flow path. This SR exclused valves that, if mispositioned, would not affect system or subsystem OPERABILITY. Also, this SR does not apply to valves that b

are locked, sealed, or otherwise secured in position, since these valves were verified to be in the' correct position prior.to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically i reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This.SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. The.31 day Frequency is appropriate because the valves are operated under procedural control and the probability.of their being mispositioned during this time period is low.

In MODES 4 and 5,'the RHR System may be required to operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Therefore,.this SR is modified by a Note that allows one LPCI subsystem to be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned (remote or local) to the LPCI' mode and not otherwise inoperable.

Alignment and operation for decay heat removal includes when the required RHR pump is not operating or when the system is being realigned from or to the RHR shutdown cooling mode.

l-Because of the low pressure and low temperature conditions in MODES 4 and 5-sufficient time will be available to manually align and initiate LPCI subsystem operation to provide- core cooling prior to postulated fuel uncovery.

This will ensure adequate core cooling if an inadvertent RPV draindown should occur.

REFERENCES 1. GENE-187-18-0892, " Loss of Coolant Accident Analysis with 125 Volt DC Power Source Failure for Cooper Nuclear Station," August 1992, l

2 .. 10 CFR 50.36(c)(2)(ii),

1 L Cooper B 3.5-23 Revision 0 l

RCIC System B 3.5.3

'B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B.3.5.3 RCIC System BASES BACKGROUND The RCIC System is not part of the ECCS; however, the RCIC System is included with the ECCS section because of their similar functions.

The RCIC System is designed to operate either automatically

, or manually following reactor pressure vessel (RPV) isolation accompanied by a loss of coolant flow from the feedwater system to provide adequate core cooling and control of the RPV water level. Under these conditions, the High Pressure Coolant Injection (HPCI) and RCIC systems perform similar functions. The RCIC System design requirements ensure that the criteria of Reference 1 are satisfied.

The RCIC System (Ref. 2) consists of a steam driven turbine pump unit, piping, and valves to provide steam to the turbine, as well as piping and valves lto transfer water from the suction source to the core via the feedwater system line, where the coolant is distributed within the RPV through the feedwater sparger. Suction piping is provided from the emergency. condensate storage tanks (ECSTs) and the suppression pool. Pump suction is normally aligned to the ECSTs to minimize injection of suppression pool water into the RPV. However, if the ECST water supply is low, an automatic transfer to the suppression pool water source

' ensures a water supp_ly for continuous operation of the RCIC System. The steam supply to the turbine is piped from a main steam line upstream of the associated inboard main steam line isolation valve.

l l

The RCIC System is designed to provide core cooling for a wide range of steam inlet pressures, 150 to 1120 psia. Upon receipt of an initiation signal, the RCIC turbine accelerates to a specified speed. As the RCIC flow l increases, the turbine control valve is automatically adjusted to maintain design flow. Exhaust steam.from the RCIC turbine is discharged to the suppression pool. A full flow test line is provided to route water tu the ECST to allow testing of the RCIC System during normal operation without injecting water into the RPV.

l (continued)

Cooper B 3.5-24 Revision 0 1

i RCIC System l B 3.5.3 '

BASES 1

BACKGROUND The RCIC pump is provided with a minimum flow bypass line, (continued) which discharges to the suppression pool. The valve in this line automatically opens to prevent pump damage due to i overheating when other discharge line valves are closed. To ensure rapid delivery of water to the RPV and to minimize water hammer effects, the RCIC System discharge piping is kept full of water. The RCIC System is normally aligned to the ECSTs. The RCIC discharge line is kept full of water using a " keep fill" system (Pressure Maintenance System).

APPLICABLE The function of the RCIC System is to respond to transient SAFETY ANALYSES events by providing makeup coolant to the reactor. The RCIC System is not an Engineered Safety Feature System and no credit is taken in the safety analyses for RCIC System operation. Based on its contribution to the reduction of overall plant risk, however, the system satisfies Criterion 4 of Reference 3.

LC0 The OPERABILITY of the RCIC System provides adequate core cooling such that actuation of any of the low pressure ECCS subsystems is not required in the event of RPV isolation accompanied by a loss of feedwater flow. The RCIC System has sufficient capacity for maintaining RPV inventory during an isolation event, ,

APPLICABILITY The RCIC System is required to be OPERABLE during MODE 1, i

j and MODES 2 and 3 with reactor steam dome pressure

> 150 psig, since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized. In MODES 2 and 3 with reactor steam dome pressure s 150 psig, and in MODES 4 and 5, RCIC is not required to be OPERABLE since the low pressure ECCS injection / spray subsystems can provide sufficient flow to the RPV.

)

l I

(continued) i Cooper B 3.5-25 Revision 0 ;

l l

RCIC System 3 3.5.3 BASES (continued)

ACTIONS A.1 and A.2 If the RCIC System is inoperable during MODE 1, or MODE 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCI System is verified to be OPERABLE, the RCIC-System must be restored to OPERABLE status within 14 days. In this b

Condition, loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at high reactor pressure since the HPCI System is the only high pressure system assumed to function during a loss of coolant accident (LOCA). OPERABILITY of HPCI is therefore verified A within I hour when'the RCIC System is inoperable. This may CD be performed as an administrative check, by examining logs or other information, to determine if HPCI is out of service for maintenance or other reasons. It does not mean it is necessary to perform the Surveillance needed to demonstrate the OPERABILITY of the HPCI System. If the OPERABILITY of the HPCI-System cannot be verified, however, Condition B must be immediately entered. For transients and certain d

abnormal events with no LOCA, RCIC (as opposed to HPCI) is the preferred source of makeup coolant because of its relatively small capacity, which allows easier control of the RPV water level. Therefore, a limited time is allowed to restore the inoperable RCIC to OPERABLE status.

The-14 day Completion Time is consistent with the recommendations in a reliability study (Ref. 4) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (A0Ts). Because of similar functions of HPCI and RCIC, the A0Ts (i.e.,

Completion Times) determined for HPCI are also applied to RCIC.

B.1 and B.2 If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within (continued)

' Cooper B 3.5-26 Revision 0

RCIC System B 3.5.3

. BASES ACTIONS B.) _and 8.2 (continu'd) e 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reactor steam dome pressure reduced to 1 150 psig within 36. hours. The allowed Completion Times are reasonable, based on operating experience, to reach the

. required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE- SR 3.5.3.1 REQUIREMENTS The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge line of the RCIC System full of water ensures that the system will perform properly, injecting its full capacity into the Reactor Coolant System'upon demand. This will also prevent a water hammer following an initiation signal. One acceptable method of ensuring the line is full is to vent at the high points. The 31 day Frequency is based on the gradual nature of void buildup in the RCIC piping, the procedural controls governing system operation, and operating experience.

