Text

Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements
	ML20248H528
Person / Time
Site:	River Bend
Issue date:	09/04/2020
From:	Gaston R; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RBG-48033
	Download: ML20248H528 (67)
	v • d • e

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing

10CFR 50.90 RBG-48033 September 4, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Application to Revise Technical Specifications to Adopt TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements" River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 In accordance with Title 10 of the Code of Federal Regulations (CFR) Part 50, Section 50.90, "Application for amendment of license, construction permit, or early site permit," Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to Renewed Facility Operating License, Appendix A, "Technical Specifications" (TS) for River Bend Station, Unit 1 (RBS).

These proposed changes adopt the U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) Traveler TSTF 582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements." The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

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

Approval of the proposed amendment is requested by January 31, 2021. Once approved, the amendment shall be implemented within 30 days.

There are no regulatory commitments made in this submittal.

RBG-48033 Page 2 of 2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), a copy of this application, with attachments, is being provided to the designated State Officials.

Should you have any questions or require additional information, please contact Ron Gaston, Director, Nuclear Licensing, at 601-368-5138.

I declare under penalty of perjury; the foregoing is true and correct. Executed on September 4, 2020.

Respectfully, Ron Gaston RWG/baj

Enclosure:

Description and Assessment Attachments: 1.

Proposed Technical Specification Changes (Mark-Up)

2.

Revised Technical Specification Pages

3.

Proposed Technical Specification Bases Changes (Mark-Up) - For Information Only cc:

NRC Regional Administrator - Region IV NRC Project Manager - River Bend Station NRC Senior Resident Inspector - River Bend Station Louisiana Department of Environmental Quality Public Utility Commission of Texas

Enclosure RBG-48033 Description and Assessment (6 Pages)

1.0 DESCRIPTION

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis 3.2 Conclusion 4.0 ENVIRONMENTAL EVALUATION

RBG-48033 Enclosure Page 1 of 6 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

Entergy Operations, Inc (Entergy) requests adoption of Technical Specification Task Force (TSTF) Traveler TSTF 582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC)

Enhancements." The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation Entergy has reviewed the NRC safety evaluation (SE) for TSTF-582 provided to the Technical Specifications Task Force in a letter dated August 13, 2020 (ADAMS Accession No. ML20223A000). This included a review of the NRC staffs evaluation, as well as the information provided in TSTF-582. Entergy has concluded that the justifications presented in TSTF-582 and the safety evaluation prepared by the NRC staff are applicable to River Bend Station (RBS) and justify this amendment for the incorporation of the changes to the RBS TS.

Entergy verifies that the required ECCS injection/spray subsystem can be aligned and the pump started using relatively simple evolutions involving the manipulation of a small number of components. These actions can be performed in a short time (less than the minimum Drain Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) from the control room using plant procedures.

2.2 Optional Changes and Variations 2.2.1 Entergy is proposing the following variations from the TS changes described in TSTF-582, based on the existing RBS TS. These variations do not affect the applicability of TSTF-582 to the proposed license amendment.

The RBS TS includes Limiting Condition for Operation (LCO) 3.3.6.1 Required Actions J.3.1 and J.3.2 that are not included in TSTF-582. With the TSTF-582 deletion of LCO 3.3.6.1 Required Action J.2, Required Actions J.3.1 and J.3.2 are no longer applicable. Required Actions J.3.1 and J.3.2 should be deleted with the deletion of Required Action J.2. This plant specific variation does not impact the applicability of TSTF-582 to the RBS TS.

The RBS TS does not contain LCO 3.5.2 Required Actions C.3 and D.4, as shown in TSTF-582. Required Actions C.3 and D.4 listed in NUREG-1434, "Standard Technical Specifications, General Electric BWR/6 Plants (ISTS) for LCO 3.5.2 are not applicable to RBS since the Standby Gas Treatment Subsystem is external to the primary containment and is not required for the operability of primary containment.

The changes being made to LCO 3.5.2 in TSTF-582 are administrative in nature and do not impact the applicability of TSTF-582 to the RBS TS.

SR 3.5.2.8 from the RBS TS states: "Verify the required LPCI or LPCS subsystem actuates on a manual initiation signal, or the required HPCS subsystem can be manually operated." This variation was approved in RBS TS Amendment 193

RBG-48033 Enclosure Page 2 of 6 (ADAMS Accession No. ML18267A341) to ensure that the HPCS manual start capability, including the HPCS Level 8 isolation override feature, was tested. TSTF-582 updates SR 3.5.2.8 to state: "Verify the required ECCS injection/spray subsystem can be manually operated." Due to this change, the wording from TSTF-582 is now consistent with the requirements for RBS. This plant specific variation does not impact the applicability of TSTF-582 to the RBS TS.

There are various site-specific wording differences between the RBS TS Bases and ISTS Bases. The changes that are being made to the RBS TS Basis are consistent with those being made in TSTF-582, as well as the variations discussed in this LAR.

2.2.2 Entergy is proposing the following variations from the TS changes described in TSTF-582, based on subsequent review of the approved Traveler by the TSTF. These additional variations provide consistency within the TS after incorporating the TSTF-582 changes to SR 3.8.2.1 TSTF-582, states:

"The ECCS injection/spray subsystem required to be operable by LCO 3.5.2 must be capable of being manually started as defense in depth against an unexpected draining event. The changes in TSTF-542 did not assume automatic actuation of the ECCS subsystem. TS 3.5.2, Required Action D.1 requires an additional method of water injection and that the required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power. However, LCO 3.5.2 does not assume that the onsite electrical power source will start automatically on an ECCS or loss of power signal.

LCO 3.8.2, 'AC Sources - Shutdown,' requires one offsite circuit and one diesel generator to be operable in Modes 4 and 5. SR 3.8.2.1 lists the TS 3.8.1, 'AC Sources - Operating,' SRs that are applicable in Modes 4 and 5. In an oversight in TSTF-542, the TS 3.8.1 SRs that test automatic start and loading of a diesel generator on an ECCS or loss of offsite power signal were not excluded from SR 3.8.2.1."

TSTF-582 revises TS 3.8.2, SR 3.8.2.1, to exclude SRs that verify the ability of the diesel generators to automatically start and load on an ECCS initiation signal or loss of offsite power signal.

The NRC SE for TSTF-582, Section 3.6, "Alternating Current Sources - Shutdown, STS 3.8.2," states:

"STS 3.5.2, 'Reactor Pressure Vessel Water Inventory Control (RPV WIC),' does not require automatic ECCS initiation to mitigate a draining event in Modes 4 and 5, and the ECCS initiation signal related to the automatic ECCS initiation is removed from the STS. Because the automatic ECCS initiation and related ECCS initial signal in Modes 4 and 5 are eliminated, the automatic start of the DG on an ECCS initiation signal is not required in Modes 4 and 5. [T]he NRC staff finds that STS 3.5.2 provides enough time from the onset of the [loss of offsite power] LOOP event for the operator to manually start the DG required to supply power to the water injection equipment to mitigate the draining event in

RBG-48033 Enclosure Page 3 of 6 Modes 4 and 5. In addition, STS 3.5.2 does not require the automatic initiation of the ECCS injection/spray subsystem or the additional method of water injection.

Therefore, since STS 3.5.2 allows enough time to manually start the DG and the equipment for water injection, the NRC staff finds that the automatic start and loading of the DG are not necessary on a LOOP signal or LOOP concurrent with an ECCS initiation signal to mitigate a draining event in Modes 4 and 5.

Furthermore, the NRC staff notes that other events postulated in Modes 4 and 5 (e.g., FHA, waste gas tank rupture) and during movement of [recently] irradiated fuel assemblies in the [primary and secondary containment] do not assume a LOOP event or an automatic ECCS initiation."

