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Changes Related to AP1000 Gts Subsection 3.3.14, ESFAS Spent Fuel Pool Level Instrumentation
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GTST AP1000-O67-3.3.14, Rev. 1 Advanced Passive 1000 (AP1000)

Generic Technical Specification Traveler (GTST)

Title:

Changes Related to LCO 3.3.14, Engineered Safety Feature Actuation System (ESFAS) Spent Fuel Pool Level Instrumentation I. Technical Specifications Task Force (TSTF) Travelers, Approved Since Revision 2 of STS NUREG-1431, and Used to Develop this GTST TSTF Number and

Title:

TSTF-411-A, Rev 1, Surveillance Test Interval Extensions for Components of the Reactor Protection System (WCAP-15376-P)

TSTF-418-A, Rev 2, RPS and ESFAS Test Times and Completion Times (WCAP-14333)

TSTF-519-T, Rev 0, Increase Standardization in Condition and Required Action Notes STS NUREGs Affected:

TSTF-411-A, Rev 1: NUREG 1431 TSTF-418-A, Rev 2: NUREG 1431 TSTF-519-T, Rev 0: NUREG 1430 and 1431 NRC Approval Date:

TSTF-411-A, Rev 1: 30-Aug-02 TSTF-418-A, Rev 2: 02-Apr-03 TSTF-519-T, Rev 0: 16-Oct-09 (TSTF Review)

TSTF Classification:

TSTF-411-A, Rev 1: Technical Change TSTF-418-A, Rev 2: Technical Change TSTF-519-T, Rev 0: NUREG Only Change Date report generated:

Monday, June 29, 2015 Page 1

GTST AP1000-O67-3.3.14, Rev. 1 II. Reference Combined License (RCOL) Standard Departures (Std. Dep.), RCOL COL Items, and RCOL Plant-Specific Technical Specifications (PTS) Changes Used to Develop this GTST RCOL Std. Dep. Number and

Title:

There are no Vogtle Electric Generating Plant Units 3 and 4 (Vogtle or VEGP) departures applicable to GTS 3.3.2.

RCOL COL Item Number and

Title:

There are no Vogtle COL items applicable to GTS 3.3.2.

RCOL PTS Change Number and

Title:

The VEGP License Amendment Request (LAR) proposed the following changes to the initial version of the PTS (referred to as the current TS by the VEGP LAR). These changes include Administrative Changes (A), Detail Removed Changes (D), Less Restrictive Changes (L), and More Restrictive Changes (M). These changes are discussed in Sections VI and VII of this GTST.

VEGP LAR DOC A028: Reformat of GTS 3.3.2 into Nine Parts; 3.3.8 through 3.3.16; note that this maps GTS 3.3.2 requirements into interim A028-modified TS (MTS) Subsection 3.3.14, to which the other changes are applied.

VEGP LAR DOC A025: SR text phrase change from the prescribed values to within limits.

VEGP LAR DOC M02: Provision for Two or More Inoperable Divisions or Channels Date report generated:

Monday, June 29, 2015 Page 2

GTST AP1000-O67-3.3.14, Rev. 1 III. Comments on Relations Among TSTFs, RCOL Std. Dep., RCOL COL Items, and RCOL PTS Changes This section discusses the considered changes that are: (1) applicable to operating reactor designs, but not to the AP1000 design; (2) already incorporated in the GTS; or (3) superseded by another change.

TSTF-411-A, Rev.1 provides justification to (1) increase the required action completion time and the bypass test time allowance for the reactor trip breakers and (2) increase the surveillance test intervals for the reactor trip breakers, master relays, logic cabinets, and analog channels based on analysis provided in WCAP-15376-P, Rev. 0, Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times.

WCAP-15376-P, Rev. 0 did not specifically consider the AP1000 design. The AP1000 GTS completion times and surveillance frequencies for instrumentation functions and reactor trip breakers were justified by APP-GW-GSC-020 (WCAP-16787), which is listed as Reference 6 in the GTS Subsection 3.3.2 Bases. Therefore, TSTF-411-A is not applicable to the AP1000 STS, and is not discussed further in this GTST.

