L-21-176, Application to Revise Technical Specifications to Adopt TSTF-554, Revise Reactor Coolant Leakage Requirements

Application to Revise Technical Specifications to Adopt TSTF-554, Revise Reactor Coolant Leakage Requirements

ML21292A274
Person / Time
Site:	Beaver Valley, Davis Besse, Perry
Issue date:	10/19/2021
From:	Benyak D Energy Harbor Nuclear Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-21-176
Download: ML21292A274 (42)

Text

Energy Harbor Nuclear Corp.

168 E. Market Street Akron, Ohio 44308 Darin M. Benyak Senior Vice President, Fleet Nuclear Operations 330-436-1380 October 19, 2021 L-21-176 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Application to Revise Technical Specifications to Adopt TSTF-554, "Revise Reactor Coolant Leakage Requirements" Pursuant to 10 CFR 50.90, Energy Harbor Nuclear Corp. is submitting a request for an amendment to the Technical Specifications (TS) for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), and Perry Nuclear Power Plant, Unit No. 1 (PNPP).

Energy Harbor Nuclear Corp. requests adoption of TSTF-554, "Revise Reactor Coolant Leakage Requirements," which is an approved change to the Standard Technical Specifications (STS), into the BVPS, DBNPS, and PNPP Technical Specifications (TSs).

The proposed amendment revises the Technical Specification (TS) definition of "Leakage," clarifies the requirements when pressure boundary leakage is detected, and adds a Required Action when pressure boundary leakage is identified.

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

Evaluation of Proposed Change Page 1 of 6

Subject:

Application to Revise Technical Specifications to Adopt TSTF-554, "Revise Reactor Coolant Leakage Requirements"

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation 2.2 Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis 3.2 Conclusion 4.0 ENVIRONMENTAL EVALUTION 5.0 ATTACHMENTS

1.

Proposed Technical Specification Changes (Mark-up)

2.

Revised Technical Specification Pages (for information only)

3.

Proposed Technical Specification Bases Markups (for information only)

Evaluation of Proposed Change Page 2 of 6

1.0 DESCRIPTION

Energy Harbor Nuclear Corp. requests adoption of TSTF-554, "Revise Reactor Coolant Leakage Requirements," which is an approved change to the Standard Technical Specifications (STS), into the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS),

Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), and Perry Nuclear Power Plant, Unit No. 1 (PNPP) Technical Specifications (TSs). The proposed amendment revises the Technical Specification (TS) definition of "Leakage" and the Reactor Coolant System (RCS) Operational Leakage TS to clarify the requirements.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation Energy Harbor Nuclear Corp. has reviewed the safety evaluation for TSTF-554 provided to the Technical Specifications Task Force in a letter dated December 18, 2020. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-554. Energy Harbor Nuclear Corp. has concluded that the justifications presented in TSTF-554 and the safety evaluation prepared by the NRC staff are applicable to BVPS, DBNPS, and PNPP and justify this amendment for the incorporation of the changes into the BVPS, DBNPS, and PNPP TSs.

2.2 Variations Energy Harbor Nuclear Corp. is proposing the following variations from the TS changes described in TSTF-554 or the applicable parts of the NRC staffs safety evaluation.

The BVPS TS utilize different punctuation than the Standard Technical Specifications on which TSTF-554 was based. Specifically, a comma is used within the definition of LEAKAGE in parts a.1 and a.2 under Identified LEAKAGE, while part a.3 uses a semicolon. Part b, Unidentified LEAKAGE, also uses a comma. To make the LEAKAGE definition punctuation consistent with TSTF-GG-05-01, Writers Guide for Plant-Specific Improved Technical Specifications, Revision 1 (August 2010), the commas in parts a.1, a.2, and b are changed to semicolons. No change is proposed for part a.3 because it already uses a semicolon. These differences are administrative and do not affect the applicability of TSTF-554 to the BVPS TS.

The DBNPS TS utilize different punctuation than the Standard Technical Specifications on which TSTF-554 was based. Specifically, a comma is used within the definition of LEAKAGE in part a.3 under Identified LEAKAGE. To make the LEAKAGE definition punctuation consistent with TSTF-GG-05-01, Writers Guide for Plant-Specific Improved Technical Specifications, Revision 1 (August 2010),

Evaluation of Proposed Change Page 3 of 6 the comma in part a.3 is changed to a semicolon. No change is proposed for part b, Unidentified LEAKAGE, because it already uses a semicolon. These differences are administrative and do not affect the applicability of TSTF-554 to the DBNPS TS.

The DBNPS definition of LEAKAGE includes an exception that differs from the Standard Technical Specifications on which TSTF-554 was based but is encompassed in the TSTF-554 justification. The parenthetical phrase that describes the exception for DBNPS is (except RCP seal return flow). This exception is used in part a.1 and part b of the definition. Seal water flow from the reactor coolant pump (RCP) seals (that is, RCP seal return flow) is the normal controlled RCP seal leakoff that is returned to the makeup tank. This difference in wording avoids an implication that the exception includes RCP upper seal leakoff, which is not returned to the makeup tank and is actual identified LEAKAGE. This difference does not affect the applicability of TSTF-554 to the DBNPS TS.