TSTF-582 did not include all of the TS changes needed to reflect that TS 3.8.2 should not require automatic start and loading of a diesel generator (DG) in 10 seconds for DG 1A and DG 1B and 13 seconds for DG 1C on an ECCS initiation signal or a loss of offsite power signal.

TS 3.3.8.1, "Loss of Power (LOP) Instrumentation," is applicable in Modes 1, 2, and 3, and when the associated DG is required to be operable by TS 3.8.2.

TSTF 582 revised TS 3.8.2 to no longer require automatic start and loading of a diesel generator on a loss of offsite power signal. Consequently, the LOP instrumentation that generates the loss of offsite power signal should not be required to be operable when the diesel generator is required to be operable by TS 3.8.2. The Applicability of LCO 3.3.8.1 is revised to not include the specified condition "When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, 'AC Sources - Shutdown'."

As an editorial improvement, SR 3.8.2.1 is revised to list the TS 3.8.1 SRs that are applicable instead of the listing the TS 3.8.1 SRs that are not applicable.

This is consistent with the current RBS TS SR 3.8.2.1. The SR 3.8.2.1 Bases are not affected and explain why the excluded TS 3.8.1 SRs are not applicable to TS 3.8.2.

TS SR 3.8.1.7 and SR 3.8.1.15 require that the DG starts from standby or hot conditions, respectively, and achieve required voltage and frequency 10 seconds for DG 1A and DG 1B and 13 seconds for DG 1C. The start requirement supports the assumptions in the design basis LOCA analysis. This capability is not required during a manual diesel generator start to respond to a draining event, which has a minimum Drain Time of one hour. Therefore, SR 3.8.1.7 and SR 3.8.1.15 are excluded from the list of TS 3.8.1 SRs that are applicable under SR 3.8.2.1.

TS SR 3.8.1.18 states, "Verify sequence time is within +/- 10% of design for each load sequencer timer." TSTF-582 retained SR 3.8.1.18 as a test that must be met but not performed. The load sequencers are only used for the automatic start and loading of the diesel generator and are not used during a manual diesel generator start. Therefore, SR 3.8.1.18 is excluded from the list of TS 3.8.1 SRs that are applicable under SR 3.8.2.1.

RBG-48033 Enclosure Page 4 of 6 The TS 3.8.2 LCO Bases were not updated by TSTF-542 or TSTF-582 to reflect that automatic start and loading of a diesel generator is not required. The LCO 3.8.2 and SR 3.8.2.1 Bases are revised to reflect the TS requirements.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis River Bend Station (RBS) requests adoption of TSTF 582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements. The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." TSTF-582 includes the following changes to the technical specifications (TS):

1. The TS are revised to eliminate the requirement for a manual Emergency Core Cooling System (ECCS) initiation signal to start the required ECCS injection/spray subsystem, and to instead rely on manual valve alignment and pump start.

2. The Drain Time definition is revised to move the examples of common mode failure mechanisms to the Bases and seismic events are no longer considered a common mode failure mechanism.

3. The Drain Time definition exception from considering the Drain Time for penetration flow paths isolated with manual or automatic valves that are that are "locked, sealed, or otherwise secured" is revised to apply the exception for manual or automatic valves that are "closed and administratively controlled."

4. The TS are revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.

5. A Surveillance Requirement (SR) that requires operating the required ECCS injection/spray subsystem for at least 10 minutes through the recirculation line, is modified to permit crediting normal operation of the system to satisfy the SR and to permit operation through the test return line.

6. TS 3.8.2, "AC Sources - Shutdown," SR 3.8.2.1, is revised to not require SRs that test the ability of the automatic diesel generator to start in Modes 4 and 5. Automatic ECCS initiation in Modes 4 and 5 was eliminated in TSTF-542. This was an oversight in TSTF-542.

7. TS 3.3.6.1, "Primary Containment Isolation Instrumentation," Required Action J.2 has been deleted. These actions are no longer applicable after adoption of TSTF-542. This was an accidental omission in TSTF-542. This change is made for clarity and has no effect on the application of the TS.

8. TS 3.3.6.1, "Primary Containment Isolation Instrumentation," Required Actions J.3.1 and J.3.2 have been deleted. These RBS-specific actions are no longer applicable after adoption of TSTF-542.

RBG-48033 Enclosure Page 5 of 6

9. The TS are revised to use wording and to define acronyms in a manner consistent with the remainder of the TS. These changes are made for consistency and have no effect on the application of the TS.

Entergy has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." Draining of RPV water inventory in Mode 4 (i.e.,

cold shutdown) and Mode 5 (i.e., refueling) is not an accident previously evaluated and, therefore, revising the existing TS controls to prevent or mitigate such an event has no effect on any accident previously evaluated. RPV water inventory control in Mode 4 or Mode 5 is not an initiator of any accident previously evaluated. The existing and revised TS controls are not mitigating actions assumed in any accident previously evaluated. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." The event of concern under the current requirements and the proposed change is an unexpected draining event. The TS have contained requirements related to an unexpected draining event during shutdown for over 40 years and this event does not appear as an analyzed event in the Updated Final Safety Analysis Report (UFSAR) for any plant or in the NRC's Standard Review Plan (NUREG-0800). Therefore, an unexpected draining event is not a new or different kind of accident not considered in the design and licensing bases that would have been considered a design basis accident in the UFSAR had it been previously identified.

None of the equipment affected by the proposed change has a design function described in the UFSAR to mitigate an unexpected draining event in Modes 4 or 5, although the equipment may be used for that purpose. Therefore, the proposed amendment will not change the design function of the affected equipment. The proposed change will effect the operation of certain equipment, such as the manual initiation function and related instrumentation to permit initiation of the required ECCS injection/spray subsystem, and the control of valves credited for preventing a draining event. However, these changes provide adequate protection to prevent or mitigate an unexpected draining event and do not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.

RBG-48033 Enclosure Page 6 of 6 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

The safety basis for the RPV WIC requirements is to protect Safety Limit 2.1.1.3. The proposed change does not affect any specific values that define a safety margin as established in the licensing basis. The proposed change does not affect a design basis or safety limit, or any controlling value for a parameter established in the UFSAR or the license.

Therefore, the proposed change does not significantly reduce the margin of safety.

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

Based on the above, Entergy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

RBG-48033 Proposed Technical Specification Changes (Mark-Up)

(15 Pages)

Definitions 1.1 RIVER BEND 1.0-2a Amendment No. 193 1.1 Definitions (continued)

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

a.

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

b.

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

1.

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

2.

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

3.

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

c.

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

RPV Water Inventory Control Instrumentation 3.3.5.2 RIVER BEND 3.3-43a Amendment No. 193 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels inoperable.

A.1 Enter the Condition referenced in Table 3.3.5.2-1 for the channel.

Immediately B. As required by Required Action A.1 and referenced in Table 3.3.5.2-1.

B.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND B.2 Calculate DRAIN TIME.

Immediately Immediately C. As required by Required Action A.1 and referenced in Table 3.3.5.2-1.

C.1 Place channel in trip.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (continued)

A.1 Initiate action to place channel in trip.

OR Immediately A.2.1 A.2.2 A. One or more channels inoperable.

Initiate action to calculate

RPV Water Inventory Control Instrumentation 3.3.5.2 RIVER BEND 3.3-43b Amendment No. 193 ACTIONS (continued)

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

D.1 Declare HPCS system inoperable OR D.2 Align the HPCS pump suction to the suppression pool.

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

E.1 Restore channel to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months F. Required Action and associated Completion Time of Condition C, D, or E not met.