SR 3.5.3.2 Verifying .the correct alignment for manual, power operated, and automatic valves in the RCIC flow path provides assurance that the proper flow path will exist for RCIC operation. This SR applies only to valves affecting the direct- flow path. This SR excludes valves that, if mispositioned, would not affect system or subsystem OPERABILITY. Also, this SR does not apply to. valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition._in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This SR does.not apply to valves that cannot be inadvertently misaligned, such as check valves. For the

. (continued) l Cooper B 3.5-27 Revision 0 l

RCIC System B 3.5.3 i

BASES SURVEILLANCE SR 3.5.3.2 (continued) l REQUIREMENTS RCIC System, this SR also includes the steam flow path for the turbine and the flow controller position.

The 31 day frequency of this SR was derived from the Inservice Testing Program requirements for performing valve testing at least once every 92 days. The frequency of 31 days is further justified because the valves are operated under procedural control and because improper valve position would affect only the RCIC System. This Frequency has been shown to be acceptable through operating experience.

SR 3.5.3.3 and SR 3.5.3.4 The RCIC pump flow rates ensure that the system can maintain reactor coolant inventory during pressurized conditions with the RPV isolated. The flow tests for the RCIC System are performed at two different pressure ranges such that system capability to provide rated flow against a system head corresponding to reactor pressure is tested both at the higher and lower operating ranges of the system. The required system head should overcome the RPV pressure and associated discharge line losses. Adequate reactor steam pressure must be available to perform these tests.

Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the RCIC System diverts steam fl ow. Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these SRs.

Adequate reactor steam pressure to perform SR 3.5.3.3 is 920 psig and 150 psig to perform SR 3.5.3.4. Adequate steam flow is represented by turbine bypass valves at least 30%

open, or total steam flow > 10" lb/hr. Reactor startup is allowed prior to performing the low pressure Surveillance because the reactor pressure is low and the time allowed to satisfactorily perform the Surveillance is short. The reactor pressure is allowed to be increased to normal i operating pressure since it is assumed that the low pressure I Surveillance has been satisfactorily completed and there is no indication or reason to believe that RCIC is inoperable.

Therefore, these SRs are modified by Notes that state the !

Surveillance are not required to be performed until 1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam pressure and flow are (continued)

Cooper B 3.5-28 Revision 0

RCIC System B 3.5.3

-BASES SURVEILLANCE SR 3.5.3.3 and SR 3.5.3.4 (continued)

REQUIREMENTS adequate to perform the test. The 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed for the flow tests after the required pressure and flow are reached

.are sufficient to achieve stable conditions for testing and provides a reasonable time to complete'the SRs.

A 92. day Frequency for SR 3.5.3.3 is consistent with the Inservice Testing Program requirements. The 18 month Frequency for SR 3.5.3.4 is based on the need to perform the Surveillance under conditions that apply just prior to or during a'startup from a plant outage. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the frequency was concluded to be acceptable from a reliability standpoint.

SR 3.5.3.5 1he RCIC System is required to actuate-automatically in order to verify its design function satisfactorily. Thi_s Surveillance verifies that, with a required system initiation signal. (actual or simulated), the automatic initiation logic'of the RCIC System will cause the system to operate as designed,. including' actuation of.the system throughout its emergency operating sequence; that is, automatic. pump startup and actuation of all automatic valves to their' required positions. This test'also ensures the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the ECST to the_ suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in

_ LCO'3.3.5.2 overlaps this Surveillance to provide complete testing of the assumed design function.

The 18 month Frequency is based on the need to perform the Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the M

Surveillance were performed with the reactor at power.

Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency

~

was concluded to be acceptable from a reliability standpoint.

(continued)

Cooper B 3.5-29 Revision 0 l

1

_ _ - _ _ - _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ - _ _ _ - _ . _ _ . _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _-_-_-_= . _ . .__ _ _

RCIC System l

B 3.5.3 BASES l

L SURVEILLANCE SR 3.5.3.5' (continued) o REQUIREMENTS This SR is modified by Note 1 that says the Surveillance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the

[ reactor steam pressure and flow are adequate to perform the test. The time allowed for this test after required pressure and flow are reached is sufficient to achieve stable conditions for testing and provides a reasonable time to. complete the SR. Adequate reactor pressure must be available to perform this test. Additionally, adequate steam flow must be passing through the-main turbine or L turbine bypass valves to continue to control reactor l

pressure when the RCIC System diverts steam flow. Thus, A sufficient time is allowed after adequate pressure and flow are achieved to perform this test. Adequate reactor steam pressure is 150 psig. Adequate steam flow is - represented by turbine bygass valves at least 30% open, or a total steam-flow of 10 lb/hr. Reactor startup is allowed prior to performing this test because the reactor pressure is low and the time allowed to satisfactorily perform the test is short.

~

This SR is modified by Note 2 that excludes vessel injection .;

during the Surveillance.- Since all active components are testable and full flow can be demonstrated.by recirculation L through the test line, coolant injection into the RPV.is not

-required during the Surveillance.

) REFERENCES- 1. USAR, Appendix F.

2. .USAR, Section IV-7.

3. 10 CFR 50.36(c)(2)(ii).

4. ' Memorandum from R.L. Baer (NRC) to V. Stello, Jr.

(NRC), " Recommended Interim Revisions to LCOs for ECCS l Components," December 1, 1975. ,

1 'i i

l 4 l

-Cooper- B 3.5-30 Revision 0 1

b ftCh4 hork 3. [o )

TJMITfNC kDITIO [ fop. OPEPATION SURVEf f_f ANCE REOUf pFMENTS /

3,5.A (con, 4AA_ (contid-) J l

h FProm and af ter the date that one oil the Core Spray subsystems is made or

'2 I Ohen it is determined t Spray subsystem is i one Core ]

erable, the found to be inoperable for any operable Core Spr 'I]

L '# subsystem and

! reason, continued reactor operation) is permissible dortna eba aneceedinr1 I both LPCI su stems shall be verified to b parable immediately.

i L*/ l~

{bevan daysfp1'5vided j that during sucn1 The opera Core Spray subsystem f Tnven days all active components

( shall verified to be operable fdD06 that affect operability of the ) , dai_1y'thereafter, l operable Core Spray subsystem and I all active components thati affect 3. LPCI subsystem testing shall be 6kJ gpe rab f l i cy 4.f _bo th LPcf enheyneame _follows:

g oper * "

hedJal 0 h CI subsystems shall Simulated "Once/ Operating l' (I tomatic Actuation Q cle ggt prior to reactor startup from} f C Pump Operyb111ty Once nth l a Cold Condition, except as specified in 3.22.B.1, or c. Motpr' Operated ce/monthj

&,c0NlI. I ~ vaTve operability -I (2) when there is irradiated fuel Pump Flow Rate in the vessel and when the ,.

(Once/3 months reactor vessel pressure is l (M 3 5 8 greater than atmospheric h m M m@

pump shall deliver least 7700 CPM '

pressure, except as specified j but no more tha 400 CPM against a ~

in3.5.A.4and3.5.A.5below) system head c ivalent to a reactor '

vessel pr sure of 20 psid above y m.d Nale 2 drywell ressure with water l evel)

A lo SR 3 CIA "" "' " ' " " " " ' '"* ****

conditions, two pump LPCI flow shall l

( 3 be at least 15,000 CPM.