The PNPP TS utilize different punctuation than the Standard Technical Specifications on which TSTF-554 was based. Specifically, commas and semicolons are used appropriately within the definition of LEAKAGE. Therefore, no changes to the punctuation are needed to make the LEAKAGE definition punctuation consistent with TSTF-GG-05-01, Writers Guide for Plant-Specific Improved Technical Specifications, Revision 1 (August 2010). These differences are administrative and do not affect the applicability of TSTF-554 to the PNPP TS.

The PNPP definition of Total LEAKAGE differs from the Standard Technical Specifications on which TSTF-554 was based. The conjunction, and, is omitted.

Energy Harbor Nuclear Corp. will add this conjunction to the definition to align with the Standard Technical Specifications. This difference is administrative and does not affect the applicability of TSTF-554 to the PNPP TS.

The PNPP TS contain requirements that differ from the Standard Technical Specifications on which TSTF-554 was based but are encompassed in the TSTF-554 justification. TS 3.4.5, RCS Operational LEAKAGE, Condition B, has only one action, Required Action B.1. Therefore, for the adoption of TSTF-554, Required Action B.1 is renumbered to C.1. In addition, the wording of the current Required Action B.1 differs from the Standard Technical Specifications. Required Action B.1 states Verify source of unidentified LEAKAGE increase is not service sensitive austenitic material. For PNPP, wrought stainless steel primary pressure boundary piping was fabricated using Type 304 material and, wherever practical, the piping was solution heat treated after welding. Welded areas that could not be solution heat treated were protected by applying high ferrite (5 percent minimum ferrite) Type 308L weld overlay prior to the welding operation. These methods provide protection against stress corrosion cracking. As clarified in the current TS Bases Section 3.4.5, Required Action B.1 is to perform an evaluation to determine that the service sensitive Inconel 182 material in the nozzle welds of the reactor vessel, which is classified as non-resistant material to intergranular stress corrosion cracking (IGSCC), is not the source of the increased leakage. This

Evaluation of Proposed Change Page 4 of 6 difference in wording for Required Action B.1 does not affect the applicability of TSTF-554 to the PNPP TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Energy Harbor Nuclear Corp. requests adoption of TSTF-554, "Revise Reactor Coolant Leakage Requirements," that is an approved change to the Standard Technical Specifications (STS), into the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), and Perry Nuclear Power Plant, Unit No. 1 (PNPP) Technical Specifications (TSs). The proposed amendment revises the Technical Specification (TS) definition of "Leakage," clarifies the requirements when pressure boundary leakage is detected, and adds a Required Action when pressure boundary leakage is identified.

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

1.

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

Response: No The proposed amendment revises the TS definition of "Leakage," clarifies the requirements when pressure boundary leakage is detected, and adds a Required Action when pressure boundary leakage is identified.

The proposed change revises the definition of pressure boundary leakage.

Pressure boundary leakage is a precursor to some accidents previously evaluated. The proposed change expands the definition of pressure boundary leakage by eliminating the qualification that pressure boundary leakage must be from a "nonisolable" flaw. A new TS Action is created which requires isolation of the pressure boundary flaw from the Reactor Coolant System. This new action provides assurance that the flaw will not result in any accident previously evaluated.

Pressure boundary leakage, and the actions taken when pressure boundary leakage is detected, is not assumed in the mitigation of any accident previously evaluated. As a result, the consequences of any accident previously evaluated are unaffected.

Evaluation of Proposed Change Page 5 of 6 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 amendment revises the TS definition of "Leakage," clarifies the requirements when pressure boundary leakage is detected, and adds a Required Action when pressure boundary leakage is identified. The proposed change does not alter the design function or operation of the RCS.

The proposed change does not alter the ability of the RCS to perform its design function. Since pressure boundary leakage is an evaluated accident, the proposed change does not create any new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.

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 amendment revises the TS definition of "Leakage," clarifies the requirements when pressure boundary leakage is detected, and adds a Required Action when pressure boundary leakage is identified. The proposed change does not affect the initial assumptions, margins, or controlling values used in any accident analysis. The amount of leakage allowed from the RCS is not increased. The proposed change does not affect any design basis or safety limit or any Limiting Condition for Operation.

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

Based on the above, Energy Harbor Nuclear Corp. 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.

Evaluation of Proposed Change Page 6 of 6 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. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

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

Proposed Technical Specification Changes (Mark-up)

(9 pages follow)

Definitions 1.1 1.1 Definitions ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its actuation setpoint TIME at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

LEAKAGE LEAKAGE shall be:

a.

Identified LEAKAGE

1.

LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank,;

2.

LEAKAGE into the containment atmosphere from sources that are both specifically located and known eitherto not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE,; or

3.

Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);

b.

Unidentified LEAKAGE All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE,; and

c.

Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a nonisolable fault in an RCS component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

Beaver Valley Units 1 and 2 1.1 - 3 Amendments 298 / 186

RCS Operational LEAKAGE 3.4.13 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.13 RCS Operational LEAKAGE LCO 3.4.13 RCS operational LEAKAGE shall be limited to:

a.

No pressure boundary LEAKAGE,

b.

1 gpm unidentified LEAKAGE,

c.

10 gpm identified LEAKAGE, and

d.

150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG).

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressure boundary LEAKAGE exists.

A.1 Isolate affected component, pipe, or vessel from the RCS by use of a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> BA. RCS operational LEAKAGE not within limits for reasons other than pressure boundary LEAKAGE or primary to secondary LEAKAGE.

BA.1 Reduce LEAKAGE to within limits.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> CB. Required Action and associated Completion Time of Condition A not met.

OR Pressure boundary LEAKAGE exists.