F.1 Declare associated ECCS injection/spray subsystem inoperable.

Immediately Move text up from Page 3.3-43c

RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

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

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

SURVEILLANCE SR 3.3.5.2.1 Perform CHANNEL CHECK.

SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST.

SR 3.3.5.2.3 Perform LOGIC SYSTEM FUNCTIONAL TEST.

RIVER BEND 3.3-43c FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 4W These SRs apply to each Function in Move text up from Pages 3.3-43d and 3.3-43e

RPV Water Inventory Control Instrumentation 3.3.5.2 RIVER BEND 3.3-43d Amendment No. 193 Table 3.3.5.2-1 (page 1 of 2)

RPV Water Inventory Control Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 1.

Low Pressure Coolant Injection A (LPCI) and Low Pressure Core Spray (LPCS) Subsytems a.

Reactor Vessel Pressure Low (Injection Permissive) 4, 5 4(a)

C SR 3.3.5.2.1 SR 3.3.5.2.2 502 psig b.

LPCS Pump Discharge Flow Low (Bypass) 4, 5 1(a)

E SR 3.3.5.2.1 SR 3.3.5.2.2

> 750 gpm c.

LPCI Pump A Discharge Flow Low (Bypass) 4, 5 1(a)

E SR 3.3.5.2.1 SR 3.3.5.2.2

> 900 gpm d.

Manual Initiation 4, 5 1 per system(a)

E SR 3.3.5.2.3 NA 2.

LPCI B and LPCI C Subsytems a.

Reactor Vessel Pressure Low (Injection Permissive) 4, 5 4(a)

C SR 3.3.5.2.1 SR 3.3.5.2.2 502 psig b.

LPCI Pump B and LPCI Pump C Discharge Flow Low (Bypass) 4, 5 1 per pump(a)

E SR 3.3.5.2.1 SR 3.3.5.2.2

> 900 gpm c.

Manual Initiation 4, 5 1 per system(a)

E SR 3.3.5.2.3 NA (continued)

(a)

Associated with an ECCS subsystem re PV) Water Inventory Control.

Page 3.3-43d is being deleted and information is being moved to 3.3-43c 1

RPV Water Inventory Control Instrumentation 3.3.5.2 RIVER BEND 3.3-43e Amendment No. 193 Table 3.3.5.2-1 (page 2 of 2)

RPV Water Inventory Control Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 3.

High Pressure Core Spray (HPCS) System a.

Condensate Storage Tank Level Low 4(b),5(b) 2(a)

D SR 3.3.5.2.1 SR 3.3.5.2.2

> -4.5 inches b.

HPCS Pump Discharge Pressure High (Bypass) 4, 5 1(a)

E SR 3.3.5.2.1 SR 3.3.5.2.2

> 275 psig c.

HPCS System Flow Rate Low (Bypass) 4, 5 1(a)

E SR 3.3.5.2.1 SR 3.3.5.2.2

> 710 gpm 4.

RHR System Isolation a.

Reactor Vessel Water Level Low (Level 3)

(c) 2 in one trip system B

SR 3.3.5.2.1 SR 3.3.5.2.2

> 8.7 inches 5.

Reactor water Cleanup (RWCU) System Isolation a.

Reactor Water Level Low, Low (Level 2)

(c) 2 in one trip system B

SR 3.3.5.2.1 SR 3.3.5.2.2

> -47 inches (a)

Assoc ure Vessel (RPV) Water (b)

When HPCS is OP o

aligned to the condensate storage tank.

(c)

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

a 1

2 a

a Page 3.3-43e is being deleted and information is being moved to 3.3-43c 1 of 1

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 RIVER BEND 3.3-50 Amendment No. 81 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H.

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

OR Required Action and associated Completion Time of Condition F or G not met.

H.1 Be in MODE 3.

AND H.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours I.

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

I.1 Declare associated standby liquid control subsystem inoperable.

OR I.2 Isolate the Reactor Water Cleanup System.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour J.

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

J.1 Initiate action to restore channel to OPERABLE status.

OR J.2 Initiate action to isolate the Residual Heat Removal (RHR)

Shutdown Cooling System suction from the reactor vessel.

OR Immediately Immediately (continued)

(continued)

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 RIVER BEND 3.3-51 Amendment No. 81 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME J.

(continued)

J.3.1 Initiate action to restore primary containment to OPERABLE status.

AND J.3.2

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

Entry and exit is permissible under administrative control.

Initiate action to close one door in each primary containment air lock.

Immediately Immediately K.

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

K.1 Isolate the affected penetration flow path(s).

OR K.2.1 Be in MODE 3.

AND K.2.2 Be in MODE 4.

Immediately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

LOP Instrumentation 3.3.8.1 RIVER BEND 3.3-72 Amendment No. 81 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, When the associated diesel generator (DG) is required to be OPERABLE by LCO 3.8.2, "AC Sources Shutdown."

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Place channel in trip.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months B.

Required Action and associated Completion Time not met.

B.1 Declare associated DG inoperable.

Immediately

ECCS Operating 3.5.1 RIVER BEND 3.5-1 Amendment No. 81, 156, 193 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS -Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of seven safety/relief valves shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure 100 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to HPCS.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One low pressure ECCS injection/spray subsystem inoperable.

A.1 Restore low pressure ECCS injection/spray subsystem to OPERABLE status.

7 days B.

High Pressure Core Spray (HPCS) System inoperable.

B.1 Verify by administrative means RCIC System is OPERABLE when RCIC is required to be OPERABLE.

AND B.2 Restore HPCS System to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 14 days (continued)

High Pressure Core Spray (HPCS)

RPV Water Inventory Control 3.5.2 RIVER BEND 3.5-6 Amendment No. 81, 193 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be > 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND One ECCS injection/spray subsystem shall be OPERABLE.

APPLICABILITY:

MODE 4 and 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Required ECCS injection/spray subsystem inoperable.

A.1 Restore required ECCS injection/spray subsystem to OPERABLE status.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months B.

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

B.1 Initiate action to establish a method of water injection capable of operating without offsite electrical power.

Immediately C. DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and

> 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months C.1 Verify primary containment boundary is capable of being established in less than the DRAIN TIME.

AND C.2 Verify each primary containment penetration flow path is capable of being isolated within the DRAIN TIME.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 4 hours (continued)

No Changes - For Information Only

RPV Water Inventory Control 3.5.2 RIVER BEND 3.5-7 Amendment No. 81, 193 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

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

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

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

D.1 Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water hours.

AND D.2 Initiate action to establish primary containment boundary.

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

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

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

E.1 Initiate action to restore Immediately No Changes - For Information Only

RPV Water Inventory Control 3.5.2 RIVER BEND 3.5-8 Amendment No. 81, 188, 193, 196 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME is > 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure ECCS injection/spray subsystem, the suppression pool water level is 13 ft 3 inches.

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

a. Suppression pool water level is 13 ft 3 inches; or

b. Condensate storage tank water level is 11 ft 1 inch.

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

In accordance with the Surveillance Frequency Control Program SR 3.5.2.5

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

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

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

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

In accordance with the Surveillance Frequency Control Program (continued)

RPV Water Inventory Control 3.5.2 RIVER BEND 3.5-9 Amendment No. 81, 168, 193, 196 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.6 Operate the required ECCS injection/spray subsystem for > 10 minutes.

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

In accordance with the Surveillance Frequency Control Program SR 3.5.2.8

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

Vessel injection/spray may be excluded.

Verify the required LPCI or LPCS subsystem actuates on a manual initiation signal, or the required HPCS subsystem can be manually operated.

