Text

Application to Adopt TSTF-246, RTS Instrumentation, 3.3.1 Condition F Completion Time
	ML22083A224
Person / Time
Site:	Byron, Braidwood, Ginna
Issue date:	03/24/2022
From:	Lueshen K; Constellation Energy Generation
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-22-014
	Download: ML22083A224 (26)
	v • d • e

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-22-014 10 CFR 50.90 March 24, 2022 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

Subject:

Application to Adopt TSTF-246, RTS Instrumentation, 3.3.1 Condition F Completion Time" In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG), requests an amendment to the Technical Specifications (TS) for Braidwood Station, Byron Station, and R.E. Ginna Nuclear Power Plant. The proposed amendment is consistent with previously NRC-approved Industry/Technical Specifications Task Force Traveler 246 (TSTF-246), Revision 0, "RTS Instrumentation, 3.3.1 Condition F Completion Time" The proposed TS changes the completion time of the Limiting Conditions for Operation (LCO) 3.3.1 Condition F Bases and TS 3.3.1 from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . provides a description and assessment of the proposed change. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides TS Bases pages marked up to show the associated TS Bases changes and is provided for information only. Attachment 4 provides the revised (clean) TS pages.

The proposed change has been reviewed by the Plant Operations Review Committees at each station in accordance with the requirements of the CEG Quality Assurance Program.

CEG requests the approval of the proposed amendment by March 22, 2023. Once approved, the amendment shall be implemented within 60 days.

March 24, 2022 U.S. Nuclear Regulatory Commission Page 2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), CEG is notifying the State of Illinois and New York of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Officials.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Phillip A. Henderson at (630) 657-4727.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 24th day of March 2022.

Respectfully, Lueshen, Digitally signed by Lueshen, Kevin Kevin Date: 2022.03.24 12:33:50 -05'00' Kevin Lueshen Sr. Manager Licensing Constellation Energy Generation, LLC Attachments:

1. Description and Assessment 2a. Braidwood - Markup of Proposed Technical Specifications Pages 2b. Byron - Markup of Proposed Technical Specifications Pages 2c. Ginna - Markup of Proposed Technical Specifications Pages 3a. Braidwood - Markup of Proposed Technical Specifications Bases Pages (For Information Only) 3b. Byron - Markup of Proposed Technical Specifications Bases Pages (For Information Only) 3c. Ginna - Markup of Proposed Technical Specifications Bases Pages (For Information Only) 4a. Braidwood - Revised (Clean) Technical Specification Pages 4b. Byron - Revised (Clean) Technical Specification Pages 4c. Ginna - Revised (Clean) Technical Specification Pages cc: NRC Regional Administrator, Regions I and III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - R.E. Ginna Illinois Emergency Management Agency - Division of Nuclear Safety New York State Energy Research and Development Authority

ATTACHMENT 1 Description and Assessment

Subject:

Application to Adopt TSTF-246, RTS Instrumentation, 3.3.1 Condition F Completion Time"

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Summary of Approved Traveler Justification 2.2 Optional Changes and Variations 2.3 NRC Approval

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis 3.2 Conclusion

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

Page 1

ATTACHMENT 1 Description and Assessment

1.0 DESCRIPTION

Constellation Energy Generation, LLC (CEG), requests adoption of Technical Specifications Task Force Traveler 246 (TSTF-246), Revision 0, "RTS Instrumentation, 3.3.1 Condition F Completion Time," which is an approved change to the Improved Standard Technical Specifications (ISTS), into Braidwood Station (Braidwood), Units 1 and 2; Byron Station (Byron),

Units 1 and 2; and R.E. Ginna Nuclear Power Plant (Ginna); Technical Specifications (TS). The Technical Specifications (TS) related to RTS Instrumentation 3.3.1 Condition F are revised to incorporate TSTF-246.