TSTF-418-A adjusts the WOG STS (NUREG-1431) required action completion times for the conventional Westinghouse Plant Protection System instrumentation design for which the WOG STS instrumentation requirements are applicable. The changes in TSTF-418 are based on the analysis in WCAP-14333-P, which did not consider the AP1000 protection and safety monitoring system (PMS) instrumentation design. The AP1000 GTS required action completion times (and surveillance frequencies) for the PMS were justified by APP-GW-GSC-020 (WCAP-16787),

which is listed as Reference 6 in the GTS Subsection 3.3.2 Bases. APP-GW-GSC-020 does not reference WCAP-14333-P, but notes, the AP1000 protection and safety monitoring system (PMS) redundancy is as good as or better than that of the conventional Westinghouse Plant Protection System. Although the PMS equipment reliability is considered to be equivalent to or better than that of the conventional Westinghouse Plant Protection System, a common basis for comparison to the digital portion of the PMS is not readily available.

TSTF-519-T has already been incorporated into the AP1000 GTS regarding the Writer's Guide for Improved Standard Technical Specifications (Reference 4) placement of Notes in TS Actions tables.

Date report generated:

Monday, June 29, 2015 Page 3

GTST AP1000-O67-3.3.14, Rev. 1 IV. Additional Changes Proposed as Part of this GTST (modifications proposed by NRC staff and/or clear editorial changes or deviations identified by preparer of GTST)

In the MTS 3.3.14 Actions section of the Bases, the phrase ...then all affected Functions provided by that channel must be declared inoperable... is revised to ...then all affected protection Functions supported by or dependent on that channel must be declared inoperable...

APOG Recommended Changes to Improve the Bases In the Surveillance Requirements section of the Bases for STS Subsection 3.3.8 under the heading SR 3.3.8.2, the next to last paragraph, last line uses the phrase integrated protection cabinets. The Bases for SR 3.3.8.3, first paragraph uses the term IPC, which is the acronym for integrated protection cabinets. The SR 3.3.8.2 Bases should be changed from integrated protection cabinets to integrated protection cabinets (IPCs). This change also applies to Section 3.3.10 (SR 3.3.10.2), Section 3.3.11 (SR 3.3.11.2), Section 3.3.13 (SR 3.3.13.2), and Section 3.3.14 (SR 3.3.14.2). Add the acronym (IPCs) after the words integrated protection cabinets in SR 3.3.8.2 (and other SRs identified above). Use PMS everywhere following its initial definition and in Bases for SR 3.3.14.2 and SR 3.3.14.3 the phrase allowed tolerance is changed to allowed as-left tolerance (APOG Comment and NRC Staff Edit).

The SRs section of the Bases under the heading SR 3.3.14.2, uses the term ESF. ESF -

Engineered Safety Features - has not been previously defined. Change ESF to Engineered Safety Features (ESF).

Throughout the Bases, references to Sections and Chapters of the FSAR do not include the FSAR clarifier. Since these Section and Chapter references are to an external document, it is appropriate to include the FSAR modifier. (DOC A003)

Date report generated:

Monday, June 29, 2015 Page 4

GTST AP1000-O67-3.3.14, Rev. 1 V. Applicability Affected Generic Technical Specifications and Bases:

Section 3.3.14, Engineered Safety Feature Actuation System (ESFAS) Spent Fuel Pool Level Instrumentation Changes to the Generic Technical Specifications and Bases:

GTS 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, is reformatted by DOC A028 into multiple Specifications including interim A028-modified TS (MTS) 3.3.14, Engineered Safety Feature Actuation System (ESFAS) Spent Fuel Pool Level Instrumentation. The reformatting relocates GTS 3.3.2 Function 24.a, Spent Fuel Pool Level - Low, into MTS 3.3.14 as part of the LCO statement. The MTS format is depicted in Section XI of this GTST as the reference case in the markup of the GTST instrumentation requirements for spent fuel pool level instrumentation.