In accordance with the Surveillance Frequency Control Program ECCS injection/spray subsystem can be manually operated 5

6 7

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

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR

AC Sources Shutdown 3.8.2 RIVER BEND 3.8-20 Amendment No. 81, 121 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1

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

The following SRs are not required to be performed:

SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, SR 3.8.1.18, and SR 3.8.1.19.

For AC sources required to be OPERABLE, the following SRs are applicable:

SR 3.8.1.1 SR 3.8.1.7 SR 3.8.1.14 SR 3.8.1.2 SR 3.8.1.9 SR 3.8.1.15 SR 3.8.1.3 SR 3.8.1.10 SR 3.8.1.16 SR 3.8.1.4 SR 3.8.1.11 SR 3.8.1.18 SR 3.8.1.5 SR 3.8.1.12 SR 3.8.1.19 SR 3.8.1.6 SR 3.8.1.13 In accordance with applicable SRs

, SR 3.8.1.10, SR 3.8.1.14, and SR 3.8.1.16.

The following SRs are applicable for

RBG-48033 Revised Technical Specification Pages (11 Pages)

Definitions 1.1 RIVER BEND 1.0-2a Amendment No. 193, 1.1 Definitions (continued)

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

a.

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

b.

The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure, for all penetration flow paths below the TAF except:

1.

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

2.

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

3.

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

c.

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

ECCS Instrumentation 3.3.5.1 RIVER BEND 3.3-43a Amendment No. 193, 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels inoperable.

A.1 Initiate action to place channel in trip.

OR A.2.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND A.2.2 Initiate action to calculate DRAIN TIME.

Immediately Immediately Immediately

ECCS Instrumentation 3.3.5.1 RIVER BEND 3.3-43b Amendment No. 193, XXX, SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Table 3.3.5.2-1.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program

RPV Water Inventory Control Instrumentation 3.3.5.2 RIVER BEND 3.3-43c Amendment No. 193, Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation (a)

When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION ALLOWABLE VALUE

1.

RHR System Isolation

a.

Reactor Vessel Water Level - Low (Level 3)

(a) 2 in one trip system

> 8.7 inches

2.

Reactor water Cleanup (RWCU) System Isolation

a.

Reactor Water Level Low, Low (Level 2)

(a) 2 in one trip system

> -47 inches

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 RIVER BEND 3.3-50 Amendment No. 81, ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H.

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

OR Required Action and associated Completion Time of Condition F or G not met.

H.1 Be in MODE 3.

AND H.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours I.

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

I.1 Declare associated standby liquid control subsystem inoperable.

OR I.2 Isolate the Reactor Water Cleanup System.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour J.

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

J.1 Initiate action to restore channel to OPERABLE status.

Immediately (continued)

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 RIVER BEND 3.3-51 Amendment No. 81, ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME K.

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

K.1 Isolate the affected penetration flow path(s).

OR K.2.1 Be in MODE 3.

AND K.2.2 Be in MODE 4.

Immediately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

LOP Instrumentation 3.3.8.1 RIVER BEND 3.3-72 Amendment No. 81, 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3 ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Place channel in trip.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months B.

Required Action and associated Completion Time not met.

B.1 Declare associated DG inoperable.

Immediately

ECCS Operating 3.5.1 RIVER BEND 3.5-1 Amendment No. 81, 156, 193, 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS -Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of seven safety/relief valves shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure 100 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to High Pressure Core Spray (HPCS).

CONDITION REQUIRED ACTION COMPLETION TIME A.

One low pressure ECCS injection/spray subsystem inoperable.

A.1 Restore low pressure ECCS injection/spray subsystem to OPERABLE status.

7 days B.

HPCS System inoperable.

B.1 Verify by administrative means RCIC System is OPERABLE when RCIC is required to be OPERABLE.

AND B.2 Restore HPCS System to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 14 days (continued)

RPV Water Inventory Control 3.5.2 RIVER BEND 3.5-8 Amendment No. 81, 188, 193, 196, SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME is > 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure ECCS injection/spray subsystem, the suppression pool water level is 13 ft 3 inches.

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

a. Suppression pool water level is 13 ft 3 inches; or

b. Condensate storage tank water level is 11 ft 1 inch.

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

In accordance with the Surveillance Frequency Control Program (continued)

RPV Water Inventory Control 3.5.2 RIVER BEND 3.5-9 Amendment No. 81, 168, 193, 196, SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5

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

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray subsystem for > 10 minutes.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.7

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

Vessel injection/spray may be excluded.

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

In accordance with the Surveillance Frequency Control Program

AC SourcesShutdown 3.8.2 RIVER BEND 3.8-20 Amendment No. 81, 121, SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1

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

The following SRs are not required to be performed:

SR 3.8.1.3, SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.14, and SR 3.8.1.16.

The following SRs are applicable for AC sources required to be OPERABLE:

SR 3.8.1.1 SR 3.8.1.5 SR 3.8.1.14 SR 3.8.1.2 SR 3.8.1.6 SR 3.8.1.16 SR 3.8.1.3 SR 3.8.1.9 SR 3.8.1.4 SR 3.8.1.10 In accordance with applicable SRs

RBG-48033 Proposed Technical Specification Bases Changes (Mark-Up) - For Information Only (29 Pages)

PV Water Inventory Control Instrumentation B 3.3.5.2 RIVER BEND B 3.3-121a Revision No. 172 B 3.3 INSTRUMENTATION B 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSS) for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The actual settings for the automatic isolation channels are the same as those established for the same functions in MODES 1, 2, and 3 in LCO 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," or LCO 3.3.6.1, "Primary Containment Isolation instrumentation.".

With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses.

RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur. Under the definition of DRAIN TIME, some penetration flow paths may be excluded from the DRAIN TIME calculation if they will be isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation.

(continued)

PV Water Inventory Control Instrumentation B 3.3.5.2 RIVER BEND B 3.3-121b Revision No. 172 BASES BACKGROUND (continued)

The purpose of the RPV Water Inventory Control Instrumentation is to support the requirements of LCO 3.5.2, Reactor Pressure Vessel (RPV)

Water Inventory Control, and the definition of DRAIN TIME. There are functions that are required for manual initiation or operation of the ECCS injection/spray subsystem required to be OPERABLE by LCO 3.5.2 and other functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

The RPV Water Inventory Control Instrumentation supports operation of low pressure core spray (LPCS), low pressure coolant injection (LPCI),

and high pressure core spray (HPCS). The equipment involved with each of these systems is described in the Bases for LCO 3.5.2.

APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analysis.

RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulated in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is postulated in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety.

Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy.

The specific Applicable Safety Analysis, LCO, and Applicability discussions are listed below on a Function by Function basis.

(continued) considered

PV Water Inventory Control Instrumentation B 3.3.5.2 RIVER BEND B 3.3-121c Revision No. 172 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

Low Pressure Coolant Injection and Low Pressure Core Spray 1.a, 2.a, Reactor Vessel Pressure Low - (Injection Permissive)

Low reactor vessel pressure signals are used as permissives for the low pressure ECCS subsystems. This ensures that, prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems' maximum design pressure. While it is assured during Modes 4 and 5 that the reactor vessel pressure will be below the ECCS maximum design pressure, the Reactor Vessel Pressure - Low signals are assumed to be operable and capable of permitting initiation of the ECCS.

The Reactor Vessel Pressure-Low signals are initiated from four pressure transmitters that sense the reactor dome pressure. The four pressure transmitters each drive a master and two slave trip units (for a total of eight slave trip units).

The Allowable Value is low enough to prevent overpressuring the equipment in the low pressure ECCS.