The proposed TS changes the completion time of the Limiting Conditions for Operation (LCO) 3.3.1 Condition F Bases and TS 3.3.1 from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2.0 ASSESSMENT 2.1 Summary of Approved Traveler Justification This proposed change is acceptable for the following reasons: (a) adequate protection is still provided by the remaining intermediate range (IR) channel and the power range (PR) channels, (b) if the second IR channel is not available, Condition G would require no positive reactivity additions and reduction of power to below P-6 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and (c) the PR low setpoint is the safety analysis credited protection for power excursions between P-6 and P-10. If a PR low setpoint channel is not available, Condition E would require that channel to be placed in trip within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (or be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ) thus fulfilling the safety function for that PR channel. Furthermore, with one PR low setpoint channel inoperable the requirement to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is less restrictive than the TS requirement to increase power to above P-10 in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

In addition, a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is impractical for increasing power above P-10 depending on plant conditions at the time one channel was determined inoperable. (For example, a main feed pump (MFP) may be required to be in operation for reactor power to approach and increase above P-10, which in turn requires completion of MFP testing prior to it being placed in service.)

With the remaining IR and PR channels OPERABLE, the change from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable. If the remaining IR or any of the PR channels are inoperable, more restrictive action requirements apply. Therefore, a limit of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is conservative with respect to the previous version of the Standard Technical Specifications, while providing a more reasonable time frame for accomplishing the required action (i.e., a slow and controlled power adjustment above P-10 or below P-6, as the TS Bases state.)

2.2 Optional Changes and Variations TSTF-246 was developed using the previous version of the Standard Technical Specifications, NUREG-0452, Rev. 5, which was a draft based on the Comanche Peak original TS. The Braidwood, Byron, Ginna TS are based on the NUREG-1431, Standard Technical Specifications, Westinghouse Plant, Volume 1, Revision 5, dated September 2021 Page 2

ATTACHMENT 1 Description and Assessment (Reference 5) and therefore, the wording for Condition F varies from the approved traveler for Braidwood, Byron, and Ginna.

TSTF-246 TS 3.3.1 Condition F states:

THERMAL POWER > P-6 and < P-10, one Intermediate Range Neutron Flux Channel Braidwood and Byron TS 3.3.1 Condition F states:

One Intermediate Range Neutron Flux channel inoperable The Ginna TS differ from the standard NUREG-1431, Standard Technical Specifications, wording as follows:

The Condition for Intermediate Range Neutron Flux channel inoperable is Condition E and states "As required by Required Action A.1. and referenced by Table 3.3.1-1".

Required Action E.1 states "Reduce THERMAL POWER to <5E-11amps"; which, is the equivalent to the P-6 permissive used in TSTF-246.

Required Action E.1 states "Increase THERMAL POWER to >8% RTP"; which, is the equivalent to the P-10 permissive used in TSTF-246.

Required Action E.2 is modified by a Note which states that the option to increase THERMAL POWER is not allowed if both intermediate range channels are inoperable or if THERMAL POWER is < 5E-11 amps. This prevents the plant from increasing THERMAL POWER when the trip capability of the Intermediate Range Neutron Flux trip Function is not available.

Ginna does not have an equivalent Condition G for two Intermediate Range channels inoperable.

These differences are administrative in nature and do not affect the applicability of TSTF-246 to the Braidwood, Byron, and Ginna TS.

2.3 NRC Approval TSTF-246, Revision 0, was approved by the NRC as documented in a letter from William Beckner (NRC) to James Davis (NEI), dated March 22, 1999 (ADAMS Access No.

ML20204E965).

Page 3

ATTACHMENT 1 Description and Assessment

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Analysis Constellation Energy Generation, LLC (CEG), requests adoption of TSTF-246, "RTS Instrumentation, 3.3.1 Condition F Completion Time". The Technical Specifications (TS) related to RTS Instrumentation, 3.3.1 Condition F are revised to incorporate TSTF-246.

Title 10 of the Code of Federal Regulations (10 CFR), 10 CFR 50.36(c)(2), states: Limiting conditions for operation. (i) Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

There will be no changes to the plant design or operation such that compliance with the regulatory requirements and guidance document above would come into question. The plant and its systems will continue to comply with all applicable regulatory requirements. The proposed changes are consistent with NUREG-1431.