OR Primary to secondary LEAKAGE not within limit.

CB.1 Be in MODE 3.

AND CB.2 Be in MODE 5.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours

Beaver Valley Units 1 and 2 3.4.13 - 1 Amendments 278 / 161

Definitions 1.1 Davis-Besse 1.1-3 Amendment 279 1.1 Definitions LEAKAGE LEAKAGE shall be:

a.

Identified LEAKAGE

1.

LEAKAGE, such as that from pump seals or valve packing (except RCP seal return flow), that is captured and conducted to collection systems or a sump or collecting tank;

2.

LEAKAGE into the containment atmosphere from sources that are both specifically located and known eitherto not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE; or

3.

Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);,

b.

Unidentified LEAKAGE All LEAKAGE (except RCP seal return flow) that is not identified LEAKAGE; and

c.

Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a nonisolable fault in an RCS component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

MODE A MODE shall correspond to any one inclusive combination of core reactivity condition, power level, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

NUCLEAR HEAT FLUX HOT FQ shall be the maximum local linear power density in the CHANNEL FACTOR (FQ) core divided by the core average fuel rod linear power density, assuming nominal fuel pellet and fuel rod dimensions.

NUCLEAR ENTHALPY RISE N

H F shall be the ratio of the integral of linear power along the HOT CHANNEL fuel rod on which minimum departure from nucleate boiling FACTOR (

N H

F) ratio occurs, to the average fuel rod power.

RCS Operational LEAKAGE 3.4.13 Davis-Besse 3.4.13-1 Amendment 279 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.13 RCS Operational LEAKAGE LCO 3.4.13 RCS operational LEAKAGE shall be limited to:

a.

No pressure boundary LEAKAGE;

b.

1 gpm unidentified LEAKAGE;

c.

10 gpm identified LEAKAGE; and

d.

150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG).

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressure boundary LEAKAGE exists.

A.1 Isolate affected component, pipe, or vessel from the RCS by use of a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> BA. RCS operational LEAKAGE not within limits for reasons other than pressure boundary LEAKAGE or primary to secondary LEAKAGE.

BA.1 Reduce LEAKAGE to within limits.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> CB. Required Action and associated Completion Time of Condition A not met.

OR Pressure boundary LEAKAGE exists.

CB.1 Be in MODE 3.

AND CB.2 Be in MODE 5.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours

RCS Operational LEAKAGE 3.4.13 Davis-Besse 3.4.13-1 Amendment 279 CONDITION REQUIRED ACTION COMPLETION TIME OR Primary to secondary LEAKAGE not within limit.

Definitions 1.1 PERRY - UNIT 1 1.0-4 Amendment No. 69 1.1 Definitions (continued)

LEAKAGE LEAKAGE shall be:

a.

Identified LEAKAGE

1. LEAKAGE into the drywell such as that from pump seals or valve packing, that is captured and conducted to a sump or collecting tank; or

2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known eitherto not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE;

b.

Unidentified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE;

c.

Total LEAKAGE Sum of the identified and unidentified LEAKAGE; and

d.

Pressure Boundary LEAKAGE LEAKAGE through a nonisolable fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

LINEAR HEAT GENERATION The LHGR shall be the heat generation rate per unit length RATE (LHGR) of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.

LOGIC SYSTEM FUNCTIONAL A LOGIC SYSTEM FUNCTIONAL TEST shall be a test of all TEST required logic components (i.e., all required relays and contacts, trip units, solid state logic elements, etc.) of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

(continued)

RCS Operational LEAKAGE 3.4.5 PERRY - UNIT 1 3.4-12 Amendment No. 69 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Operational LEAKAGE LCO 3.4.5 RCS operational LEAKAGE shall be limited to:

a.

No pressure boundary LEAKAGE;

b.

5 gpm unidentified LEAKAGE;

c.

30 gpm total LEAKAGE averaged over the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period; and

d.

2 gpm increase in unidentified LEAKAGE within the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period in MODE 1.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressure boundary LEAKAGE exists.

A.1 Isolate affected component, pipe, or vessel from the RCS by use of a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> BA. Unidentified LEAKAGE not within limit.

OR Total LEAKAGE not within limit.

BA.1 Reduce LEAKAGE to within limits.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> CB. Unidentified LEAKAGE increase not within limit.

CB.1 Verify source of unidentified LEAKAGE increase is not service sensitive austenitic material.

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

RCS Operational LEAKAGE 3.4.5 PERRY - UNIT 1 3.4-13 Amendment No. 171 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DC.

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

OR Pressure boundary LEAKAGE exists.

DC.1 Be in MODE 3.

AND DC.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify RCS unidentified LEAKAGE, total LEAKAGE, and unidentified LEAKAGE increase are within limits.

In accordance with the Surveillance Frequency Control Program Revised Technical Specification Pages (for information only)

(7 pages follows)

Definitions 1.1 1.1 Definitions ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its actuation setpoint TIME at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE

1. LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank;

2. LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or

3. Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);

b. Unidentified LEAKAGE All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE; and

c. Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a fault in an RCS component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

Beaver Valley Units 1 and 2 1.1 - 3 Amendments TBD / TBD FOR INFORMATION ONLY

RCS Operational LEAKAGE 3.4.13 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.13 RCS Operational LEAKAGE LCO 3.4.13 RCS operational LEAKAGE shall be limited to:

a.

No pressure boundary LEAKAGE,

b.