Four channels of Reactor Vessel Pressure - Low Function per associated ECCS Division are only required to be OPERABLE in MODES 4 and 5 when ECCS Manual Initiation is required to be OPERABLE, since these channels support the manual initiation Function. In addition, the channels are only required when the associated ECCS subsystem is required to be OPERABLE by LCO 3.5.2.

1.b, 1.c, 2.b. Low Pressure Coolant Injection and Low Pressure Core Spray Discharge Flow Low (Bypass)

The minimum flow instruments are provided to protect the associated low pressure ECCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump.

One flow transmitter per ECCS pump is used to detect the associated subsystems' flow rates. The logic is arranged such that each transmitter causes its associated minimum flow valve to open. The logic will close the minimum flow valve once the closure setpoint is exceeded. The LPCI minimum flow valves are time delayed such that the valves will not open for 10 seconds after the switches detect low flow. The time delay is provided to limit reactor vessel inventory loss during the startup of the Residual Heat Removal (RHR) shutdown cooling mode (for RHR A and RHR B).

(continued)

PV Water Inventory Control Instrumentation B 3.3.5.2 RIVER BEND B 3.3-121d Revision No. 172 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY 1.b, 1.c, 2.b. Low Pressure Coolant Injection and Low Pressure Core Spray Discharge Flow Low (Bypass) (continued)

The Pump Discharge Flow - Low Allowable Values are high enough to ensure that the pump flow rate is sufficient to protect the pump, yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core.

One channel of the Pump Discharge Flow - Low Function is required to be OPERABLE in MODES 4 and 5 when the associated LPCS or LPCI pump is required to be OPERABLE by LCO 3.5.2 to ensure the pumps are capable of injecting into the Reactor Pressure Vessel when manually initiated.

1.d, 2.c. Manual Initiation The Manual Initiation push button channels introduce signals into the appropriate ECCS logic to provide manual initiation capability. There is one push button for each of the two Divisions of low pressure ECCS (i.e.,

Division 1 ECCS, LPCS and LPCI A; Division 2 ECCS, LPCI B and LPCI C). The only the manual initiation function required to be OPERABLE is that associated with the ECCS subsystem required to be OPERABLE by LCO 3.5.2.

There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons.

High Pressure Core Spray System 3.a. Condensate Storage Tank Level - Low Low level in the CST indicates the unavailability of an adequate supply of makeup water from this normal source. Normally the suction valves between HPCS and the CST are open and water for HPCS injection would be taken from the CST. However, if the water level in the CST falls below a preselected level, first the suppression pool suction valve automatically opens, and then the CST suction valve automatically closes. This ensures that an adequate supply of makeup water is available to the HPCS pump. To prevent losing suction to the pump, the suction valves are interlocked so that the suppression pool suction valve must be open before the CST suction valve automatically closes.

(continued)

PV Water Inventory Control Instrumentation B 3.3.5.2 RIVER BEND B 3.3-121e Revision No. 172 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY 3.a. Condensate Storage Tank Level - Low (continued)

Condensate Storage Tank Level - Low signals are initiated from two level transmitters. The logic is arranged such that either transmitter and associated trip unit can cause the suppression pool suction valve to open and the CST suction valve to close.

The Condensate Storage Tank Level - Low Function Allowable Value is high enough to ensure adequate pump suction head while water is being taken from the CST.

Two channels of the Condensate Storage Tank Level - Low Function are only required to be OPERABLE when HPCS is required to be OPERABLE to fulfill the requirements of LCO 3.5.2 and HPCS is aligned to the CST.

3.b, 3.c. HPCS Pump Discharge Pressure - High (Bypass) and HPCS System Flow Rate - Low (Bypass)

The minimum flow instruments are provided to protect the HPCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow line valve is opened when low flow and high pump discharge pressure are sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump or the discharge pressure is low (indicating the HPCS pump is not operating).

One flow transmitter is used to detect the HPCS System's flow rate. The logic is arranged such that the transmitter causes the minimum flow valve to open, provided the HPCS pump discharge pressure, sensed by another transmitter, is high enough (indicating the pump is operating).

The logic will close the minimum flow valve once the closure setpoint is exceeded. (The valve will also close upon HPCS pump discharge pressure decreasing below the setpoint.)

The HPCS System Flow Rate - Low and HPCS Pump Discharge Pressure - High Allowable Value is high enough to ensure that pump flow rate is sufficient to protect the pump, yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core.

The HPCS Pump Discharge Pressure - High Allowable Value is set high enough to ensure that the valve will not be open when the pump is not operating.

(continued)

PV Water Inventory Control Instrumentation B 3.3.5.2 RIVER BEND B 3.3-121f Revision No. 172 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY 3.b, 3.c. HPCS Pump Discharge Pressure - High (Bypass) and HPCS System Flow Rate - Low (Bypass) (continued)

One channel of each Function associated with one pump is required to be OPERABLE when HPCS is required to be OPERABLE by LCO 3.5.2 in MODES 4 and 5.

RHR System Isolation 4.a. Reactor Vessel Water Level - Low, Level 3-The definition of DRAIN TIME allows crediting the closing of penetration flow paths that are capable of being automatically isolated by RPV water level isolation instrumentation prior to the RPV water level being equal to the TAF. The Reactor Vessel Water Level - Low, Level 3 Function is only required to be OPERABLE when automatic isolation of the associated RHR penetration flow path is credited in calculating DRAIN TIME.

Reactor Vessel Water Level - Low, Level 3 signals are initiated from four level transmitters (two per trip system) that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low, Level 3 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low, Level 3 Allowable Value was chosen to be the same as the RPS Reactor Vessel Water Level - Low, Level 3 Allowable Value (LCO 3.3.1.1), since the capability to cool the fuel may be threatened.

This Function isolates the Groups 5 and 14 valves.

Reactor Water Cleanup (RWCU) System Isolation 5.a. Reactor Vessel Water Level - Low Low, Level 2 The definition of DRAIN TIME allows crediting the closing of penetration flow paths that are capable of being automatically isolated by RPV water level isolation instrumentation prior to the RPV water level being equal to the TAF. The Reactor Vessel Water Level - Low Low, Level 2 Function associated with RWCU System isolation may be credited for automatic isolation of penetration flow paths associated with the RWCU System.

(continued) 1 2

PV Water Inventory Control Instrumentation B 3.3.5.2 RIVER BEND B 3.3-121g Revision No. 172 BASES (continued)

APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY 5.a. Reactor Vessel Water Level - Low Low, Level 2 (continued)

Reactor Vessel Water Level - Low Low, Level 2 is initiated from two channels per trip system that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low, Level 2 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low Low, Level 2 Allowable Value was chosen to be the same as the ECCS Reactor Vessel Water Level -

Low Low, Level 2 Allowable Value (LCO 3.3.5.1), since the capability to cool the fuel may be threatened.

The Reactor Vessel Water Level - Low Low, Level 2 Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

This Function isolates the Group 8 valves.

ACTIONS A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control instrumentation channel.

A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.2-1. The applicable Condition referenced in the Table is Function dependent. Each time a channel is discovered inoperable, Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition.

(continued) 2

PV Water Inventory Control Instrumentation B 3.3.5.2 RIVER BEND B 3.3-121h Revision No. 172 BASES ACTIONS (continued)

B.1 and B.2 RHR System Isolation, Reactor Vessel Water Level - Low Level 3, and Reactor Water Cleanup System, Reactor Vessel Water Level - Low Low, Level 2 functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating Drain Time. If the instrumentation is inoperable, Required Action B.1 directs an immediate declaration that the associated penetration flow path(s) are incapable of automatic isolation. Required Action B.2 directs calculation of DRAIN TIME. The calculation cannot credit automatic isolation of the affected penetrations flow paths.