,y g,5 Recirculation pump discharge valves shall be tested leach retuelin

.Se e CT5 ; loutagel to verify full open to full ,.

y,g,g g f.

closed lin#s; 26 sednaJ An air est shall be perf ed on)

M h 'From and after the date C Et one of the RHR (LPCI) pumps is made or L the ell and torus zles nee /5 years.

ders and

)

My k - found to be inoperable for any A. When it is determined tha one of reason, continued reactor operation the RHR (LPCI) pumps is noperable - l,,,, / )

is p_ermi sible only during tha j

,fq7l

, 7 mucceed

~

hyreg anyffprovicea Laat i at a time when it is operable, the re utred to be ning active fIng sucn enpr G days the I components that af cc operability jremaining act(ve components that {

of the LPCI subsysfem containing the C

g- -

affect operability of the LPCI inoperable pump, all active subsystem containing the inoperable components that affect operability pump, and all active components that of the operable LPCI subsystem, and i affect operability of the operable [ both Core Spray subsystems shall be subsystem, both Core Spray) verified to be operable immediately LLPCI subsystems, A nd both diese and the operable LPCI pumps daily ene,ators _e operam e.

a er.after. a l

-115- 1 3/11/92 :

)

l l

1

SpeciL % 3 Cl LIMITINC CON M ONS FOR OPERATION SURVE IANCE REQUIREMENTS 1 L 5. A d.) _ , _ _ A. (Cont'd.)

( h I rom F and after the date that one LPCI subsystem is made or found to r.

5 Who it is determined hat a 1.PCI .

! a system 'is in erable, the I be inoperable for any reason, perable LPCI sub stem, both Core i (JI)CC continued reactor operation is Spray subs _yst s A nd ie RHR7 permissible only during the [servic Su5syst associated -

l succeeding 7 days, unless it is! Iwith erable u ooner made operable, provided that' a I subsystem,,

during such 7 days all active shall b . verified to be operabre j1 imme tely and daily thereafter. f T l ,

components that affect operability c Jon h of the operable 1.PCI subsystem, bot .

Core Spray subsys tems .jt (servi 3. 5, l. s

./bI Lui ater suosyscem anarmhla 1P sociated mub aygg ,) -

R b p diesel generators sh 1 be opgrable._ }

P h~ All recirculation pump discharge

h. J , f;/,g

% All recirculation pump discharge valves shall be operable prior to valves shall be tested for operability juuring any period of I reactor startup (or closed if permitted elsewhere (Reactor cold shutdown evenadine in these 148 hour0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months slif operability tests have u specifications) not been performed during the j t e a e r9 preceding 31 days. .

OoCo fac Ng The reactor shall not be started upl

% kp pr.of' l

with the RHR system supplying 3.0h cooling to the fuel pool. J -

/0 &#CNg] I z s % RTP Q. fIf 1 the requirements of 3.5.A an Q jy(yg N cnet B ' gr,2,3,4,5,6 oer or 7 cannot snuedown or one be ,re.ctomet, d >.^ G han.5 lah be initiatedfand the reactor

(

shall be in the cold shutd b

hours.

j L . lp condition within s "B . Residual Heat Removal (RHR) Service h ,

{

d' 7 Residual Heat Removal (RHR) Service Water System i

Water System N 1. RHR Service Water System testing l j i l

1. Except as specified in 3.5.B.2, shall be as follows:

1 3.5.B.3, and 3.5.F.3 below, both RHR Service Water subsystess shall be USB Frecuency operable whenever irradiated fuel is in the reactor vessel and reactor a. Pump & Valve Once/3 months i

coolant temperature is greater than Operability i

212'F. and prior to reactor startup from a Cold Condition, b. Pump Capacity Test. After pump Each RHR service maintenance and ,

water booster pump every 3 months !

shall deliver 4000 gpm.

3.11 Ay S R 3.L L 4

-116- 3/11/92 f

w ay 3 u 10

5pec;Ccahon 3Sl

$.l LIMITING CONDITION OR OPERATION SURVEILLANCE REOtdREMENT l 1 -

3.5.C HPCI S a (cont'd.) 4.5.C. HP ystem (cont'd.) {

) From and after the date that the -

Frecuency

~ HPCI System is made or found to be -

p inoperable for any reason, continuedQ Flow Rate at ce/3 months reactor operation is permissible approximately 1 0 only during the succeeding 1se/eri ft/ psig Steam Pres 20-1020 fg days unless such system is sooner 7 -

j made operable, providing that during Flow Rate at [

such 4 se,*n) days all active approximately (Once/operatin cycle )

components that affect operability psig Steam Press.

fof the ADS, the RCIC System, both q bb i

The HPCI pump shall be demonstrated h N (LPCI subsystems subsystems are operable. and both Core Spray g I'l to be capable of delivering at least 9to o*A 5101 sg 4250 gpra for a system head With the surve 11ance sequuements A cqrrespondin ressure .

I g3 jg of 4.5.C not performed at the required intervals due to reactor orr.seni tosj a reactor gg p%

SR 3 5,l ~f an /Apfjen C

shutdown, a reactor startup may be [ Vhen it o uncesmthed that the HPCI N3.Sdk0* conducted provided the appropriate System is inoperable, the RCIC !

i j'h' f'o" surveillance is performed within Sys temf)foth LPCI systems. an ,/

12. hours of achieving lua ystd stemdshall be M. reactor steam cressur , (@bothCoteSpravsub erified to be operable n mm.awrei und adequaN * *

g If the requirements of .C.1

g The e

IC System sh 1 be verilleo erable hil the re a f te r_. f CTrod cannot be met, fan orderly strutdown) e additio the ADS logic hall be gg . 4./

pshall b( initiatedfand the reactor pressure shall demo rated to operable l'k

. be reduced to i i _diately "

and dai

~

thereafter.

150 psig or less within hours.

(08 wde 12 8 Nuff thLw i 6dr Q . .5 -

py 056 bchon }

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

LA D. Eeactor Core Isolation Cooline D, Reactor Core Isolation Cooling g (RCIC) System (RCIC) System j

\

1. The RCIC System shall be operable 1. RCIC System testing shall be )

whenever there is irradiated fuel in performed as follows:

the reactor vessel, the reactor pressure is greater than 113 psig. litm Frecuency

)

and prior to reactor startup from a Cold Condition, except as specified a. Simulated Once/ operating in 3.5.D.2 and 3.5.D.3 below. Automatic cycle i

Actuation Test i J

Sii T TS.

3.5. 3

-118 01/2S/95 l

) fu e [ of IO

~

l l

c_______________.__.

t

.L,}fif 7ING CONDITJ s p ci k k 3 s i FOR OPERATION SURVEILIAN RPOUTPEMENTS Q S.E )

4.5 nt'd) f

(

From and after the date that one 12. When it is detemined tha l valve in the Automatic Depressuriza. of the ADS is inoper e, ne valve'

^

CTro# F tion System is made or found to be the ADS inoperable for any reason, continued actuation logic f valves shall the other ADS ,,_,) r / * } 1I teactor operation is nermi.sible w operable i demonstrated to be. 6 only during the succeeding se en iately / In addition,1 the HPCI System shall be verified to days unless such valve is sooner be operable immediately. /,f p j

made operable, provided that during

[h

~

N such seven days the HPCI System is operable.