1 gpm unidentified LEAKAGE,

c.

10 gpm identified LEAKAGE, and

d.

150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG).

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressure boundary LEAKAGE exists.

A.1 Isolate affected component, pipe, or vessel from the RCS by use of a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve.

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

RCS operational LEAKAGE not within limits for reasons other than pressure boundary LEAKAGE or primary to secondary LEAKAGE.

B.1 Reduce LEAKAGE to within limits.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> C. Required Action and associated Completion Time not met.

OR Primary to secondary LEAKAGE not within limit.

C.1 Be in MODE 3.

AND C.2 Be in MODE 5.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours Beaver Valley Units 1 and 2 3.4.13 - 1 Amendments TBD / TBD FOR INFORMATION ONLY

Definitions 1.1 Davis-Besse 1.1-3 Amendment TBD9 1.1 Definitions LEAKAGE LEAKAGE shall be:

a.

Identified LEAKAGE 1.

LEAKAGE, such as that from pump seals or valve packing (except RCP seal return flow), that is captured and conducted to collection systems or a sump or collecting tank; 2.

LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or 3.

Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);

b.

Unidentified LEAKAGE All LEAKAGE (except RCP seal return flow) that is not identified LEAKAGE; and c.

Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a fault in an RCS component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

MODE A MODE shall correspond to any one inclusive combination of core reactivity condition, power level, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

NUCLEAR HEAT FLUX HOT FQ shall be the maximum local linear power density in the CHANNEL FACTOR (FQ) core divided by the core average fuel rod linear power density, assuming nominal fuel pellet and fuel rod dimensions.

NUCLEAR ENTHALPY RISE N

H F shall be the ratio of the integral of linear power along the HOT CHANNEL fuel rod on which minimum departure from nucleate boiling FACTOR (

N H

F) ratio occurs, to the average fuel rod power.

FOR INFORMATION ONLY

RCS Operational LEAKAGE 3.4.13 Davis-Besse 3.4.13-1 Amendment TBD 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.13 RCS Operational LEAKAGE LCO 3.4.13 RCS operational LEAKAGE shall be limited to:

a.

No pressure boundary LEAKAGE; b.

1 gpm unidentified LEAKAGE; c.

10 gpm identified LEAKAGE; and d.

150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG).

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressure boundary LEAKAGE exists.

A.1 Isolate affected component, pipe, or vessel from the RCS by use of a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. RCS operational LEAKAGE not within limits for reasons other than pressure boundary LEAKAGE or primary to secondary LEAKAGE.

B.1 Reduce LEAKAGE to within limits.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> C. Required Action and associated Completion Time not met.

OR Primary to secondary LEAKAGE not within limit.

C.1 Be in MODE 3.

AND C.2 Be in MODE 5.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours FOR INFORMATION ONLY

Definitions 1.1 PERRY - UNIT 1 1.0-4 Amendment No. TBD69 1.1 Definitions (continued)

LEAKAGE LEAKAGE shall be:

a.

Identified LEAKAGE

1. LEAKAGE into the drywell such as that from pump seals or valve packing, that is captured and conducted to a sump or collecting tank; or

2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems;

b.

Unidentified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE;

c.

Total LEAKAGE Sum of the identified and unidentified LEAKAGE; and

d.

Pressure Boundary LEAKAGE LEAKAGE through a fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

LINEAR HEAT GENERATION The LHGR shall be the heat generation rate per unit length RATE (LHGR) of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.

LOGIC SYSTEM FUNCTIONAL A LOGIC SYSTEM FUNCTIONAL TEST shall be a test of all TEST required logic components (i.e., all required relays and contacts, trip units, solid state logic elements, etc.) of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

(continued)

FOR INFORMATION ONLY

RCS Operational LEAKAGE 3.4.5 PERRY - UNIT 1 3.4-12 Amendment No. TBDT 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Operational LEAKAGE LCO 3.4.5 RCS operational LEAKAGE shall be limited to:

a.

No pressure boundary LEAKAGE;

b.

5 gpm unidentified LEAKAGE;

c.

30 gpm total LEAKAGE averaged over the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period; and

d.

2 gpm increase in unidentified LEAKAGE within the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period in MODE 1.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressure boundary LEAKAGE exists.

A.1 Isolate affected component, pipe, or vessel from the RCS by use of a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. Unidentified LEAKAGE not within limit.

OR Total LEAKAGE not within limit.

B.1 Reduce LEAKAGE to within limits.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> C. Unidentified LEAKAGE increase not within limit.

C.1 Verify source of unidentified LEAKAGE increase is not service sensitive austenitic material.

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

FOR INFORMATION ONLY

RCS Operational LEAKAGE 3.4.5 PERRY - UNIT 1 3.4-13 Amendment No. TBD.

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and associated Completion Time not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify RCS unidentified LEAKAGE, total LEAKAGE, and unidentified LEAKAGE increase are within limits.

In accordance with the Surveillance Frequency Control Program FOR INFORMATION ONLY Proposed Technical Specification Bases Markups (for information only)

(15 pages follow)

RCS Operational LEAKAGE B 3.4.13 BASES APPLICABLE SAFETY ANALYSIS (continued)

The RCS operational LEAKAGE satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO RCS operational LEAKAGE shall be limited to:

a.