CEG has evaluated whether or not 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 change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed changes to the Completion Times does not increase the probability of an accident. The proposed changes to the Completion Times does not change how the plant would mitigate an accident previously evaluated. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed changes do not have any impact on the integrity of any plant system, structure, or component that initiates an analyzed event. The proposed changes will not alter the operation of, or otherwise increase the failure probability of any plant equipment that initiates an analyzed accident. Thus, the probability of any accident previously evaluated is not significantly increased.

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

Response: No The proposed changes to the Completion Times do not degrade the availability or capability of safety related equipment, and therefore do not create the possibility of a new or different kind of accident from any accident previously evaluated. The loss of function of any specific component will continue to be addressed in the applicable TS Page 4

ATTACHMENT 1 Description and Assessment LCO and plant configuration will be governed by the required actions of those LCOs.

There are no design changes associated with the proposed changes, and the changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed). The changes do not alter assumptions made in the safety analysis, and are consistent with the safety analysis assumptions and current plant operating practice.

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 change involve a significant reduction in a margin of safety?

Response: No The proposed changes do not affect the safety analysis acceptance criteria for any analyzed event, nor is there a change to any safety analysis limit. The proposed changes do not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined, nor is there any adverse effect on those plant systems necessary to assure the accomplishment of protection functions. The proposed changes will not result in plant operation in a configuration outside the design basis.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

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

4.0 ENVIRONMENTAL CONSIDERATION

CEG has determined that the proposed amendment 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, "Standards for Protection Against Radiation." However, the proposed amendment does not involve: (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory Page 5

ATTACHMENT 1 Description and Assessment actions eligible for categorical exclusion or otherwise not requiring environmental review,"

paragraph (c)(9). Therefore, pursuant to 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

5.0 REFERENCES

1. Letter from the U.S. Nuclear Regulatory Commission to NEI dated March 22, 1999 (ADAMS Access No. ML ML20204E965).

2. TSTF-246-A, "RTS Instrumentation, 3.3.1 Condition F Completion Time," Revision 0.

3. McGuire 1/2 - Issuance of Amendments 248/228 RE Reactor Trip System and Engineered Safety Features Actuation System Completion Times, Bypass Test Times and Surveillance Test Intervals (TAC Nos. MD7720 and MD7721)(ADAMS Access No. ML073480445).

4. Joseph M. Farley Nuclear Plant, Units 1 and 2 RE: Issuance of Amendments RE: Revised Technical Specification to Extend Reactor Trip System and Engineered Safety Features Actuation System Completion Times, Bypass Test Times, and Surveillance Test Intervals (TAC NOS. MD8135 and MD8136)(ADAMS Access No. ML083450588).

5. NUREG-1431, Standard Technical Specifications, Westinghouse Plant, Volume 1, Revision 5, dated September 2021.

Page 6

ATTACHMENT 2a BRAIDWOOD STATION, UNITS 1 AND 2 DOCKET NOS. 50-456 AND 50-457 RENEWED FACILITY OPERATING LICENSE NOS. NPF-72 AND NPF-77 APPLICATION TO ADOPT TSTF-246, "RTS INSTRUMENTATION, 3.3.1 CONDITION F COMPLETION TIME" Braidwood Proposed Technical Specifications Changes MARKED-UP TS PAGE 3.3.1-5

RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One Intermediate Range F.1 Reduce THERMAL POWER 242 hours0.0028 days 0.0672 hours 4.001323e-4 weeks 9.2081e-5 months Neutron Flux channel to P-6.

inoperable.

OR F.2 Increase THERMAL 242 hours0.0028 days 0.0672 hours 4.001323e-4 weeks 9.2081e-5 months POWER to P-10.

G. Two Intermediate Range G.1 Suspend operations Immediately Neutron Flux channels involving positive inoperable. reactivity additions.

AND G.2 Reduce THERMAL POWER 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to < P-6.