.c- m With the surveillance requirements O of 4.6.D.5 not performed at the Cdh

.gh required intervals due to reactor y

R'3.7,l3 shutdown, a reactor startup may be conducted provided the appropriate surveillance is performed within 12 j hours of achieving M ' a eactor l M4 pry 0!d steam pressu A M.E A (Acriosa L. >

$ g 3,g,j,3 h? In bW If the requirements of 3.5.E.1 or ~

(dC7 eoWf 3.5.E.2 cannot be met ,J ayorde rl y7 .fh'nl7fiadr j* ' (_shutdomfh shal1 be initi #edfand the reactor pressure shall be reduced to -

f,,, j j f50 at leas psig within Q hours. J 3 -

N. Minimum Low pressure Cppling and F.

Diesel Generator Availability Minimum Low Pressure Coolina and Diesel Generator Availability

1. During any period when one diesel 1.

generator is inoperable, continued When it is determined that one reactor operation is permissible diesel generator is inoperable, the following requirements shall be met. g only durint the succeeding seven g I

days unless such diesel generato. is a. Immediately and daily j

sooner made operable, provided L..e.:

( the operable diesel generator and thereafter, the diesel generator shall be redundant its associated LPCI, Core Spray, and verified to be OPERABLE.

RHR Service Water subsystems are

't operable, the requirements of b. Immediately and daily 4.5.F 1 and the remaining thereafter,

'k requirements of 3. 9. A.1 are met. If the LPCI, Core Spray, and RHR Service Water kl s

these requirements cannot be sne t ,

the requirements of 3. 5.F.2 shall be subsystems associated with the OPERABLE diesel generator met. shall be verified to be

, operable.

\

Within 24 hours determine c.

I

! OPERABLE diesel generator is not inoperable due to common

\i cause failure, or perform

\ Surveillance 4.9.A.2.a.1.

(

d. Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months thereafter, the OPERABLE I

diesel generator shall be j demonstrated to be OPERABLE if the inoperable C.iesel generator is not soonet declared OPERAELE.

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

,_ _..- v - - -

u

Amendment No. 175 -120+ I i

See TTS: 04/29/96 3.S .1 i

Py e 7 /10

DISCUSSION OF CHANGES ITS: 3.5.1 - ECCS-OPERATING ADMINISTRATIVE 4 A.5 CTS 3.5.F.3, which states any combination of inoperable components shall not defeat the capability of remaining components to fulfill their cooling function, is proposed to be deleted because proposed LCO 3.0.6 and Specification 5.5.11, Safety Function Determination Program, covers these requirements in significantly more detail. As such, the change is considered administrative.

TECHNICAL CHANGES - MORE RESTRICTIVE M.1 An additional requirement, proposed SR 3.5.1.2, is to be added to existing Specifications for surveillance testing of CS (CTS 4.5.A.1),

LPCI (CTS 4.5.A.3), and HPCI (CTS 4.5.C.1). SR 3.5.1.2 adds a requirement that each ECCS spray / injection subsystem manual, power l operated, and automatic valve in the flow path, that is not locked, I sealed, or otherwise secured in position, will be verified to be in the I correct position every 31 days. This SR provides assurance that the proper flow path will exist for ECCS operation. The addition of new requirements to the Technical Specifications constitutes a more restrictive change.

M.2 The Completion Time for CTS 3.5. A.4 (proposed ITS 3.5.1 ACTION A) is proposed to be decreased from 30 days to 7 days. Because loss of a LPCI pump causes one LPCI subsystem to become inoperable (a LPCI subsystem consists of two LPCI pumps and piping and valves), the Completion Times for loss of a LPCI pump and loss of a LPCI subsystem should be the same.

Reducing the Completion Time to restore an inoperable LPCI pump to service from 30 days to 7 days constitutes a more restrictive change l necessary to ensure timely action is taken in the event of an inoperable LPCI pump.

M.3 CTS 4.5.A.6 requires that recirculation pump discharge valves be demonstrated Operable (capable of being closed) following "any period of reactor cold shutdown exceeding 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ". This requirement is proposed to be replaced by SR 3.5.1.5 which requires that recirculation pump discharge valve Operability verification be performed once each startup l prior to exceeding > 25% RTP. Recirculation pump discharge valves are l not required while the plant is shutdown. The requirement to perform the verification once each startup prior to exceeding 25% RTP is more restrictive than the existing requirement to perform the test since the l test will now be required to be performed within 31 days of any startup not just a startup from a Cold Shutdown that exceeded 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . Testing prior to need is more restrictive than one test per outage. This change is necessary to ensure the Operability of the recirculation pump discharge valves is adequately maintained.

M.4 CTS 3.5.A.8 requires that "an orderly shutdown of the reactor shall be initiated" when the ACTIONS or Completion Times associated with an inoperable LPCI or CS System cannot be satisfied. CTS 3.5.C 4 and CTS 3.5.E.4 require that "an orderly shutdown shall be initiated" when the ACTIONS associated with an inoperable HPCI or ADS System cannot be satisfied. This requirement is proposed to be replaced by LC0 3.5.1 Required Actions B.1 and G.1 which require the plant be in MODE 3 within b

. CNS 2 Revision 0

DISCUSSION OF CHANGES ITS: 3.5.1 - ECCS-0PERATING TECHNICAL CHANGES - MORE RESTRIC11VE H.4 (continued) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months under the same conditions. Based on operating experience, this Completion Time limit still allows for an orderly transition to MODE 3 without challenging plant systems. This change is more restrictive because it provides an additional requirement to place the plant in MGDE 3 vice simply initiating a shutdown. This change is necessary to ensure timely action is taken to place the unit in a MODE outside of the Applicability.

M.5 SR 3.5.1.4 is proposed to be added to existing Specifications for surveillance testing of the RHR System. This SR requires verification that the RHR System cross tie shutoff valve is closed every 31 days to ensure reliable operation of the LPCI System during an accident. The addition of a new SR constitutes a more restrictive change.

.M . 6 CTS 3.5.C.3 is proposed, in the Note to ITS SR 3.5.1.8, to require that CTS 4.5.C.I.e (the low pressure test, proposed SR 3.5.1.8) be performed A within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after adequate steam pressure (150 psig) and adequate steam flow are achieved, vice 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This change is more restrictive since it stipulates that proposed SR 3.5.1.8 be completed within a smaller time frame with respect to suitable reactor steam pressure and flow. This also applies to CTS 4.5.C.I.a (the simulated automatic actuation test, proposed SR 3.5.1.9), as proposed in Note 1 to SR g

3.5.1.9. In addition, CTS 4.5.C.l.d (the high pressure test, proposed SR 3.5.1.7) must be .erformed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after adequate steam pressure and flow ar available per the Note to ITS SR 3.5.1.7. Because this is generally satisfied within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after exceeding 150 psig, this addition is also considered more restrictive. This change is necessary to ensure the HPCI pump is tested at the earliest opportunity after conditions are reached to perform the testing.