Pressure Boundary LEAKAGE No pPressure boundary LEAKAGE is prohibitedallowed, being indicative of material deterioration. LEAKAGE of this type is unacceptable as the leak itself could cause further RCPB deterioration, resulting in higher LEAKAGE. Violation of this LCO could result in continued degradation of the RCPB. LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE.

Should pressure boundary LEAKAGE occur through a component which can be isolated from the balance of the Reactor Coolant System, plant operation may continue provided the leaking component is promptly isolated from the Reactor Coolant System since isolation removes the source of potential failure.

b.

Unidentified LEAKAGE One gallon per minute (gpm) of unidentified LEAKAGE is allowed as a reasonable minimum detectable amount that the containment air monitoring and containment sump level monitoring equipment can detect within a reasonable time period. Separating the sources of leakage (i.e., leakage from an identified source versus leakage from an unidentified source) is necessary for prompt identification of potentially adverse conditions, assessment of the safety significance, and corrective action. Violation of this LCO could result in continued degradation of the RCPB, if the LEAKAGE is from the pressure boundary.

c.

Identified LEAKAGE Up to 10 gpm of identified LEAKAGE is considered allowable because LEAKAGE is from known sources that do not interfere with detection of unidentified LEAKAGE and is well within the capability of the RCS Makeup System. Identified LEAKAGE includes LEAKAGE to the containment from specifically known and located sources, but does not include pressure boundary LEAKAGE or controlled reactor coolant pump (RCP) seal leakoff (a normal function not considered LEAKAGE). Violation of this LCO could result in continued degradation of a component or system.

FOR INFORMATION ONLY

Beaver Valley Units 1 and 2 B 3.4.13 - 3 Revision 0 FOR INFORMATION ONLY

RCS Operational LEAKAGE B 3.4.13 BASES LCO (continued)

d.

Primary to Secondary LEAKAGE through Any One SG The limit of 150 gallons per day per SG is based on the operational LEAKAGE performance criterion in NEI 97-06, Steam Generator Program Guidelines (Ref. 4). The Steam Generator Program operational LEAKAGE performance criterion in NEI 97-06 states, "The RCS operational primary to secondary leakage through any one SG shall be limited to 150 gallons per day." The limit is based on operating experience with SG tube degradation mechanisms that result in tube leakage. The operational leakage rate criterion in conjunction with the implementation of the Steam Generator Program is an effective measure for minimizing the frequency of steam generator tube ruptures.

APPLICABILITY In MODES 1, 2, 3, and 4, the potential for RCPB LEAKAGE is greatest when the RCS is pressurized.

In MODES 5 and 6, LEAKAGE limits are not required because the reactor coolant pressure is far lower, resulting in lower stresses and reduced potentials for LEAKAGE.

LCO 3.4.14, "RCS Pressure Isolation Valve (PIV) Leakage," measures leakage through each individual PIV and can impact this LCO. Of the two PIVs in series in each isolated line, leakage measured through one PIV does not result in RCS LEAKAGE when the other is leak tight. If both valves leak and result in a loss of mass from the RCS, the loss must be included in the allowable identified LEAKAGE.

ACTIONS A.1 If pressure boundary LEAKAGE exists, the affected component, pipe, or vessel must be isolated from the RCS by a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. While in this condition, structural integrity of the system should be considered because the structural integrity of the part of the system within the isolation boundary must be maintained under all licensing basis conditions, including consideration of the potential for further degradation of the isolated location. Normal LEAKAGE past the isolation device is acceptable as it will limit RCS LEAKAGE and is included in identified or unidentified LEAKAGE. This action is necessary to prevent further deterioration of the RCPB.

B.1 Unidentified LEAKAGE or identified LEAKAGE in excess of the LCO limits must be reduced to within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This Completion Time allows time to verify leakage rates and either identify unidentified LEAKAGE or reduce LEAKAGE to within limits before the reactor must be shut down. This action is necessary to prevent further FOR INFORMATION ONLY

deterioration of the RCPB.

CB.1 and CB.2 If any pressure boundary LEAKAGE exists, or primary to secondary LEAKAGE is not within limit, or if any of the Required Actions and associated Completion Times cannot be met, unidentified or identified LEAKAGE cannot be reduced to within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the reactor must be brought to lower pressure conditions to reduce the severity of the Beaver Valley Units 1 and 2 B 3.4.13 - 4 Revision 0 FOR INFORMATION ONLY

RCS Operational LEAKAGE B 3.4.13 BASES ACTIONS (continued)

LEAKAGE and its potential consequences. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE.

The reactor must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This action reduces the LEAKAGE and also reduces the factors that tend to degrade the pressure boundary.

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

In MODE 5, the pressure stresses acting on the RCPB are much lower, and further deterioration is much less likely.

SURVEILLANCE SR 3.4.13.1 REQUIREMENTS Verifying RCS LEAKAGE to be within the LCO limits ensures the integrity of the RCPB is maintained. Pressure boundary LEAKAGE would at first appear as unidentified LEAKAGE and can only be positively identified by inspection. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. Unidentified LEAKAGE and identified LEAKAGE are determined by performance of an RCS water inventory balance.

The RCS water inventory balance must be met with the reactor at steady state operating conditions (stable temperature, power level, pressurizer and makeup tank levels, makeup and letdown and RCP seal injection and return flows) and near operating pressure. The Surveillance is modified by two Notes. Note 1 states that this SR is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established.

Note 2 states that this SR is not applicable to primary to secondary LEAKAGE because LEAKAGE of 150 gallons per day cannot be measured accurately by an RCS water inventory balance.