MTS 3.3.14 LCO Title GTS 3.3.2 Function Engineered Safety Feature 24. Refueling Cavity Isolation Actuation System (ESFAS) Spent a. Spent Fuel Pool Fuel Pool Level Instrumentation Level - Low References 2, 3, and 6 provide details showing the correspondence of GTS 3.3.2 Functions and STS 3.3.8 through 3.3.16 Functions.

GTS 3.3.2 Conditions H and P are reordered and relabeled as AP1000 MTS 3.3.14 Conditions A and B. (DOC A028)

GTS SR 3.3.2.1, SR 3.3.2.4, SR 3.3.2.5, SR 3.3.2.6 are retained and renumbered as MTS SR 3.3.14.1, SR 3.3.14.3, SR 3.3.14.2, and SR 3.3.14.4, respectively. (DOC A028)

MTS 3.3.14 Condition B is revised by adding a second condition statement for inoperability of two or more channels. Otherwise, LCO 3.0.3 would apply when the LCO is not met and the associated Actions are not met or an associated Action is not provided. (DOC M02)

MTS SR 3.3.14.3 Note is revised from ...adjusted to the prescribed values. to ... adjusted to within limits. This change is made for clarity and consistency. (DOC A025)

The following tables are provided as an aid to tracking the various changes to GTS 3.3.2 Conditions, Required Actions, Functions, Applicability Footnotes, and Surveillance Requirements that result in interim A028-modified TS (MTS) 3.3.14 and as further changed, STS 3.3.14.

Date report generated:

Monday, June 29, 2015 Page 5

GTST AP1000-O67-3.3.14, Rev. 1 Changes to Conditions GTS 3.3.2 MTS 3.3.14 STS 3.3.14 Other STS Subsections Additional Condition Condition Condition Addressing the Listed Condition DOC Changes A 3.3.8, 3.3.9, 3.3.10 ---

B 3.3.8 ---

C 3.3.10 ---

D 3.3.12, 3.3.15 ---

E 3.3.9 ---

F 3.3.13 ---

G 3.3.9, 3.3.13, 3.3.16 ---

H A A 3.3.11 ---

I 3.3.8 ---

J 3.3.8 ---

K 3.3.13 ---

L 3.3.8 ---

M 3.3.8, 3.3.12 ---

N 3.3.8, 3.3.9, 3.3.11 ---

O 3.3.9, 3.3.13, 3.3.15 ---

P B B 3.3.8 M02 Q 3.3.8, 3.3.9 ---

R 3.3.8, 3.3.9 ---

S 3.3.8, 3.3.9 ---

T 3.3.8 ---

U 3.3.9 ---

V 3.3.8 ---

W 3.3.16 ---

X 3.3.8, 3.3.9 ---

Y 3.3.8, 3.3.9, 3.3.10 ---

Z 3.3.8 ---

AA 3.3.10 ---

BB 3.3.10 ---

CC 3.3.8, 3.3.9 ---

Changes to Functions (a complete function list appears in GTST AP1000-O61-3.3.8)

Function [Modes(footnote)] ----------- STS 3.3.14 Other STS Subsections Additional GTS 3.3.2 MTS 3.3.14 STS 3.3.14 Conditions and Additional Changes DOC Changes 24.a [6] LCO 3.3.14 LCO 3.3.14 A, B --- M02 Changes to Applicability Footnotes None Changes to Surveillance Requirements GTS 3.3.2 MTS 3.3.14 STS 3.3.14 STS Subsections Also Example Surveillance No.