M.7 The proposed change adds a requirement, LC0 3.5.1 ACTION F, that limits /bA continued reactor operation to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when there is a simultaneous ,

.inoperability of'one ADS valve and one low pressure ECCS (CS or LPCI) l subsystem. This requirement is more restrictive because current requirements will allow 7 days of continued operation under the same conditions. The current specifications do not require that the Operability of low pressure ECCS Systems be considered when an ADS valve .

is inoperable. With both an ADS valve and a low pressure ECCS subsystem ;

inoperable, another single failure may place the plant in a condition ;

where adequate core cooling may not be available during an accident.

Therefore, an allowable outage time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months has been assigned to i i

either restore the inoperable ADS valve or the low pressure ECCS

. subsystem. The addition of a new requirement to the Technical Specifications constitutes a more restrictive changt.

M.8 SR 3.5.1.3 is proposed to be~added to existing Specifications for surveillance testing of the ADS System. This SR requires ADS pneumatic supply header pressure to be verified a 88 psig every 31 days to ensure CNS 3 Revision 0

l DISCUSSION OF CHANGES ITS: 3.5.1 - ECCS-OPERATING f TECHNICAL CHANGES - LESS RESTRICTIVE l

L.3 (continued)

I' equipment availability. Also, the ITS and current BWR operating philosophy accept the philosophy of system Operability based on satisfactory performance of monthly, quarterly, refueling interval, post maintenance or other specified performance tests without requiring additional testing when another system is inoperable (except for diesel generator testing, which is not being changed).

L.4 This change proposes to delete the requirements in CTS 3.5. A.2, 3.5. A.4, and 3.5.A.5 to ensure that the diesel generators (DG) are Operable.

Requiring an Operable DG in the same division as an inoperable LPCI pump, LPCI subsystem, or CS pump is overly restrictive, because the CNS accident analysis in.USAR Section VI - 5.0, " Safety Evaluation", assumes an inoperable DG in this situation. Additionally, ACTIONS to be performed if an inoperable DG exists with an inoperable LPCI pump, LPCI l subsystem, or CS pump in the opposite division are proposed to be retained, but moved to proposed Specification 3.8.1, AC Sources -

Operating, Required Action B.2. Currently, CTS 3.5.A.2, 3.5.A.4, and 3.5.A.5 specify no Completion Time for this verification, while proposed Specification 3.8.1 allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to declare required features supported by the inoperable DG inoperable when the redundant required features are inoperable. This 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time will allow the operator time to evaluate and repair any discovered inoperabilities, l which minimize the risk due to subjecting the unit to transients associated with a shutdown. The Completion Time also considers the capacity and capability of the remaining AC sources and the low probability of a DBA occurring during this period. The deletion of the requirement to ensure Operability of the DGs and the allowance of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to declare the required features supported by an inoperable DG {

l inoperable when the redundant required features are inoperable i constitutes a less restrictive change.

L.5 CTS 3.5. A.3 requires that "the reactor shall be in Cold Shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " when the ACTIONS for LPCI or CS cannot be satisfied, CTS 3.5.C.4 requires that " reactor pressure shall be reduced l to 150 psig or less within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " when the ACTIONS' for HPCI cannot be satisfied, and 3.5.E.4 requires that " reactor pressure shall be reduced ta at least 113 psig within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " when the Required Actions for an

inoperable ADS valve cannot be satisfied. For ADS, the pressure of l 113 psig in the Applicability and corresponding shutdown requirement is l revised to 150 psig. This change is addressed in Discussion of Changes for ITS: 3.5.1 Change L.ll. The proposed requirements, LC0 3.5.1, n Required Actions B.2 and G.2, extend the time allowed for the plant to L81 reduce pressure or be in MODE 4, from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This extension provides the necessary time to cool the plant and reduce pressure in a controlled and orderly manner. The additional time to complete these ACTIONS reduces the potential for a plant event that could challenge plant safety systems. The 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months proposed is a reasonable amount of time to reach the required plant operating .

conditions. l l

CNS 7 Revision 0 l

I.

N _-___ ___ _ _-______ ---__ ___- __-_. _ _ - _ _ _ - _ _ - _ - _ _- _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

DISCUSSION OF CHANGES ITS: 3.5.1 - ECCS-0PERATING TECHNICAL CHANGES - LESS RESTRICTIVE L.6 CTS 3.5.C.2 allows continued operation for a maximum of 7 days after HPCI is determined to be inoperable. Proposed Specification 3.5.1 ACTION C allows continued operation for a maximum of 14 days under the same conditions. As in the existing Specification, the 14 day d

Completion Time for restoring HPCI is contingent upon the Operability of RCIC and all of the ECCS subsystems (ADS, LPCI, and CS). The exception, LC0 3.5.1 ACTION D, which allows operation for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with HPCI and d {

one low pressure ECCS subsystem inoperable is addressed in Discussion of Changes for ITS: 3.5.1 Comment L.9. The 14 day completion time is based on a reliability study that evaluated the impact on ECCS availability .

(Memorandum from R.L. Baer (NRC) to V. Stello, JR. (NRC), " Recommended '

Interim Revisions to LCOs for ECCS Components," December 1,1975).

Factors contributing to the acceptability of allowing continued operation for 14 days with HPCI inoperable include: the similar functions of HPCI and RCIC, and that the RCIC is capable of performing i the HPCI function, although at a substantially lower capacity; the continued availability of the full complement of ADS valves and the ADS system's capability in response to a small break LOCA; and, the continued availability of the full complement of low pressure ECCS subsystems which, in conjunction with ADS, are capable of responding to I a small break LOCA. For combinations of inoperable ECCS not bounded by the safety analysis, ITS 3.5.1 Required Action H.1 is provided to direct entry into LC0 3.0.3 since this condition results in operation outside of the CNS design and licensing basis. dI L.7 CTS 4.5.C.I.d requires verification that HPCI is capable of delivering at least 4250 gpm "at approximately 1000 psig reactor steam pressure." 4 The proposed Specification, SR 3.5.1.7, requires verification of a minimum 4250 gpm HPCI flow rate with reactor pressure ;a 920 psig and

s 1020 psig, providing a specific pressure band in which the testing is to be performed. The HPCI performance to at high pressure is the second part of a two part test that verifies HPCI pump performance at the upper and lower end of the range of steam supply and pump discharge pressures in which the HPCI pump is expected to perform. Performance of 1 the HPCI test at both ends of the expected operating pressure range confirms that the HPCI pump and turbine are functioning in accordance with design specifications. The ability of the HPCI pump to perform at i

the highest required pressure has already been demonstrated. A small l decrease in the pressure to as low as 920 psig at which the performance to design specifications is verified will not affect the validity of the test to determine that the pump and turbine are still operating at the design specifications.