Steady state operation is required to perform a proper inventory balance since calculations during maneuvering are not useful. For RCS operational LEAKAGE determination by water inventory balance, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows.

Beaver Valley Units 1 and 2 B 3.4.13 - 5 Revision 0 FOR INFORMATION ONLY

RCS Operational LEAKAGE B 3.4.13 BASES SURVEILLANCE REQUIREMENTS (continued)

An early warning of pressure boundary LEAKAGE or unidentified LEAKAGE is provided by the instrumentation systems that monitor the containment atmosphere radioactivity and the containment sump level. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. These leakage detection systems are specified in LCO 3.4.15, "RCS Leakage Detection Instrumentation."

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

SR 3.4.13.2 This SR verifies that primary to secondary LEAKAGE is less than or equal to 150 gallons per day through any one SG. Satisfying the primary to secondary LEAKAGE limit ensures that the operational LEAKAGE performance criterion in the Steam Generator Program is met. If this SR is not met, compliance with LCO 3.4.20, "Steam Generator Tube Integrity," should be evaluated. The 150 gallons per day limit is measured at room temperature (25C) as described in Reference 5. The operational LEAKAGE rate limit applies to LEAKAGE through any one SG. If it is not practical to assign the LEAKAGE to an individual SG, all the primary to secondary LEAKAGE should be conservatively assumed to be from one SG.

The Surveillance is modified by a Note which states that the Surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation. For RCS primary to secondary LEAKAGE determination, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The primary to secondary LEAKAGE is determined using continuous process radiation monitors or radiochemical grab sampling in accordance with the EPRI guidelines (Ref. 5).

REFERENCES

1.

Unit 1 UFSAR Appendix 1A, "1971 AEC General Design Criteria Conformance" and Unit 2 UFSAR Section 3.1, "Conformance with U.S. Nuclear Regulatory Commission General Design Criteria."

2.

UFSAR Section 4.2.7.1 (Unit 1) and UFSAR Section 5.2.5 (Unit 2).

Beaver Valley Units 1 and 2 B 3.4.13 - 6 Revision 29 FOR INFORMATION ONLY

RCS Operational LEAKAGE B 3.4.13 Davis-Besse B 3.4.13-2 Revision 32 BASES APPLICABLE Except for primary to secondary LEAKAGE, the safety analyses do not SAFETY address operational LEAKAGE. However, other operational LEAKAGE ANALYSES is related to the safety analyses for LOCA; the amount of leakage can affect the probability of such an event. The safety analysis for an event resulting in steam discharge to the atmosphere assumes that primary to secondary LEAKAGE from all steam generators (SGs) is 1 gallon per minute or increases to 1 gallon per minute as a result of accident induced conditions. The LCO requirement to limit primary to secondary LEAKAGE through any one SG to less than or equal to 150 gallons per day is significantly less than the conditions assumed in the safety analysis.

Primary to secondary LEAKAGE is a factor in the dose releases outside containment resulting from a main steam line break (MSLB) accident. To a lesser extent, other accidents or transients involve secondary steam release to the atmosphere, such as a steam generator tube rupture (SGTR). The leakage contaminates the secondary fluid.

The UFSAR (Ref. 3) analysis for SGTR assumes the contaminated secondary fluid is only briefly released via safety valves and the majority is steamed to the condenser. The 1 gpm primary to secondary LEAKAGE safety analysis assumption is relatively inconsequential.

The safety analysis for the MSLB accident assumes the entire 1 gpm primary to secondary LEAKAGE is through the affected generator as an initial condition. The dose consequences resulting from the MSLB accident are well within the limits defined in 10 CFR 100.

RCS operational LEAKAGE satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO RCS operational LEAKAGE shall be limited to:

a.

Pressure Boundary LEAKAGE No pPressure boundary LEAKAGE is prohibitedallowed, being indicative of material deterioration. LEAKAGE of this type is unacceptable as the leak itself could cause further RCPB deterioration, resulting in higher LEAKAGE. Violation of this LCO could result in continued degradation of the RCPB. LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE.

FOR INFORMATION ONLY

RCS Operational LEAKAGE B 3.4.13 Davis-Besse B 3.4.13-3 Revision 32 BASES LCO (continued)

b.

Unidentified LEAKAGE One gallon per minute (gpm) of unidentified LEAKAGE is allowed as a reasonable minimum detectable amount that the containment air monitoring and containment sump level monitoring equipment can detect within a reasonable time period. Separating the sources of leakage (i.e., leakage from an identified source versus leakage from an unidentified source) is necessary for prompt identification of potentially adverse conditions, assessment of the safety significance, and corrective action. Violation of this LCO could result in continued degradation of the RCPB, if the LEAKAGE is from the pressure boundary.

c.

Identified LEAKAGE Up to 10 gpm of identified LEAKAGE is considered allowable because LEAKAGE is from known sources that do not interfere with detection of unidentified LEAKAGE and is well within the capability of the RCS makeup system. Identified LEAKAGE includes LEAKAGE to the containment from specifically known and located sources, but does not include pressure boundary LEAKAGE or controlled reactor coolant pump (RCP) seal return flow (a normal function not considered LEAKAGE). Violation of this LCO could result in continued degradation of a component or system.

d.