SR SR SR Addressing the Listed SR Surveillance Description 3.3.2.1 3.3.14.1 3.3.14.1 3.3.8, 3.3.10, 3.3.11, 3.3.13 3.3.8.1 CHANNEL CHECK 3.3.2.2 3.3.15, 3.3.16 3.3.15.1 ACTUATION LOGIC TEST 3.3.2.3 3.3.9, 3.3.12 3.3.9.1 TRIP ACTUATING DEVICE OPERATIONAL TEST 3.3.2.4 3.3.14.3 3.3.14.3 3.3.8, 3.3.10, 3.3.11, 3.3.13 3.3.8.3 CHANNEL CALIBRATION 3.3.2.5 3.3.14.2 3.3.14.2 3.3.8, 3.3.10, 3.3.11, 3.3.13 3.3.8.2 CHANNEL OPERATIONAL TEST 3.3.2.6 3.3.14.4 3.3.14.4 3.3.8, 3.3.10, 3.3.11, 3.3.13 3.3.8.4 ESF RESPONSE TIME 3.3.2.7 3.3.8, 3.1.9, 3.5.2, 3.5.4, 3.5.6, 3.6.10, 3.7.7 ACTUATION DEVICE TEST*

3.3.2.8 3.3.8, 3.4.11, 3.4.13 Squib Valve ACTUATION DEVICE TEST 3.3.2.9 3.3.15, 3.3.16 Pressurizer Heater ACTUATION DEVICE TEST Date report generated:

Monday, June 29, 2015 Page 6

GTST AP1000-O67-3.3.14, Rev. 1

Typically, the associated STS system specification or STS 3.3.15 or 3.3.16 will include a SR for the actuation device, as follows: Verify [tested required component] actuates to the [required position or state] on an actual or simulated actuation signal. Such SRs overlap with the Actuation Logic Test for complete testing of the actuation device. (DOC L01)

The discussion in the Surveillance Requirements section of the Bases under the headings SR 3.3.14.2 and SR 3.3.14.3 is revised for clarity and consistency. (APOG Comment and NRC Staff Edit)

The acronym FSAR is added to modify Section and Chapter in references to the FSAR throughout the Bases. (DOC A003) (APOG Comment)

Date report generated:

Monday, June 29, 2015 Page 7

GTST AP1000-O67-3.3.14, Rev. 1 VI. Traveler Information Description of TSTF changes:

Not Applicable Rationale for TSTF changes:

Not Applicable Description of changes in RCOL Std. Dep., RCOL COL Item(s), and RCOL PTS Changes:

The Vogtle Electric Generating Plant Units 3 and 4 (VEGP) technical specifications upgrade (TSU) License Amendment Request (VEGP TSU LAR) (Reference 2) proposed changes to the initial version of the VEGP PTS (referred to as the current TS by the VEGP TSU LAR). As detailed in VEGP TSU LAR Enclosure 1, administrative change number 28 (DOC A028) reformats PTS 3.3.2 into multiple Specifications as follows:

3.3.8, Engineered Safety Feature Actuation System (ESFAS) Instrumentation,

3.3.9, Engineered Safety Feature Actuation System (ESFAS) Manual Initiation,

3.3.10, Engineered Safety Feature Actuation System (ESFAS) Reactor Coolant System (RCS) Hot Leg Level Instrumentation,

3.3.11, Engineered Safety Feature Actuation System (ESFAS) Startup Feedwater Flow Instrumentation,

3.3.12, Engineered Safety Feature Actuation System (ESFAS) Reactor Trip Initiation,

3.3.13, Engineered Safety Feature Actuation System (ESFAS) Control Room Air Supply Radiation Instrumentation,

3.3.14, Engineered Safety Feature Actuation System (ESFAS) Spent Fuel Pool Level Instrumentation,

3.3.15, Engineered Safety Feature Actuation System (ESFAS) Actuation Logic -

Operating, and

3.3.16, Engineered Safety Feature Actuation System (ESFAS) Actuation Logic -

Shutdown.