L.8 This change proposes to raise the steam pressure in CTS 3.5.C.3 and 4.5.C.e at which the HPCI pump flow rate tests are performed from approximately 150 psig to less than or equal to 165 psig. This l additional pressure can provide additional time for test performance by making additional steam pressure available. Operating experience has !

shown that the Digital Electro-Hydraulic (DEH) Control System can better maintain stable steam pressure at 165 psig vice 150 psig. The ability i of the HPCI System to perform at the lowest required design pressure l (150 psig) has already been demonstrated. The proposed small increase in pressure at which this low pressure test is performed will not CNS 8 Revision 0 L _ -__ - - _______-_-____ _- . _ _ . - _ _ _ _

1 l

DISCUSSION OF CHANGES j ITS: 3.5.1 - ECCS-OPERATING l i

TECHNICAL CHANGES - LESS RESTRIC11VE

! L.8 (continued) significantly delay or affect the validity of the test. This change I also effectively extends the initial entry into the applicable condition for performing the surveillance. However, this is considered to be acceptable since the most common outcome of the performance of a surveillance is the successful demonstration that the acceptance criteria are satisfied. The change also ensures that performance of the surveillance can be delayed until plant conditions exist where performance of the surveillance is unlikely to result in a pressure '

transient.

L.9 Proposed LC0 3.5.1 ACTION D establishes Required Actions and Completion Times for the situation when the HPCI System and one low pressure ECCS h ;

(CS or LPCI) subsystem are inoperable. The proposed Specification is l less restrictive than existing LC0 3.5.C.2, which allows continued

, operation if HPCI is inoperable only if the ADS subsystem, the RCIC l System, both LPCI subsystems and both core spray subsystems are Operable. The accident analysis presented in NEDC-32687P, Revision 1,

" Cooper Nuclear Station SAFER /GESTR-LOCA Loss-of-Coolant Accident 1 Analysis," March 1997; approved in J.R. Hall (NRC) to G.R. Horn (NPPD), M\ l

" Approval of SAFER /GESTR-LOCA Analysis for Cooper Nuclear Station (TAC l No. M98293)," September 23, 1997, indicates that the plant is protected !

by the ADS System and the remaining ECCS subsystems when the HPCI System and one low pressure ECCS subsystem are inoperable. However, with both the HPCI System and one low pressure ECCS subsystem inoperable, another hj single failure may place the plant in a condition where adequate core l cooling may not be available during an accident. Therefore, an I allowable outage time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months has been assigned to either restore the inoperable HPCI System or the low pressure ECCS subsystem. For combinations of inoperable ECCS not bounded by the safety analysis, A ITS 3.5.1 Required Action H.1 is added to direct entry into LC0 3.0.3 lMA

, since this condition results in operation outside of the CNS design

! basis.

L.10 Not used. l L.ll The pressure at which ADS is required to be Operable is proposed to be increased to > 150 psig in CTS 4.5.E.1 to provide consistency with the Operability requirements for HPCI. Small break loss of coolant accidents (i.e., between 113 and 150 psig) are bounded by analyses performed at higher pressures. The ADS is required to operate to lower the pressure sufficiently so that the LPCI and CS Systems can provide makeup to mitigate such accidents. Since these systems can begin to ,

inject water into the reactor pressure vessel at pressures well above !

150 psig (217 psig for LPCI and 390 psig for CS), there is no safety significance in ADS not being Operable between 113 &nd 150 psig.

l L.12 CTS 3.5.E.2 allows continued operation for a maximum of 7 days after an ADS valve is determined to be inoperable. Proposed LC0 3.5.1 ACTION E M l

CNS 9 Revision 0 l

l. . _ _ _ _ _____________________-_____-____-_w

DISCUSSION OF CHANGES ITS: 3.5.1 - ECCS-0PERATING TECHNICAL CHANGES - LESS RESTRICTIVE L.12 (continued) allows continued operation for a maximum of 14 days under the same conditions. The 14 day Completion Time for restoring the ADS valve is contingent upon the Operability of the HPCI System. The 14 day Completion Time is based on a reliability study that evaluated the impact on ECCS availability (Memorandum from R.L. Baer (NRC) to V.

Stello, JR. (NRC), " Recommended Interim Revisions to LCOs for ECCS Components," Decernber 1,1975) . Factors contributing to the acceptability of allowing continued operation for 14 days with an ADS valve inoperable include the continued availability of HPCI and the accident analysis for CNS indicating that the plant remains protected with only 5 ADS valves Operable. For combinations of inoperable ECCS not bounded by the safety analysis, ITS 3.5.1 Required Action H.1 is /A provided to direct entry into LCO 3.0.3 since this condition results in W operation outside of the CNS design and licensing basis.

L.13 This change proposes to modify the periodic surveillance in CTS 4.6.D.5 and the conditional surveillance in CTS 3.5.E.3. The Note to proposed ITS GR 3.5.1.11 would require performance of the ADS manual operation test within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving adequate steam pressure and flow. /S\

The proposed Bases B 3.5.1 for SR 3.5.1.11 defines adequate steam pressure as a 500 psig, instead of the current 2 100 psig of CTS 4.6.D.5 and within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of achieving 113 psig in CTS 3.5.E.3. Adequate steam flow is defined in the proposed Bases as turbine bypass valves at least 30% open or total steam flow 210" lb/hr. This allows for A I sufficient conditions to exist and allows the plant to stabilize within these conditions prior to performing the Surveillance. The valve manufacturer's recommended test pressure is a 500 psig. This recommendation comes after the recently concluded mid-cycle-18 outage at CNS, during which all of the pilot valves for the ADS valves were replaced, and the old valves were examined by the manufacturer. The manufacturer believes that testing the valves at steam pressures less than 500 psig may have contributed to the degraded condition of the pilot valves. The Note to SR 3.5.1.11 allows the valve testing to not .

be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving adequate steam pressure and J fl ow. This time is sufficient to achieve stable conditions and allow performance of the Surveillance. The time to achieve proper conditions for and to perform testing and operations that must occur at startup justifies the additional time for performing the ADS manual actuation test. The time to achieve proper conditions for and to perform testing and operations that must occur at startup justifies the additional time g

for performing the ADS manual actuation test. The estimated time to proceed from 113 psig to a 500 psig is approximately 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This requires the testing to be completed in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Doing this along with other plant startup activities also in progress is not recommended. The proposed Note will provide sufficient time to complete the testing of all six ADS valves in a controlled, expeditious manner. The added time is acceptable because of the low probability of an accident requiring ADS. Since the normal outcome of the performance of this Surveillance is that the ADS valves are verified Operable, this change is considered acceptable.

CNS 10 Revision 0

DISCUSSION OF CHANGES ITS: 3.5.1 - ECCS-0PERATING IECHNICAL CHANGES - LESS RESTRICTIVE L.14 Not used. g L.15 CTS 3.5.A.5 provides an allowed outage time of 7 days for an inoperable LPCI subsystem provided certain conditions are satisfied. One of these conditions is that the Residual Heat Removal Service Water (RHRSW) subsystem associated with the Operable LPCI subsystem must be Operable.