Primary to Secondary LEAKAGE Through Any One SG The limit of 150 gallons per day per SG is based on the operational LEAKAGE performance criterion in NEI 97-06, Steam Generator Program Guidelines (Ref. 4). The Steam Generator Program operational LEAKAGE performance criterion in NEI 97-06 states, "The RCS operational primary to secondary leakage through any one SG shall be limited to 150 gallons per day." The limit is based on operating experience with SG tube degradation mechanisms that result in tube leakage. The operational leakage rate criterion in conjunction with the implementation of the Steam Generator Program is an effective measure for minimizing the frequency of steam generator tube ruptures.

APPLICABILITY In MODES 1, 2, 3, and 4, the potential for RCPB LEAKAGE is greatest when the RCS is pressurized.

In MODES 5 and 6, LEAKAGE limits are not required because the reactor coolant pressure is far lower, resulting in lower stresses and reduced potentials for LEAKAGE.

FOR INFORMATION ONLY

RCS Operational LEAKAGE B 3.4.13 Davis-Besse B 3.4.13-4 Revision 32 BASES APPLICABILITY (continued)

LCO 3.4.14, "RCS Pressure Isolation Valve (PIV) Leakage," measures leakage through each individual PIV and can impact this LCO. Of the two PIVs in series in each isolated line, leakage measured through one PIV does not result in RCS LEAKAGE when the other is leaktight. If both valves leak and result in a loss of mass from the RCS, the loss must be included in the allowable identified LEAKAGE.

ACTIONS A.1 If pressure boundary LEAKAGE exists, the affected component, pipe, or vessel must be isolated from the RCS by a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. While in this condition, structural integrity of the system should be considered because the structural integrity of the part of the system within the isolation boundary must be maintained under all licensing basis conditions, including consideration of the potential for further degradation of the isolated location. Normal LEAKAGE past the isolation device is acceptable as it will limit RCS LEAKAGE and is included in identified or unidentified LEAKAGE. This action is necessary to prevent further deterioration of the RCPB.

B.1 If unidentified LEAKAGE or identified LEAKAGE are in excess of the LCO limits, the LEAKAGE must be reduced to within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This Completion Time allows time to verify leakage rates and either identify unidentified LEAKAGE or reduce LEAKAGE to within limits before the reactor must be shut down. This action is necessary to prevent further deterioration of the RCPB.

CB.1 and CB.2 If any pressure boundary LEAKAGE exists or primary to secondary LEAKAGE is not within limit, or any of the Required Actions and associated Completion Times cannot be met, if unidentified or identified LEAKAGE cannot be reduced to within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the reactor must be brought to lower pressure conditions to reduce the severity of the LEAKAGE and its potential consequences. The reactor must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This action reduces the LEAKAGE and also reduces the factors that tend to degrade the pressure boundary.

The Completion Times allowed are reasonable, based on operating experience, to reach the required conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 5, FOR INFORMATION ONLY

RCS Operational LEAKAGE B 3.4.13 Davis-Besse B 3.4.13-4 Revision 32 the pressure stresses acting on the RCPB are much lower and further deterioration is much less likely.

SURVEILLANCE SR 3.4.13.1 REQUIREMENTS Verifying RCS LEAKAGE within the LCO limits ensures that the integrity of the RCPB is maintained. Pressure boundary LEAKAGE would at first appear as unidentified LEAKAGE and can only be positively identified by inspection. Unidentified LEAKAGE and identified LEAKAGE are determined by performance of an RCS water inventory balance.

The RCS water inventory balance must be performed with the reactor at steady state operating conditions (stable temperature, power level, and pressurizer level). The accuracy of the results will be impacted if any FOR INFORMATION ONLY

RCS Operational LEAKAGE B 3.4.5 PERRY - UNIT 1 B 3.4-24 Revision No. 7 BASES (continued)

APPLICABLE The allowable RCS operational LEAKAGE limits are based on the SAFETY predicted and experimentally observed behavior of pipe cracks. The ANALYSES normally expected background LEAKAGE due to equipment design and the detection capability of the instrumentation for determining system LEAKAGE were also considered. The evidence from experiments suggests, for LEAKAGE even greater than the specified unidentified LEAKAGE limits, the probability is small that the imperfection or crack associated with such LEAKAGE would grow rapidly.

The unidentified LEAKAGE flow limit allows time for corrective action before the RCPB could be significantly compromised. The 5 gpm limit is a small fraction of the calculated flow from a critical crack in the primary system piping. Crack behavior from experimental programs (Refs. 4 and 5) shows leak rates of hundreds of gallons per minute will precede crack instability (Ref. 6).

The low limit on increase in unidentified LEAKAGE assumes a failure mechanism of intergranular stress corrosion cracking (IGSCC) that produces tight cracks. This flow increase limit is capable of providing an early warning of such deterioration.

No applicable safety analysis assumes the total LEAKAGE limit. The total LEAKAGE limit considers RCS inventory makeup capability and drywell floor drain sump capacity.

RCS operational LEAKAGE satisfies Criterion 2 of the NRC Final Policy Statement on Technical Specification Improvements (58 FR 39132).

LCO RCS operational LEAKAGE shall be limited to:

a.

Pressure Boundary LEAKAGE No pPressure boundary LEAKAGE is prohibited allowed, being indicative of material degradation. LEAKAGE of this type is unacceptable as the leak itself could cause further RCPB deterioration, resulting in higher LEAKAGE. Violation of this LCO could result in continued degradation of the RCPB. LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE.