Since PTS 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, is identical to GTS 3.3.2, it is appropriate for this GTST to consider the proposed changes to PTS 3.3.2 as changes to GTS 3.3.2 for incorporation in AP1000 STS 3.3.14. DOC A028 is extensive, but retains the intention of PTS 3.3.2 while improving operational use of the TS. The numerous Functions, Conditions and extensive bases discussion associated with PTS 3.3.2 are repackaged into nine smaller parts. Therefore, the changes implemented by DOC A028 are presented in the attached Subsection 3.3.14 markup, in Section XI of this GTST, as the clean starting point and are identified as interim A028-modified TS (MTS) 3.3.14. The specific details of the reformatting for MTS 3.3.14 can be found in VEGP TSU LAR (Reference 2), in (markup) and Enclosure 4 (clean). The NRC staff safety evaluation regarding DOC A028 can be found in Reference 3, VEGP LAR SER. The VEGP TSU LAR was modified in response to NRC staff RAIs in Reference 5 and the Southern Nuclear Operating Company RAI Response in Reference 6.

Date report generated:

Monday, June 29, 2015 Page 8

GTST AP1000-O67-3.3.14, Rev. 1 DOC A025 revises MTS 3.3.14 SR 3.3.14.3 Note to change the phrase the prescribed values to within limits.

DOC M02 addresses the fact that MTS 3.3.14, Engineered Safety Feature Actuation System (ESFAS) Spent Fuel Pool Level Instrumentation, does not specify Actions for inoperability of two or more channels, and that additional Actions are being proposed for AP1000 STS.

A more detailed description of the changes by each of the above DOCs can be found in Reference 2, VEGP TSU LAR in Enclosure 1; the NRC staff safety evaluation can be found in Reference 3, VEGP LAR SER. The VEGP TSU LAR was modified in response to NRC staff RAIs (Reference 5) by Southern Nuclear Operating Companys RAI Response in Reference 6.

Rationale for changes in RCOL Std. Dep., RCOL COL Item(s), and RCOL PTS Changes:

The reformatting per DOC A028, except where addressed in other DOCs, addresses inconsistencies in formatting and approach between PTS 3.3.1 and PTS 3.3.2, respectively.

Simplification and clarification are proposed for each Specification. In breaking down each PTS Specification into specific subsets of the Protection and Safety Monitoring System (PMS) function, improved human factored operator usability results.

These improvements also reflect the general approach currently in use in the Improved Standard Technical Specifications (STS) for Babcock and Wilcox Plants, NUREG-1430, Rev. 4.

That is to separate the functions for [sensor] instrumentation, Manual Actuation, Trip/Actuation Logic, and Trip Actuation Devices (e.g., Reactor Trip Breakers (RTBs)) into separate Specification subsections. Furthermore, the Actions for some ESFAS Functions generally involve a more complex presentation than needed for other Functions, such that simple common Actions are not reasonable. Such Functions are also provided with separate Specification subsections.

When TS instrument function tables are utilized to reference Actions, the generally preferred format of the Actions for an instrumentation Specification in NUREG-1430 is to provide the initial Actions that would be common to all of the specified functions (typically for bypassing and/or tripping one or two inoperable channels), then the default Action would direct consulting the function table for follow-on Actions applicable to the specific affected function. These follow-up Actions generally reflect the actions to exit the Applicability for that function.

This format also allows splitting the default Actions from the initial preferred actions. This general approach is the standard format for other Specifications and for Instrumentation Specifications for other vendors Improved STS.

DOC A025 is consistent with similar requirements elsewhere in the AP1000 GTS and STS (NUREG-1431).

GTS 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, does not specify Actions for inoperability of more than two inoperable automatic initiation channels; resulting in entry into LCO 3.0.3 when three or more channels are inoperable while in Modes 1, 2, 3, and 4, and entry into GTS LCO 3.0.8 while in Modes 4 and 5. DOC M02 provides new Conditions (in MTS 3.3.8 through MTS 3.3.16) to address inoperability of two or more than one ESFAS channels to avoid entry into LCO 3.0.3 or GTS LCO 3.0.8 (deleted by DOC L05). Since MTS 3.3.14, Engineered Safety Feature Actuation System (ESFAS) Spent Fuel Pool Level Instrumentation, is only applicable in Mode 6, LCO 3.0.3 is not a factor. However, DOC M02 addresses the lack of specified Actions when two or more ESFAS Spent Fuel Pool Level Instrumentation channels are inoperable.