C.1 Low reactor vessel pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual initiation functions. If this permissive is inoperable, manual initiation of ECCS is prohibited.

Therefore, the permissive must be placed in the trip condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . With the permissive in the trip condition, manual initiation may be performed. Prior to placing the permissive in the tripped condition, the operator can take manual control of the pump and the injection valve to inject water into the RPV.

The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in trip.

D.1 and D.2 Required Actions D.1 and D.2 are intended to ensure that appropriate actions are taken if multiple, inoperable channels within the same Function result in a loss of automatic suction swap for the HPCS system from the condensate storage tank to the suppression pool. The HPCS system must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or the HPCS pump suction must be aligned to the suppression pool, since, if aligned, the function is already performed.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes the risk of HPCS being needed without an adequate water source while allowing time for restoration or alignment of HPCS pump suction to the suppression pool.

(continued)

A.1, A.2.1, A.2.2 Insert #1

Insert #1 A.1 directs immediate action to place the channel in trip. With the inoperable channel in the tripped condition, the remaining channel will isolate the penetration flow path on low water level. If both channels are inoperable and placed in trip, the penetration flow path will be isolated. Alternatively, Required Action A.2.1 requires that the associated penetration flow path(s) to be immediately declared incapable of automatic isolation. Required Action A.2.2 directs initiating action to calculate DRAIN TIME.

PV Water Inventory Control Instrumentation B 3.3.5.2 RIVER BEND B 3.3-121i Revision No. 172 BASES ACTIONS (continued)

E.1 and E.2 Required Actions E.1 and E.2 apply when the HPCS Reactor Vessel Water Level - High, Level 8 function is inoperable. If the function is inoperable and the channel is tripped, the HPCS pump discharge valve will not open and HPCS injection is prevented. The HPCS system must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and the function must be restored to Operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is provided to declare the HPCS System inoperable. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The Completion Time is appropriate given the ability to manually start the HPCS and to locally open the discharge valve.

F.1 If an LPCI or LPCS Discharge Flow - Low bypass function or HPCS System Discharge Pressure - High or Flow Rate - Low bypass function is inoperable, there is a risk that the associated ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the pump and the injection valve to ensure the pump does not overheat. If a manual initiation function is inoperable, the ECCS subsystem pumps can be started manually and the valves can be opened manually, but this is not the preferred condition.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The Completion Time is appropriate given the ability to manually start the ECCS pumps and open the injection valves and to manually ensure the pump does not overheat.

G.1 With the Required Action and associated Completion Time of Conditions C, D, E, or f not met, the associated ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.(continued)

(continued)

PV Water Inventory Control Instrumentation B 3.3.5.2 RIVER BEND B 3.3-121j Revision No. 172 BASES (continued)

SURVEILLANCE REQUIREMENTS An noted in the beginning of the SRs, the SRs for each RPV Water Inventory Control Instrument Function are found in the SRs column of Table 3.3.5.2-1.

SR 3.3.5.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK guarantees that undetected outright channel failure is limited; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL FUNCTIONAL TEST.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based upon operating experience that demonstrates channel failure is rare.

The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.

SR 3.3.5.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

(continued)

The following SRs apply to

PV Water Inventory Control Instrumentation B 3.3.5.2 RIVER BEND B 3.3-121k Revision No. 172 BASES SURVEILLANCE REQUIREMENTS SR 3.3.5.2.2 (continued)

The Frequency of 92 days is based upon operating experience that demonstrates channel failure is rare.

SR 3.3.5.2.3 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.5.2 overlaps this Surveillance to complete testing of the assumed safety function.

The 24 month Frequency is based on operating experience that has shown that these components usually pass the Surveillance when performed at the 24 month Frequency.

REFERENCES

1. Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup,"

November 1984.

2. Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(F), " August 1992.

4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.

5. Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.

Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 RIVER BEND B 3.3-164 Revision No. 172 BASES ACTIONS I.1 and I.2 (continued) this Function is required to ensure that the SLC System performs its intended function, sufficient remedial measures are provided by declaring the associated SLC subsystem inoperable or isolating the RWCU System.

The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is acceptable because it minimizes risk while allowing sufficient time for personnel to isolate the RWCU System.

J.1, J.2, J.3.1 and J.3.2 If the channel is not restored to OPERABLE status or placed in trip within the allowed Completion Time, the RHR Shutdown Cooling System suction from the reactor vessel should be isolated (i.e., closing either 1E12*F008 or 1E12*F009). However, if the shutdown cooling function is needed to provide core cooling, these Required Actions allow the penetration flow path to remain unisolated provided action is immediately initiated to restore the channel to OPERABLE status or to provide alternate decay heat removal capability or to provide means for control of potential radioactive releases. This is accomplished by ensuring primary containment is OPERABLE. This may be performed as an administrative check, by examining logs or other information, to determine if the components are out of service for maintenance or other reasons. It is not necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the components. If, however, any required component is inoperable, then it must be restored to OPERABLE status. In this case, the Surveillances may need to be performed to restore the component to OPERABLE status. In addition, at least one door in each primary containment air lock must be closed. The closed air lock door completes the boundary for control of potential radioactive releases. With the appropriate administrative controls however, the closed air lock door can be opened intermittently for entry and exit. This allowance is acceptable due to the need for containment access and due to the slow progression of events which may result from a reactor vessel draindown event.

Reactor vessel draindown events would not be expected to result in the immediate release of appreciable fission products to the containment atmosphere. Actions must continue until all requirements of this Condition are satisfied.

(continued) the channel is restored to OPERABLE status

LOP Instrumentation B 3.3.8.1 RIVER BEND B 3.3-211 Revision No. 1 BASES APPLICABLE uncertainties, process effects, calibration tolerances, instrument drift, SAFETY ANALYSES, and severe environment errors (for channels that must function in LCO, and harsh environments as defined by 10 CFR 50.49) are accounted for.

APPLICABILITY (continued)

The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.

4.16 kV Emergency Bus Undervoltage 1.a, 1.b, 2.a, 2.b. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage)

Loss of voltage on a 4.16 kV emergency bus indicates that offsite power may be completely lost to the respective emergency bus and is unable to supply sufficient power for proper operation of the applicable equipment.

Therefore, the power supply to the bus is transferred from offsite power to DG power when the voltage on the bus drops below the Loss of Voltage Function Allowable Values (loss of voltage with a short time delay). This ensures that adequate power will be available to the required equipment.

The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that power is available to the required equipment.

Three channels of 4.16 kV Emergency Bus Undervoltage (Loss of Voltage) Function per associated emergency bus are only required to be OPERABLE when the associated DG is required to be OPERABLE to ensure that no single instrument failure can preclude the DG function.

(Four channels input to each of the three DGs.) Refer to LCO 3.8.1, "AC Sources-Operating," and LCO 3.8.2, "AC Sources-Shutdown," for Applicability Bases for the DGs.

(continued)

LOP Instrumentation B 3.3.8.1 RIVER BEND B 3.3-212 Revision No. 145 BASES APPLICABLE 1.c, 1.d, 1.e, 2.c, 2.d, 2.e. 4.16 kV Emergency Bus Undervoltage SAFETY ANALYSES, (Degraded Voltage)

LCO, and APPLICABILITY A reduced voltage condition on a 4.16 kV emergency bus indicates (continued) that while offsite power may not be completely lost to the respective emergency bus, power may be insufficient for starting large motors without risking damage to the motors that could disable the ECCS function. Therefore, power supply to the bus is transferred from offsite power to onsite DG power when the voltage on the bus drops below the Degraded Voltage Function Allowable Values (degraded voltage with a time delay). This ensures that adequate power will be available to the required equipment.