This condition is not included in ITS 3.5.1. CTS 3.5.A.5 and ITS 3.5.1 provide requirements for the CNS Emergency Core Cooling Systems (ECCS) i and include requirements for LPCI subsystems to be Operable. The LPCI mode of the RHR System is included as-part of the CNS ECCS. The RHRSW System does not support the Operability of the LPCI subsystems for ECCS.

As a result, the inoperability of the RHRSW subsystems does not impact l the Operability of the remaining LPCI subsystem when one LPCI subsystem I

is inoperable. Therefore, the associated requirement in CTS 3/4.5.A.5

.for the Operability verification of the RHRSW subsystem associated with the Operable LPCI subsystem is unnecessary for assuring LPCI subsystem Operability and is deleted.

L.16 Not used.

L.17 This proposed change deletes most of the requirements to periodically verify the Operability of other systems, subsystems, or components when an ECCS component, subsystem, or system is inoperable (CTS 4.5. A.2; 4.5.A.4; 4.5.A.5; 4.5.C.2, except RCIC immediately; and 4.5.E.2). This verification is an implicit p&rt of using Technical Specifications and determining the appropriate Conditions to enter and Actions to take in l the event of inoperability of Technical Specification equipment. In ,

addition, plant and equipment status is continuously monitored by control room personnel. The results of this monitoring process are documented in records / logs maintained by control room personnel. The continuous monitoring process includes re-evaluating the status of compliance with Technical Specification requirements when Technical Specification equipment becomes inoperable using the control room records / logs as aids. Therefore, the explicit requirements to periodically verify the Operability of other systems, subsystems, or components when an ECCS component, subsystem, or system is inoperable are considered to be unnecessary for ensuring compliance with the l applicable Technical Specification actions. j L.18 Not used.

1 I

b CNS 11 Revision 0 4

DISCUSSION OF CHANGES ITS: 3.5.1 - ECCS-0PERATING 1ECHNICAL CHANGES - LESS RESTRICTIVE L.18 (continued)

Not used.

b L.19 The proposed change will modify CTS 4.5.C.2 to verify RCIC Operability within I hour when the HPCI System in inoperable. CTS 4.5.C.2 now g

requires immediately verifying the RCIC System to be OPERABLE. Proposed ACTION C.1 of LC0 3.5.1 allows I hour to verify RCIC Operability by administrative means. The present CTS verification is an implicit part lb of using Technical Specifications and determining the appropriate Conditions to enter and Actions to take due to inoperability of Technical Specification equipment. Control room personnel continuously monitor plant and equipment status. They maintain records / logs that M

document the results of this monitoring process. This continuous monitoring process, using the control room records / logs as aids, includes re-evaluating the status of compliance with Technical CNS 12 Revision 0

DISCUSSION OF CHANGES ITS: 3.5.1 - ECCS-0PERATING TECHNICAL CHANGES - tESS RESTRICTIVE L.19 (continued)

Specification requirements when Technical Specification equipment becomes inoperable. The hour allowed to verify RCIC Operability provides a period of time to correct the problem commensurate with the importance of maintaining HPCI OPERABLE during MODES 1, 2, and 3, with reactor steam dome pressure > 150 psig. Initiation of an analyzed event b

does not assume a completion time to verify RCIC Operability, and the consequences of an event during the proposed I hour Completion Time are the same as those during the current completion time of "immediately".

RELOCATED SPECIFICATIONS None l

l CNS 13 Revision 0

l:

l ECCS-Operating

{

. 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING

{ 3.5.1 (RCIC) SYSTEM ECCS-Operating i

i LCO 3.5.1 Each ECCS injection / spray subsystem and the Automatic Depressurization System (ADS) function of ((spfen]l safety /

relief valves shall be OPERABLE. I h Gix APPLICABILITY: MODE 1 MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with t reactorsteamdomepressuresgl5a5PSis- I ACTIONS b

CONDITION REQUIRED. ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days '

injection /rpray ECCS injection / spray subsystem inoperable. subsystem to OPERABLE status.

~

\

j B. Required Action and S.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Comp'letion

( Time of Condition A E I

not met. .

B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C; HPCI System *

,i Verify by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable, administrative means 4

RCIC System is OPERABLE.

E C.2 Restore HPCI System 14 days to OPERABLE status, d

(continued)

BWR/4 STS ' 3.5-1 Rev 1, 04/07/95 l

l

(-

l

ECCS-Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. HPCI System inoperable.

lD.1 Restore HPCI System to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months b m a A One low pressure ECCS D.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months injection / spray ECCS injection / spray l .. subsystem is subsystem to OPERABLE l

inoperable. status.

E. One ADS valve inoperable.

E.1 Restore ADS valve to OPERABLE status.

14 days b F. One ADS valve 'f .1 Restore ADS valve to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months g 1 inoperable. OPERABLE status. 4 l

l AHQ E One low pressure ECCS F.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months injection / spray ECCS injection / spray &

subsystem inoperable, subsystem to OPERABLE status.

'G. woormore'ADSvalves] G.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months jnoperable. J (

l AND G.2 Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months rRequiredActionand) dome pressure to associated Completion' 5$150gpsig.

Time of Condition C ) T}

L,E,erF,notmet.)

D L'.J (continued) !

h BWR/4 STS ' 3.5-2 Rev 1, 04/07/95 4

__ .________._-___i_______________..________.___.___ __ _ __. _ _ _ _ _ . _ . _ . - _ _ _ _ _____.__.__.______a

ECCS-Operating 3.5.1 !

ACTIONS (continued) l CONDITION REQUIRED ACTION COMPLETION TIME !

H. Two or more low H.I pressure ECCS Enter LC0 3.0.3. Immediately injection / spray subsystems inoperable.

HPCI System and one or more ADS valves inoperable.

4 f

i 1

l BWR/4 STS 3.5-3 Rev 1, 04/07/95 l

l L______-__--_ . _ _ _ _ _ _ _ _

JUSTIFICATION FOR DEVIATION FROM NUREG 1433 ITS: 3.5.1 - ECCS-0PERATING

1. The brackets have been removed and the proper plant specific value/ nomenclature has been provided.

2. Not used.

3. Change made for consistency with the Writer's Guide.

4. The SRs ' performing verification that LPCI inverter output voltage is appropriate is not required due to the plant specific design of CNS.

Subsequent SRs have been renumbered.

5. The CNS design does not include recirculation pump bypass valves.

Additionally, CNS is analyzed and licensed for single loop operation. Therefore, SR 3.5.1.4 of NUREG-1433 is revised accordingly.

O 6 '. The ECCS pump testing requirements are revised to reflect _ the CNS specific design and analysis or current licensing basis. The subsequent Note has been renumbered.

d

7. > The ADS valves at CNS have a single valve solenoid for each valve, therefore this Surveillance Frequency is not applicable and may be deleted.