Date report generated:

Monday, June 29, 2015 Page 9

GTST AP1000-O67-3.3.14, Rev. 1 Description of additional changes proposed by NRC staff/preparer of GTST:

In the second paragraph of the MTS 3.3.14 Actions section of the Bases, the phrase ...then all affected Functions provided by that channel must be declared inoperable... is revised to ...then all affected protection Functions supported by or dependent on that channel must be declared inoperable... However, the spent fuel pool level - low Function supports no other instrument Function; so the affected paragraph is included only for consistency with other ESFAS instrument LCO Actions Bases.

In the Surveillance Requirements section of the Bases for STS Subsection 3.3.14 under the heading SR 3.3.14.2, the next to last paragraph, last line is revised from integrated protection cabinets to integrated protection cabinets (IPCs). In addition, PMS is used everywhere following its initial definition and in Bases for SR 3.3.14.2 and SR 3.3.14.3 the phrase allowed tolerance is changed to allowed as-left tolerance (APOG Comment and NRC Staff Edit).

The acronym ESF in the SRs section of the Bases under the heading SR 3.3.14.2, is revised to Engineered Safety Features (ESF). (APOG Comment)

The acronym FSAR is added to modify Section and Chapter in references to the FSAR throughout the Bases. (DOC A003) (APOG Comment)

Rationale for additional changes proposed by NRC staff/preparer of GTST:

This change was requested by NRC staff RAIs in Reference 5. Southern Nuclear Operating Company declined to make the change in its plant TS as documented in its RAI Response, Reference 6, because the wording is part of the original AP1000 GTS. However, the change is made to the AP1000 STS to provide clarity.

The non-technical changes to the Surveillance Requirements section of the Bases under the headings SR 3.3.14.2 and SR 3.3.14.3 provide clarity and consistency.

Since Bases references to FSAR Sections and Chapters are to an external document, it is appropriate to include the FSAR modifier.

Date report generated:

Monday, June 29, 2015 Page 10

GTST AP1000-O67-3.3.14, Rev. 1 VII. GTST Safety Evaluation Technical Analysis:

The revisions described in DOC M02 address multiple-channel inoperability. The revisions immediately impose default Actions for a given ESFAS Function. This is necessary because GTS 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, does not specify Actions for inoperability of more than two inoperable automatic initiation channels, which would otherwise result in entry into LCO 3.0.3 when three or more instrumentation channels are inoperable while in Modes 1, 2, 3, and 4, and entry into GTS LCO 3.0.8 (deleted by DOC L05) while in Modes 4 and 5. Since MTS 3.3.14, Engineered Safety Feature Actuation System (ESFAS) Spent Fuel Pool Level Instrumentation, is only applicable in Mode 6, LCO 3.0.3 is not a factor. However, for consistency, DOC M02 addresses the lack of specified Actions when two or more ESFAS Spent Fuel Pool Level Instrumentation channels are inoperable. The revised Condition B statement providing restoration time and compensatory action allowances for two or more inoperable ESFAS Spent Fuel Pool Level Instrumentation channels in MTS 3.3.14 is more restrictive than the similar ESFAS Spent Fuel Pool Level Instrumentation Function in GTS 3.3.2, and is therefore, acceptable.

The remaining changes, including those made by DOC A028, are editorial, clarifying, grammatical, or otherwise considered administrative. These changes do not affect the technical content, but improve the readability, implementation, and understanding of the requirements, and are therefore acceptable.

Having found that this GTSTs proposed changes to the GTS and Bases are acceptable, the NRC staff concludes that AP1000 STS Subsection 3.3.14 is an acceptable model Specification for the AP1000 standard reactor design.

References to Previous NRC Safety Evaluation Reports (SERs):

None Date report generated:

Monday, June 29, 2015 Page 11

GTST AP1000-O67-3.3.14, Rev. 1 VIII. Review Information Evaluator Comments:

None Randy Belles Oak Ridge National Laboratory 865-574-0388 bellesrj@ornl.gov Review Information:

Availability for public review and comment on Revision 0 of this traveler approved by NRC staff on 5/29/2014.