The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that sufficient power is available to the required equipment. To ensure an inadvertent power supply transfer does not occur, no more than three 1250 HP motors may be powered by Preferred Station Transformer RTX-XSR1D with grid voltage below the main control room Low Grid Voltage alarm setpoint. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that sufficient power is available to the required equipment.

Three channels of Division I and II - 4.16 kV Emergency Bus Undervoltage (Degraded Voltage) Function per associated emergency bus and two channels of Division III - 4.16 kV Emergency Bus Undervoltage (Degraded Voltage) Functions per associated emergency bus are only required to be OPERABLE when the associated DG is required to be OPERABLE to ensure that no single instrument failure can preclude the DG function. Refer to LCO 3.8.1 and LCO 3.8.2 for Applicability Bases for the DGs.

ACTIONS A Note has been provided to modify the ACTIONS related to LOP instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable LOP instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable LOP instrumentation channel.

(continued)

LOP Instrumentation B 3.3.8.1 RIVER BEND B 3.3-213 Revision No. 0 BASES ACTIONS A.1 (continued)

With one or more channels of a Function inoperable, the Function may not be capable of performing the intended function. Therefore, only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore the inoperable channel to OPERABLE status. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action A.1. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue. Alternately, if it is not desired to place the channel in trip (e.g.,

as in the case where placing the channel in trip would result in a DG initiation), Condition B must be entered and its Required Action taken.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

B.1 If any Required Action and associated Completion Time is not met, the associated Function may not be capable of performing the intended function. Therefore, the associated DG(s) are declared inoperable immediately. This requires entry into applicable Conditions and Required Actions of LCO 3.8.1 and LCO 3.8.2, which provides appropriate actions for the inoperable DG(s).

SURVEILLANCE As noted at the beginning of the SRs, the SRs for each LOP REQUIREMENTS Instrumentation Function are located in the SRs column of Table 3.3.8.1-1.

The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provided the associated Function maintains DG initiation capability. Upon completion of the Surveillance, (continued)

LOP Instrumentation B 3.3.8.1 RIVER BEND B 3.3-215 Amendment No. 196 BASES SURVEILLANCE SR 3.3.8.1.2 (continued)

REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.8.1.3 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. There is a plant specific program which verifies that the instrumentation channel functions as required by verifying that the as-left and as-found settings are consistent with those established by the setpoint methodology.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.8.1.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel. The system functional testing performed in LCO 3.8.1 and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety functions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

USAR, Section 8.3.1.

2.

USAR, Section 5.2.

3.

USAR, Section 6.3.

4.

USAR, Chapter 15.

RPV Water Inventory Control B 3.5.2 RIVER BEND B 3.5-15 Revision No. 172 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR COR ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF.

If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

APPLICABLE SAFETY ANALYSIS With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety sizes for a postulated loss of coolant accident (LOCA). The long term analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material to the environment should an unexpected draining event occur.

A doubleended guillotine break of the Reactor Coolant System (RCS) is not postulated in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is considered in which single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety.

Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO The RPV water level must be controlled in MODES 4 and 5 to ensure that if an unexpected draining event should occur, the reactor coolant water level remains above the top of the active irradiated fuel as required by Safety Limit 2.1.1.3.

(continued) considered an an event that creates a drain path through multiple vessel penetrations located below top of active fuel, such as, or a

RPV Water Inventory Control B 3.5.2 RIVER BEND B 3.5-16 Revision No. 172 BASES LCO (continued)

The Limiting Condition for Operation (LCO) requires the DRAIN TIME of RPV water inventory to the TAF to be 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A DRAIN TIME of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate unexpected draining of reactor coolant. An event that could cause loss of RPV water inventory and result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

One ECCS injection/spray subsystem is required to be OPERABLE and capable of being manually started to provide defenseindepth should an unexpected draining event occur. An ECCS injection/spray subsystem is defined as either one of the three Low Pressure Coolant Injection (LPCI) subsystems, the Low Pressure Core Spray (LPCS) System, or the High Pressure Core Spray (HPCS) System. The LPCI subsystem and the each LPCS System consist of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV. The HPCS System consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or condensate storage tank (CST) to the RPV.

The LCO is modified by a Note which allows a required LPCI subsystem (A or B) to 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 is 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. This allowance is necessary since the RHR System may be required to operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor.

Because of the restrictions on DRAIN TIME, sufficient time will be available following an unexpected draining event to manually align and initiate LPCI subsystem operation to maintain RPV water inventory prior to the RPV water level reaching the TAF.

APPLICABILITY RPV water inventory control is required in MODES 4 and 5.

Requirements on water inventory control in other MODES are contained in LCOs in Section 3.3, "Instrumentation," and other LCOs in Section 3.5, "ECCS, RCIC, and RPV Water Inventory Control." RPV water inventory control is required to protect Safety Limit 2.1.1.3 which is applicable whenever irradiated fuel is in the reactor vessel.

(continued) aligned and from the control room OPERABILITY of the ECCS injection/spray subsystem includes any necessary valves, instrumentation, or controls needed to manually align and start the subsystem from the control room.

RPV Water Inventory Control, and RCIC System

RPV Water Inventory Control B 3.5.2 RIVER BEND B 3.5-19 Revision No. 172 BASES SURVEILLANCE REQUIREMENTS SR 3.5.2.1 (continued)

The definition of DRAIN TIME states that realistic crosssectional areas and drain rates are used in the calculation. A realistic drain rate may be determined using a single, stepwise, or integrated calculation considering the changing RPV water level during a draining event. For a Control Rod RPV penetration flow path with the Control Rod Drive Mechanism removed and not replaced with a blank flange, the realistic crosssectional area is based on the control rod blade seated in the control rod guide tube. If the control rod blade will be raised from the penetration to adjust or verify seating of the blade, the exposed crosssectional area of the RPV penetration flow path is used.

The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths. A blank flange or other bolted device must be connected with a sufficient number of bolts to prevent draining in the event of an Operating Basis Earthquake. Normal or expected leakage from closed systems or past isolation devices is permitted. Determination that a system is intact and closed or isolated must consider the status of branch lines and ongoing plant maintenance and testing activities.

The Residual Heat Removal (RHR) Shutdown Cooling System is only considered an intact closed system when misalignment issues (Reference 6) have been precluded by functional valve interlocks or by isolation devices, such that redirection of RPV water out of an RHR subsystem is precluded. Further, RHR Shutdown Cooling System is only considered an intact closed system if its controls have not been transferred to Remote Shutdown, which disables the interlocks and isolation signals.

The exclusion of penetration flow paths from the determination of DRAIN TIME must consider the potential effects of a single operator error or initiating event on items supporting maintenance and testing (rigging, scaffolding, temporary shielding, piping plugs, snubber removal, freeze seals, etc.). If failure of such items could result and would cause a draining event from a closed system or between the RPV and the isolation device, the penetration flow path may not be excluded from the DRAIN TIME calculation.

Surveillance Requirement 3.0.1 requires SRs to be met between performances. Therefore, any changes in plant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined.

(continued) closed and administratively controlled Insert #2

Insert #2 The exclusion of a single penetration flow path, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME should consider the effects of temporary alterations in support of maintenance (rigging, scaffolding, temporary shielding, piping plugs, freeze seals, etc.). If reasonable controls are implemented to prevent such temporary alterations from causing a draining event from a closed system, or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered. Reasonable controls include, but are not limited to, controls consistent with the guidance in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4, NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, or commitments to NUREG-0612, Control of Heavy Loads at Nuclear Power Plants.