H. One Source Range H.1 Suspend operations Immediately Neutron Flux channel involving positive inoperable. reactivity additions.

I. Two Source Range I.1 Open Reactor Trip Immediately Neutron Flux channels Breakers (RTBs).

inoperable.

J. One Source Range J.1 Restore channel to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Neutron Flux channel OPERABLE status.

inoperable.

OR J.2.1 Initiate action to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months fully insert all rods.

AND J.2.2 Place the Rod Control 49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months System in a condition incapable of rod withdrawal.

(continued)

BRAIDWOOD UNITS 1 & 2 3.3.1 5 Amendment 169

ATTACHMENT 2b BYRON STATION, UNITS 1 AND 2 DOCKET NOS. 50-454 AND 50-455 RENEWED FACILITY OPERATING LICENSE NOS. NPF-37 AND NPF-66 APPLICATION TO ADOPT TSTF-246, "RTS INSTRUMENTATION, 3.3.1 CONDITION F COMPLETION TIME" Byron Proposed Technical Specifications Changes MARKED-UP TS PAGE 3.3.1-4

RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One Intermediate Range F.1 Reduce THERMAL POWER 242 hours0.0028 days 0.0672 hours 4.001323e-4 weeks 9.2081e-5 months Neutron Flux channel to P-6.

inoperable.

OR F.2 Increase THERMAL 242 hours0.0028 days 0.0672 hours 4.001323e-4 weeks 9.2081e-5 months POWER to P-10.

G. Two Intermediate Range G.1 Suspend operations Immediately Neutron Flux channels involving positive inoperable. reactivity additions.

AND G.2 Reduce THERMAL POWER 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to < P-6.

H. One Source Range H.1 Suspend operations Immediately Neutron Flux channel involving positive inoperable. reactivity additions.

I. Two Source Range I.1 Open Reactor Trip Immediately Neutron Flux channels Breakers (RTBs).

inoperable.

(continued)

BYRON UNITS 1 & 2 3.3.1 4 Amendment 186

ATTACHMENT 2c R.E. GINNA NUCLEAR POWER PLANT ,

UNIT 1 DOCKET NO. 50-244 RENEWED FACILITY OPERATING LICENSE NO. DPR-18 APPLICATION TO ADOPT TSTF-246, "RTS INSTRUMENTATION, 3.3.1 CONDITION F COMPLETION TIME" R.E. Ginna Proposed Technical Specifications Changes MARKED-UP TS PAGE 3.3.1-2

RTS Instrumentation 3.3.1 CONDITION REQUIRED ACTION COMPLETION TIME D. As required by Required D.1 Action A.1 and referenced by Table 3.3.1-1. - NOTE -

1. For Functions 2a, 2b, 5, 6, 7b, 8, and 13, one channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing.

2. The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

Place channel in trip. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months E. As required by Required E.1 Reduce THERMAL POWER 242 hours0.0028 days 0.0672 hours 4.001323e-4 weeks 9.2081e-5 months Action A.1 and referenced to < 5E-11 amps.

by Table 3.3.1-1.

OR E.2

- NOTE -

Required Action E.2 is not applicable when:

a. Two channels are inoperable, or

b. THERMAL POWER is

< 5E-11 amps.

Increase THERMAL 242 hours0.0028 days 0.0672 hours 4.001323e-4 weeks 9.2081e-5 months POWER to 8% RTP.

F. As required by Required F.1 Open RTBs and RTBBs Immediately upon Action A.1 and referenced upon discovery of two discovery of two by Table 3.3.1-1. inoperable channels. inoperable channels AND R.E. Ginna Nuclear Power Plant 3.3.1-2 Amendment 144

ATTACHMENT 3a BRAIDWOOD STATION, UNITS 1 AND 2 DOCKET NOS. 50-456 AND 50-457 RENEWED FACILITY OPERATING LICENSE NOS. NPF-72 AND NPF-77 APPLICATION TO ADOPT TSTF-246, "RTS INSTRUMENTATION, 3.3.1 CONDITION F COMPLETION TIME" Braidwood Proposed Technical Specifications Bases Changes (for information only)