APOG Comments (Ref. 7) and Resolutions:

1. (Internal # 3) Throughout the Bases, references to Sections and Chapters of the FSAR do not include the FSAR clarifier. Since these Section and Chapter references are to an external document, it is appropriate (DOC A003) to include the FSAR modifier. This is resolved by adding the FSAR modifier as appropriate.

2. (Internal # 6) The GTST sections often repeat VEGP LAR DOCs, which reference existing and current requirements. The inclusion in the GTST of references to existing and current, are not always valid in the context of the GTS. Each occurrence of existing and current should be revised to be clear and specific to GTS, MTS, or VEGP COL TS (or other), as appropriate. Noted ambiguities are corrected in the GTST body.

3. (Internal # 7)Section VII, GTST Safety Evaluation, inconsistently completes the subsection References to Previous NRC Safety Evaluation Reports (SERs) by citing the associated SE for VEGP 3&4 COL Amendment 13. It is not clear whether there is a substantive intended difference when omitting the SE citation. This is resolved by removing the SE citation in Section VII of the GTST and ensuring that appropriate references to the consistent citation of this reference in Section X of the GTST are made.

4. (Internal # 116 and 165) In GTST for Subsection 3.3.8,Section VI, under the heading Rationale for changes in RCOL Std. Dep., RCOL COL Item(s), and RCOL PTS Changes, the first paragraph mentions DOC A024. This DOC is for changes to RTS Instrumentation and does not affect Subsection 3.3.8. Note that it is not mentioned anywhere else in this Subsection. This is also stated in Subsections 3.3.9 through 3.3.16. Change DOCs A024 and A028 to DOC A028 in GTST 3.3.8 through GTST 3.3.16. This is resolved by making the recommended change. Note that comment # 116 is actually directed at removing DOC A028 in Subsections 3.3.1 through 3.3.7, but the opposite is true for DOC A024 in Subsections 3.3.8 through 3.3.16 as stated above.

5. (Internal # 178) In the Surveillance Requirements section of the Bases for STS Subsection 3.3.8 under the heading SR 3.3.8.2, the next to last paragraph, last line uses the phrase integrated protection cabinets. The Bases for SR 3.3.8.3, first paragraph uses the term IPC, which is the acronym for integrated protection cabinets. The SR 3.3.8.2 Bases should be changed from integrated protection cabinets to integrated protection Date report generated:

Monday, June 29, 2015 Page 12

GTST AP1000-O67-3.3.14, Rev. 1 cabinets (IPCs). This change also applies to Section 3.3.10 (SR 3.3.10.2), Section 3.3.11 (SR 3.3.11.2), Section 3.3.13 (SR 3.3.13.2), and Section 3.3.14 (SR 3.3.14.2). Add the acronym (IPCs) after the words integrated protection cabinets in SR 3.3.8.2 (and other SRs identified above). This is resolved by making the recommended change with additional edits for added clarity. Use PMS everywhere following its initial definition and in Bases for SR 3.3.14.2 and SR 3.3.14.3 the phrase allowed tolerance is changed to allowed as-left tolerance.

6. (Internal # 196) In the Actions section of the Bases for STS Subsection 3.3.14, the first word in the first paragraph should be In, not n. Change n to In. This is resolved by making the recommended change.

7. (Internal # 197) The SRs section of the Bases under the heading SR 3.3.14.2, uses the term ESF. ESF - Engineered Safety Features - has not been previously defined. Change ESF to Engineered Safety Features (ESF). This is resolved by making the recommended change.