(continued)

FOR INFORMATION ONLY

RCS Operational LEAKAGE B 3.4.5 PERRY - UNIT 1 B 3.4-25 Revision No. 1 BASES LCO

b.

Unidentified LEAKAGE (continued)

Five gpm of unidentified LEAKAGE is allowed as a reasonable minimum detectable amount that the drywell atmospheric monitoring, drywell floor drain sump level monitoring, and upper drywell air cooler condensate flow rate monitoring equipment can detect within a reasonable time period. Separating the sources of leakage (i.e.,

leakage from an identified source versus leakage from an unidentified source) is necessary for prompt identification of potentially adverse conditions, assessment of the safety significance, and corrective action. Violation of this LCO could result in continued degradation of the RCPB.

c.

Total LEAKAGE The total LEAKAGE limit is based on a reasonable minimum detectable amount. The limit also accounts for LEAKAGE from known sources (identified LEAKAGE). Violation of this LCO indicates an unexpected amount of LEAKAGE and, therefore, could indicate new or additional degradation in an RCPB component or system.

d.

Unidentified LEAKAGE Increase An unidentified LEAKAGE increase of > 2 gpm within the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period indicates a potential flaw in the RCPB and must be quickly evaluated to determine the source and extent of the LEAKAGE. The increase is measured relative to the steady state value; temporary changes in LEAKAGE rate as a result of transient conditions (e.g., startup) are not considered. As such, the 2 gpm increase limit is only applicable in MODE 1 when operating pressures and temperatures are established. Violation of this LCO could result in continued degradation of the RCPB.

APPLICABILITY In MODES 1, 2, and 3, the RCS operational LEAKAGE LCO applies because the potential for RCPB LEAKAGE is greatest when the reactor is pressurized.

In MODES 4 and 5, RCS operational LEAKAGE limits are not required since the reactor is not pressurized and stresses in the RCPB materials and potential for LEAKAGE are reduced.

(continued)

FOR INFORMATION ONLY

RCS Operational LEAKAGE B 3.4.5 PERRY - UNIT 1 B 3.4-26 Revision No. 1 BASES (continued)

ACTIONS A.1 If pressure boundary LEAKAGE exists, the affected component, pipe, or vessel must be isolated from the RCS by a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. While in this condition, structural integrity of the system should be considered because the structural integrity of the part of the system within the isolation boundary must be maintained under all licensing basis conditions, including consideration of the potential for further degradation of the isolated location. Normal LEAKAGE past the isolation device is acceptable as it will limit RCS LEAKAGE and is included in identified or unidentified LEAKAGE. This action is necessary to prevent further deterioration of the RCPB.

B.1 With RCS unidentified or total LEAKAGE greater than the limits, actions must be taken to reduce the LEAKAGE. Because the LEAKAGE limits are conservatively below the LEAKAGE that would constitute a critical crack size, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is allowed to reduce the LEAKAGE rates before the reactor must be shut down. If an unidentified LEAKAGE has been identified and quantified, it may be reclassified and considered as identified LEAKAGE. However, the total LEAKAGE limit would remain unchanged.

CB.1 An unidentified LEAKAGE increase of > 2 gpm within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period is an indication of a potential flaw in the RCPB and must be quickly evaluated. Although the increase does not necessarily violate the absolute unidentified LEAKAGE limit, certain susceptible components must be determined not to be the source of the LEAKAGE increase within the required Completion Time. For an unidentified LEAKAGE increase greater than required limits, an alternative to reducing LEAKAGE increase to within limits (i.e., reducing the leakage rate such that the current rate is less than the 2 gpm increase in the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; either by isolating the source or other possible methods) is to perform an evaluation to determine that the service sensitive Inconel 182 material in the nozzle welds of the reactor vessel, which is classified as non-resistant material to Intergranular Stress Corrosion Cracking (IGSCC), is not the source of the increased leakage.

The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time is needed to properly reduce the LEAKAGE increase or verify the source before the reactor must be shut down.

DC.1 and DC.2 FOR INFORMATION ONLY

RCS Operational LEAKAGE B 3.4.5 PERRY - UNIT 1 B 3.4-26 Revision No. 1 If any Required Action and associated Completion Time of Condition A or B is not met or if pressure boundary LEAKAGE exists, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within (continued)

FOR INFORMATION ONLY

RCS Operational LEAKAGE B 3.4.5 PERRY - UNIT 1 B 3.4-27 Revision No. 11 BASES ACTIONS DC.1 and DC.2 (continued) 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS The RCS LEAKAGE is monitored by a variety of instruments designed to quantify the various types of LEAKAGE. Leakage detection instrumentation is discussed in more detail in the Bases for LCO 3.4.7, "RCS Leakage Detection Instrumentation." Sump level and flow rate are typically monitored to determine actual LEAKAGE rates. However, any method may be used to quantify LEAKAGE within the guidelines of Reference 7. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

10 CFR 50.2.

2.

10 CFR 50.55a(c).

3.

10 CFR 50, Appendix A, GDC 55.

4.

GEAP-5620, Failure Behavior in ASTM A106B Pipes Containing Axial Through-Wall Flaws, April 1968.

5.

NUREG-75/067, Investigation and Evaluation of Cracking in Austenitic Stainless Steel Piping of Boiling Water Reactor Plants, October 1975.

6.

USAR, Section 5.2.5.5.3.

7.

Regulatory Guide 1.45, May 1973.

8.

Deleted.

FOR INFORMATION ONLY