MARKED-UP TS BASES PAGE B 3.3.1-45

RTS Instrumentation B 3.3.1 BASES ACTIONS (continued)

Functions. If THERMAL POWER is greater than the P-6 setpoint but less than the P-10 setpoint, 242 hours0.0028 days 0.0672 hours 4.001323e-4 weeks 9.2081e-5 months is allowed to reduce THERMAL POWER below the P-6 setpoint or increase to THERMAL POWER above the P-10 setpoint. The provisions of LCO 3.0.4 allow entry into a MODE or other specified condition in the Applicability as directed by the Required Actions. Therefore, a MODE change is permitted with one channel inoperable whenever Required Action F.2 is used. The NIS Intermediate Range Neutron Flux channels must be OPERABLE when the power level is above the capability of the source range, P-6, and below the capability of the power range, P-10. If THERMAL POWER is greater than the P-10 setpoint, the NIS power range detectors perform the monitoring and protection functions and the intermediate range is not required. The Completion Times allow for a slow and controlled power adjustment above P-10 or below P-6 and take into account the redundant capability afforded by the redundant OPERABLE channel, and the low probability of its failure during this period. This action does not require the inoperable channel to be tripped because the Function uses one-out-of-two logic. Tripping one channel would trip the reactor. Thus, the Required Actions specified in this Condition are only applicable when channel failure does not result in reactor trip.

G.1 and G.2 Condition G applies to two inoperable Intermediate Range Neutron Flux trip channels in MODE 2 when THERMAL POWER is above the P-6 setpoint and below the P-10 setpoint.

Required Actions specified in this Condition are only applicable when channel failures do not result in reactor trip. Above the P-6 setpoint and below the P-10 setpoint, the NIS intermediate range detector performs the monitoring Functions. With no intermediate range channels OPERABLE, the Required Actions are to suspend operations involving positive reactivity additions immediately. This will preclude any power level increase since there are no OPERABLE Intermediate Range Neutron Flux channels. The operator must also reduce THERMAL POWER below the P-6 setpoint within two hours. Below P-6, the Source Range Neutron Flux channels will be able to monitor the core power level. The Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months will allow a slow and controlled power reduction to less than the P-6 setpoint and takes into account the low probability of occurrence of an event during this period that may require the protection afforded by the NIS Intermediate Range Neutron Flux trip.

BRAIDWOOD UNITS 1 & 2 B 3.3.1 45 Revision 88

ATTACHMENT 3b BYRON STATION, UNITS 1 AND 2 DOCKET NOS. 50-454 AND 50-455 RENEWED FACILITY OPERATING LICENSE NOS. NPF-37 AND NPF-66 APPLICATION TO ADOPT TSTF-246, "RTS INSTRUMENTATION, 3.3.1 CONDITION F COMPLETION TIME" Byron Proposed Technical Specifications Bases Changes (for information only)

MARKED-UP TS BASES PAGES B 3.3.1-42

RTS Instrumentation B 3.3.1 BASES ACTIONS (continued)

The Required Action is modified by a Note that allows placing one channel in bypass for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while performing surveillance testing.

When surveillance testing is performed under the Required Action Note, the appropriate TS Condition is entered, and the Required Action Note is applied, allowing an inoperable channel to be placed in bypass for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The Completion Time starts after the time in the Required Action Note expires, providing the equipment remains removed from service or bypassed. If the surveillance time exceeds 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the Required Action would have to be performed (e.g., place channel in trip within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .) In addition, if a channel is discovered inoperable, the channel may be placed in a bypass condition during troubleshooting prior to expiration of the appropriate TS Condition Required Action Completion Time to place the channel in trip. The 12-hour time limit is justified in Reference 13.