RPV Water Inventory Control B 3.5.2 RIVER BEND B 3.5-19a Amendment No. 196 BASES SURVEILLANCE REQUIREMENTS SR 3.5.2.1 (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.2 and SR 3.5.2.3 The minimum water level of 13 feet 3 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 ECCS pumps, recirculation volume, and vortex prevention. With the suppression pool water level less than the required limit, the required ECCS injection/spray subsystem is inoperable unless aligned to an OPERABLE CST.

When the suppression pool level is < 13 feet 3 inches, the HPCS System is considered OPERABLE only if it can take suction from the CST and the CST water level is sufficient to provide the required NPSH for the HPCS pump. Therefore, a verification that either the suppression pool water level is 13 feet 3 inches or the HPCS System is aligned to take suction from the CST and the CST level is 11 feet 1 inch ensures that the HPCS System can supply makeup water to the RPV.

The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

SR 3.5.2.4 The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the required ECCS injection/spray subsystems full of water ensures that the ECCS subsystem will perform properly. This may 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 Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued) actuation

RPV Water Inventory Control B 3.5.2 RIVER BEND B 3.5-19b Amendment No. 196 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.5 Verifying the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow paths provides assurance that the proper flow paths will be available for ECCS operation. 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 non accident 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. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program Note 1 is included to clarify the condition of OPERABILITY of a LPCI system when operating in a decay heat removal mode. Note 2 provides for administratively controlling the system vent flow paths while maintaining compliance with this SR.

SR 3.5.2.6 Verifying that the required ECCS injection/spray subsystem can be manually started and operate for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. The minimum operating time of 10 minutes was based on engineering judgment. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.7 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued) 5 aligned, and the pump 6

Insert #3

Insert #3 This SR is modified by two Notes. Note 1 states that testing the ECCS injection/spray subsystem may be done through the test return line to avoid overfilling the refueling cavity. Note 2 states that credit for meeting the SR may be taken for normal system operation that satisfies the SR, such as using the RHR mode of LPCI for 10 minutes.

RPV Water Inventory Control B 3.5.2 RIVER BEND B 3.5-19c Amendment No. 196 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.8 The required ECCS subsystem is required to have a manual start capability. This Surveillance verifies that a manual initiation signal will cause the required LPCI subsystem, or LPCS System to start and operate as designed, including pump startup and actuation of all automatic valves to their required positions. The HPCS system is verified to start manually from a standby configuration, and includes the ability to override the RPV Level 8 injection valve isolation.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program This SR is modified by a Note 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.

REFERENCES

1. Information Notice 8481 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup,"

November 1984.

2. Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(F)," August 1992.

4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.

5. Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.

6. General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6,"

February 1983.

7

, or HPCS System can be manually aligned and started from the control room, including any necessary valve alignment, instrumentation, or controls, to transfer water from the suppression pool or CST to the RPV.

AC Sources Shutdown B 3.8.2 RIVER BEND B 3.8-36 Revision No. 172 BASES LCO electrical power support, assuming a loss of the offsite circuit. Similarly, (continued) when the high pressure core spray (HPCS) is required to be OPERABLE, a separate offsite circuit to the Division III Class 1E onsite electrical power distribution subsystem, or an OPERABLE Division III DG, ensure an additional source of power for the HPCS. This additional source for Division III is not necessarily required to be connected to be OPERABLE.

Either the circuit required by LCO Item a, or a circuit required to meet LCO Item c may be connected, with the second source available for connection. Together, OPERABILITY of the required offsite circuit(s) and DG(s) ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

The qualified offsite circuit(s) must be capable of maintaining rated frequency and voltage while connected to their respective ESF bus(es),

and accepting required loads during an accident. Qualified offsite circuits are those that are described in the USAR and are part of the licensing basis for the plant. The offsite circuit consists of incoming breaker and disconnect to the respective preferred station service transformers 1C and 1D, the 1C and 1D preferred station service transformers, and the respective circuit path including feeder breakers to all 4.16 kV ESF buses required by LCO 3.8.10.

The required DG must be capable of starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus undervoltage, and accepting required loads. This sequence must be accomplished within 10 seconds for DG 1A and DG 1B and 13 seconds for DG 1C. Each DG must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as: DG in standby with the engine hot and DG in standby with the engine at ambient conditions. Additional DG capabilities must be demonstrated to meet required Surveillance, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode.

Proper sequencing of loads, including tripping of (continued) the ability to manually start a being manually started

AC Sources Shutdown B 3.8.2 RIVER BEND B 3.8-37 Revision No. 172 BASES LCO nonessential loads, is a required function for DG OPERABILITY. In (continued) addition, proper load sequence operation is an integral part of offsite circuit and DG OPERABILITY since its inoperability impacts the ability to start and maintain energized any loads required OPERABLE by LCO 3.8.10.

It is acceptable for divisions to be cross tied during shutdown conditions, permitting a single offsite power circuit to supply all required AC electrical power distribution subsystems.

As described in Applicable Safety Analyses, in the event of an accident during shutdown, the TS are designed to maintain the plant in a condition such that, even with a single failure, the plant will not be in immediate difficulty.

APPLICABILITY The AC sources required to be OPERABLE in MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the primary containment or fuel building provide assurance that:

a.

Systems that provide core cooling are available;

b.

Systems needed to mitigate a fuel handling accident are available;

c.

Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d.

Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.1.

ACTIONS The ACTIONS are modified by a Note indicating that LCO 3.0.3 does not apply. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require reactor shutdown.

(continued)

AC Sources Shutdown B 3.8.2 RIVER BEND B 3.8-39 Revision No. 102 BASES ACTIONS A.2.1, A.2.2, A.2.3, A.2.4, B.1, B.2, B.3, and B.4 (continued) minimize the time during which the plant safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System ACTIONS are not entered even if all AC sources to it are inoperable, resulting in de-energization.

Therefore, the Required Actions of Condition A have been modified by a Note to indicate that when Condition A is entered with no AC power to any required ESF bus, ACTIONS for LCO 3.8.10 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit whether or not a division is de-energized. LCO 3.8.10 provides the appropriate restrictions for the situation involving a de-energized division.

C.1 When the HPCS is required to be OPERABLE, and the additional required Division III AC source is inoperable, the required diversity of AC power sources to the HPCS is not available. Since these sources only affect the HPCS, the HPCS is declared inoperable and the Required Actions of the affected Emergency Core Cooling Systems LCO entered.

In the event all sources of power to Division III are lost, Condition A will also be entered and direct that the ACTIONS of LCO 3.8.10 be taken. If only the Division III additional required AC source is inoperable, and power is still supplied to HPCS, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore the additional required AC source to OPERABLE. This is reasonable considering HPCS will still perform its function, absent an additional single failure.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.8 is not required to be met since only one offsite circuit is required to be OPERABLE. SR 3.8.1.17 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods (continued)

SR 3.8.1.7, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.15, SR 3.8.1.18, and SR 3.8.1.19 are not required to be met because DG start and load within a specified time and response on an offsite power or ECCS initiation signal is not required.

AC SourcesShutdown B 3.8.2 RIVER BEND B 3.8-40 Revision No. 102 BASES SURVEILLANCE SR 3.8.2.1 (continued)

REQUIREMENTS of being synchronized to the offsite circuit. SR 3.8.1.20 is excepted because starting independence is not required with the DG(s) that is not required to be OPERABLE. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs, and preclude de-energizing a required 4.16 KV ESF bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and the DG. It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG is required to be OPERABLE.

REFERENCES None.

No Changes - For Information

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RBG-48033, Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

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RBG-48033, Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

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