8. Not used.

b l

1 l

l l

L l

CNS 1 Revision 0

-_-__=_-___-___-_________________________-_____-___________________-__________-__-____-____________-_____________-___________________

JUSTIFICATION FOR DEVIATION FROM NUREG 1433 ITS: 3.5.1 - ECCS-OPERATING

8. (continued)

Not used.

b 1

l j i

l i

l

,i i

l l

l CNS 2 Revision 0 l~

l

1 l

ECCS-0 pirating i 8 3.5.1 I(

BASES APPLICABILITY is s 150 psig, ADS and HPCI are not required to be OPERABLE (continued) because the low pressure ECCS subsystems can provide sufficient flow below this pressure. ECCS requirements for MODES 4 and 5 are specified in LC0 3.5.2, "ECCS-Shutdown."

l ACTIONS L.1 If any one low pressure ECCS injection / spray subsystem is

,g y ff.g' inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the

& a c~, ,,,,/o ta s remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is js o v r/e d "." reduced, because a single failure in one of the remaining

. OPERABLE subsystems, concurrent with a LOCA, may result in the ECCS not beina able to perform its intended safety rl function. The 7 day Com letion Time 1ssnaseeros a

- L- al{ ability study (Ref. that evaluated the impact on ECCS availability assu'aing various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment the consequences of a LOCA as a function needed of allowed toumitie ate /imes [p.e., agrietton Times].

b Co"tehon B.1 and B.2

- (- If the inoperable low pressure ECCS subsystem cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4

. within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are /A reasonable, based on operating experience, to reach the 'E required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

C.1 and C.2 If the HPCI System is inoperable and the RCIC System is verified to be OPERABLE, the HPCI System must be restored to OPERABLE status within 14 days. In this Condition, adequate core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection / spray subsystems in (continued)

BWR/4 STS B 3.5-6 Rev 1, 04/07/95 1

k I

INSERT 1 Not used.

b I

i Insert Page B 3.5-6 L_______________._______.___________ . _ - _ . - - _ _ . - . - - - - - - - - - - - - - - - -

ECCS-Operating 8 3.5.1 BASES ACTIONS C.1 and C.2 (continued) h conjunction with ADS. Also, the RCIC System will automatically provide makeup water at most reactor operating pressures. Verification of RCIC OPERABILITY within I hour is therefore required when HPCI is inoperable. This may be performed as an administrative check by examining logs or d

_ other information to determine if RCIC is out of service for maintenance or other reasons. .It does not mean to perfom the Surveillance needed to demonstrate the OPERABILITY of the RCIC System. If the OPERABILITY of the RCIC System cannot be verified, however, Condition'G must be immediately M

entered. If a single active component fails concurrent with a design basis LOCA, there is a potential, depending on the specific failure, that the minimum required ECCS equipment _ _

will not be available. A I4 day Complet n Time isitase<ron) a reliability study cited in Reference and has been found c us < s te-/ <dM to be acceptable through. operating experience.

d,e ver o r </o fEr ll f *nole A in D 1 and D.2 -

If any one low pressure ECCS injection / spray subsystem is inoperable in addition to an inoperable HPCI System, the 4 inoperable low pressure ECCS injection / spray subsystem or the HPCI System must be restored to OPERABLE status within ,

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this Condition, adequate core cooling is ensured by the OPERABILITY of the ADS and the remaining low

( pressure ECCS subsystems. However, the overall ECCS reliability is significantly reduced because a single failure in one of the remaining OPERABLE subsystems concurrent with a design basis LOCA may result in the ECCS k not being able to perform its intended safety function. l Since both a high pressure system (HPCI) and a low pressure l In subsystem are inoperable, a more restrictive Completion Time ;

CJ of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is required to restore either the HPCI System or '

Co a e j ,~ f. "' y- the low pressure ECCS injection / spray subsystem to OPERABLE status. This completion Time i?1 base <r o3 a reliability j g/. c. recem,,, e [o b m, / study cited in Reference nd has been found to be acceptable through operat experience, b

N Six h h The LCO requires n ADS valves to be OPERABLE in order to provide the ADS func on. Reference ontains the results b (continued)

BWR/4 STS B 3.5-7 Rev I, 04/07/95 1

ECCS-Operating B 3.5.1 BASES ACTIONS L 1 (continued) f

( shows Oat 455mg 4 fa,Ln, g M ffpcf sy3kn j g

of an analysis that evaluat the effect of one ADS valve being out of service. his analyst operation of only ADS valves will pr the required depressurization.

D/ ive.

ver, overall reliability of the ADS is reduced, because g a single failure in the OPERABLE ADS valves could result in a reduction in depressurization capability. Therefore, c ae r he+f . , operation is only allowed for a limited time. The 14 day

zMe. ree w - M /*6**,'

completion me 10BasWU on1a reliability study cited in Referenc and has been found to be acceptable through

/rev e d p xperience.-

t M @ operatin F.1 and F.2 If any one low pressure ECCS injection / spray.s stem is inoperable in addition to one Onocerable7AITS va v adequate core cooling is ensured by the OPERABILITY of HPCI and the remaining low pressure ECCS injection / spray subsystem.

However, overall ECCS reliability is reduced because.a single active component failure concurrent with a design basis LOCA could result in the minimum required ECCS equipment not being available. Since both a high pressure system (ADS) and a low pressure subsystem are inoperable, a more restrictive Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is required to restore either the low pressure ECCS ribsystem or the ADS valve to OPERABLE status. This Complettpn Time is)pnl

-(~ --

ba reliability study cited in Referen dandhasbeenfound to be acceptable through operating exper ence.

h 11 G.1 and G.2 N

If any Required Action and associated Completion Time of g

Condition C, D, E, or F is not met, or if two or more ADS valves are inoperable, the plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reactor steam done pressure reduced to s 150 psig 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.

j- (continued)

BWR/4 STS- B 3.5-8 Rev 1, 04/07/95 i

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INSERT 2 Not used.

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l Insert Page B 3.5-8

ECCS-Operating B 3.5.1 BASES ACTIONS tid (continued)

When multiple ECCS subsystems are inoperable, as stated in g

Condition H, the plant is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.5.1.1 REf)UIREMENTS The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the HPCI System, CS System, and LPCI subsystems full of water ensures that the ECCS will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent a water hammer following an ECCS initiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points. The

' 31 day Frequency is based on the gradual nature of void buildup in the ECCS piping, the procedural controls governing system operation, and operating experience. '

SR 3.5.1.2

<T

, Verifying the correct alignment for manual, power operated, t

3- and automatic valves in the ECCS flow paths provides A

!\

(' Twrert/41 assurance th_at the proper flow paths will exist for ECCS M operation. M SR does not apply to valves that are locked, sealed, or otherwise secured in position since these l .. were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the

-proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. For the HPCI System, this SR also includes the steam flow path for the turbine and the flow controller position.

The 31 day frequency of this SR was derived from the Inservice Testing Program requirements for performing valve Ii (continued) 1.

l BWR/4 STS B 3.5-9 Rev 1, 04/07/95 i

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ML20236Q064

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