F.1 and F.2 Condition F applies to the Intermediate Range Neutron Flux trip when THERMAL POWER is above the P-6 setpoint and below the P-10 setpoint and one channel is inoperable. Above the P-6 setpoint and below the P-10 setpoint, the NIS intermediate range detector performs the monitoring Functions. If THERMAL POWER is greater than the P-6 setpoint but less than the P-10 setpoint, 242 hours0.0028 days 0.0672 hours 4.001323e-4 weeks 9.2081e-5 months is allowed to reduce THERMAL POWER below the P-6 setpoint or increase to THERMAL POWER above the P-10 setpoint. The provisions of LCO 3.0.4 allow entry into a MODE or other specified condition in the Applicability as directed by the Required Actions. Therefore, a MODE change is permitted with one channel inoperable whenever Required Action F.2 is used. The NIS Intermediate Range Neutron Flux channels must be BYRON UNIT 1 & 2 B 3.3.1 42 Revision 115

ATTACHMENT 3c R.E. GINNA NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-244 RENEWED FACILITY OPERATING LICENSE NO. DPR-18 APPLICATION TO ADOPT TSTF-246, "RTS INSTRUMENTATION, 3.3.1 CONDITION F COMPLETION TIME" R.E. Ginna Proposed Technical Specifications Bases Changes (for information only)

MARKED-UP TS BASES PAGES B 3.3.1-31

RTS Instrumentation B 3.3.1

Overtemperature T;

Overpower T;

Pressurizer Pressure-High;

Pressurizer Water Level-High; and

SG Water Level-Low Low.

With one channel inoperable, the channel must be restored to OPERABLE status or placed in the tripped condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Placing the channel in the tripped condition results in a partial trip condition. For the Power Range Neutron Flux-High, Power Range Neutron Flux-Low, Overtemperature T, and Overpower T functions, this results in a one-out-of-three logic for actuation. For the Pressurizer Pressure-High and Pressurizer Water Level-High Functions, this results in a one-out-of two logic for actuation. For the SG Water Level-Low Low Function, this results in a one-out-of-two logic per each affected SG for actuation. The 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed to place the inoperable channel in the tripped condition is consistent with References 11 and 13.

Troubleshooting, corrective maintenance, and post maintenance re-testing can be performed in bypass within the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time specified for functions with installed bypass capability. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months clock starts as soon as the action statement is entered and does not include the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed for surveillance testing in bypass.

The Required Actions have been modified by two Notes. Note 1 allows bypassing a channel for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing for Functions 2a, 2b, 5, 6, 7b, 8, and 13. Note 2 allows placing the inoperable channel in the bypass condition for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while performing surveillance testing of other channels. This includes placing the inoperable channel in the bypass condition to allow setpoint adjustments of other channels when required to reduce the setpoint in accordance with other Technical Specifications. This 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is applied to each of the remaining OPERABLE channels. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time limit is consistent with References 11 and 13.

E.1 and E.2 Condition E applies to the Intermediate Range Neutron Flux trip Function when THERMAL POWER is below 6% RTP and one channel is inoperable. Below the P-10 setpoint, the NIS intermediate range detector performs a monitoring and protection function. With one NIS intermediate range channel inoperable, 242 hours0.0028 days 0.0672 hours 4.001323e-4 weeks 9.2081e-5 months is allowed to either reduce THERMAL POWER below 5E-11amps or increase THERMAL POWER above 8% RTP. If THERMAL POWER is greater than the P-10 setpoint, the NIS power range detectors perform the monitoring and protection functions and the intermediate range is not required. The Completion Times allow for a slow and controlled power adjustment above 8% RTP or below 5E-11amps and take into account the redundant capability afforded by the redundant OPERABLE channel, and the low R.E. Ginna Nuclear Power Plant B 3.3.1-31 Revision 102

ATTACHMENT 4a BRAIDWOOD STATION, UNITS 1 AND 2 DOCKET NOS. 50-456 AND 50-457 RENEWED FACILITY OPERATING LICENSE NOS. NPF-72 AND NPF-77 APPLICATION TO ADOPT TSTF-246, "RTS INSTRUMENTATION, 3.3.1 CONDITION F COMPLETION TIME" Braidwood Proposed Technical Specifications Changes REVISED (CLEAN) TS PAGE 3.3.1-5

RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One Intermediate Range F.1 Reduce THERMAL POWER 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Neutron Flux channel to P-6.

inoperable.

OR F.2 Increase THERMAL 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months POWER to P-10.

G. Two Intermediate Range G.1 Suspend operations Immediately Neutron Flux channels involving positive inoperable. reactivity additions.

AND G.2 Reduce THERMAL POWER 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to < P-6.

H. One Source Range H.1 Suspend operations Immediately Neutron Flux channel involving positive inoperable. reactivity additions.

I. Two Source Range I.1 Open Reactor Trip Immediately Neutron Flux channels Breakers (RTBs).

inoperable.

J. One Source Range J.1 Restore channel to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Neutron Flux channel OPERABLE status.

inoperable.

OR J.2.1 Initiate action to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months fully insert all rods.

AND J.2.2 Place the Rod Control 49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months System in a condition incapable of rod withdrawal.

(continued)

BRAIDWOOD UNITS 1 & 2 3.3.1 5 Amendment xx

ATTACHMENT 4b BYRON STATION, UNITS 1 AND 2 DOCKET NOS. 50-454 AND 50-455 RENEWED FACILITY OPERATING LICENSE NOS. NPF-37 AND NPF-66 APPLICATION TO ADOPT TSTF-246, "RTS INSTRUMENTATION, 3.3.1 CONDITION F COMPLETION TIME" Byron Proposed Technical Specifications Changes REVISED (CLEAN) TS PAGE 3.3.1-4

RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One Intermediate Range F.1 Reduce THERMAL POWER 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Neutron Flux channel to P-6.

inoperable.

OR F.2 Increase THERMAL 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months POWER to P-10.

G. Two Intermediate Range G.1 Suspend operations Immediately Neutron Flux channels involving positive inoperable. reactivity additions.

AND G.2 Reduce THERMAL POWER 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to < P-6.

H. One Source Range H.1 Suspend operations Immediately Neutron Flux channel involving positive inoperable. reactivity additions.

I. Two Source Range I.1 Open Reactor Trip Immediately Neutron Flux channels Breakers (RTBs).

inoperable.

(continued)

BYRON UNITS 1 & 2 3.3.1 4 Amendment XXX

ATTACHMENT 4c R.E. GINNA NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-244 RENEWED FACILITY OPERATING LICENSE NO. DPR-18 APPLICATION TO ADOPT TSTF-246, "RTS INSTRUMENTATION, 3.3.1 CONDITION F COMPLETION TIME" R.E. Ginna Proposed Technical Specifications Changes REVISED (CLEAN) TS PAGE 3.3.1-2

RTS Instrumentation 3.3.1 CONDITION REQUIRED ACTION COMPLETION TIME D. As required by Required D.1 Action A.1 and referenced by Table 3.3.1-1. - NOTE -

1. For Functions 2a, 2b, 5, 6, 7b, 8, and 13, one channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing.

2. The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

Place channel in trip. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months E. As required by Required E.1 Reduce THERMAL POWER 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and referenced to < 5E-11 amps.

by Table 3.3.1-1.

OR E.2

- NOTE -

Required Action E.2 is not applicable when:

a. Two channels are inoperable, or

b. THERMAL POWER is

< 5E-11 amps.

Increase THERMAL 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months POWER to 8% RTP.

F. As required by Required F.1 Open RTBs and RTBBs Immediately upon Action A.1 and referenced upon discovery of two discovery of two by Table 3.3.1-1. inoperable channels. inoperable channels AND R.E. Ginna Nuclear Power Plant 3.3.1-2 Amendment

RS-22-014, Application to Adopt TSTF-246, RTS Instrumentation, 3.3.1 Condition F Completion Time

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RS-22-014, Application to Adopt TSTF-246, RTS Instrumentation, 3.3.1 Condition F Completion Time

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Subject:

Subject:

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3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

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4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

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