NRC Final Approval Date: 6/29/15 NRC

Contact:

C. Craig Harbuck United States Nuclear Regulatory Commission 301-415-3140 Craig.Harbuck@nrc.gov Date report generated:

Monday, June 29, 2015 Page 13

GTST AP1000-O67-3.3.14, Rev. 1 IX. Evaluator Comments for Consideration in Finalizing Technical Specifications and Bases None Date report generated:

Monday, June 29, 2015 Page 14

GTST AP1000-O67-3.3.14, Rev. 1 X. References Used in GTST

1. AP1000 DCD, Revision 19, Section 16, Technical Specifications, June 2011 (ML11171A500).

2. Southern Nuclear Operating Company, Vogtle Electric Generating Plant, Units 3 and 4, Technical Specifications Upgrade License Amendment Request, February 24, 2011 (ML12065A057).

3. NRC Safety Evaluation (SE) for Amendment No. 13 to Combined License (COL) No.

NPF-91 for Vogtle Electric Generating Plant (VEGP) Unit 3, and Amendment No. 13 to COL No. NPF-92 for VEGP Unit 4, September 9, 2013, ADAMS Package Accession No. ML13238A337, which contains:

ML13238A355 Cover Letter - Issuance of License Amendment No. 13 for Vogtle Units 3 and 4 (LAR 12-002).

ML13238A359 Enclosure 1 - Amendment No. 13 to COL No. NPF-91 ML13239A256 Enclosure 2 - Amendment No. 13 to COL No. NPF-92 ML13239A284 Enclosure 3 - Revised plant-specific TS pages (Attachment to Amendment No. 13)

ML13239A287 Enclosure 4 - Safety Evaluation (SE), and Attachment 1 - Acronyms ML13239A288 SE Attachment 2 - Table A - Administrative Changes ML13239A319 SE Attachment 3 - Table M - More Restrictive Changes ML13239A333 SE Attachment 4 - Table R - Relocated Specifications ML13239A331 SE Attachment 5 - Table D - Detail Removed Changes ML13239A316 SE Attachment 6 - Table L - Less Restrictive Changes The following documents were subsequently issued to correct an administrative error in Enclosure 3:

ML13277A616 Letter - Correction To The Attachment (Replacement Pages) - Vogtle Electric Generating Plant Units 3 and 4-Issuance of Amendment Re:

Technical Specifications Upgrade (LAR 12-002) (TAC No. RP9402)

ML13277A637 Enclosure 3 - Revised plant-specific TS pages (Attachment to Amendment No. 13) (corrected)

4. TSTF-GG-05-01, Writer's Guide for Plant-Specific Improved Technical Specifications, June 2005.

5. RAI Letter No. 01 Related to License Amendment Request (LAR)12-002 for the Vogtle Electric Generating Plant Units 3 and 4 Combined Licenses, September 7, 2012 (ML12251A355).

6. Southern Nuclear Operating Company, Vogtle Electric Generating Plant, Units 3 and 4, Response to Request for Additional Information Letter No. 01 Related to License Amendment Request LAR-12-002, ND-12-2015, October 04, 2012 (ML12286A363 and ML12286A360)

Date report generated:

Monday, June 29, 2015 Page 15

GTST AP1000-O67-3.3.14, Rev. 1

7. APOG-2014-008, APOG (AP1000 Utilities) Comments on AP1000 Standardized Technical Specifications (STS) Generic Technical Specification Travelers (GTSTs), Docket ID NRC-2014-0147, September 22, 2014 (ML14265A493).

Date report generated:

Monday, June 29, 2015 Page 16

GTST AP1000-O67-3.3.14, Rev. 1 XI. MARKUP of the Applicable GTS Subsection for Preparation of the STS NUREG The entire section of the Specifications and the Bases associated with this GTST is presented next.

Changes to the Specifications and Bases are denoted as follows: Deleted portions are marked in strikethrough red font, and inserted portions in bold blue font.

Date report generated:

Monday, June 29, 2015 Page 17

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation 3.3.14 3.3 INSTRUMENTATION 3.3.14 Engineered Safety Feature Actuation System (ESFAS) Spent Fuel Pool Level Instrumentation LCO 3.3.14 Three channels of ESFAS Spent Fuel Pool Level - Low instrumentation shall be OPERABLE.

APPLICABILITY: MODE 6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One channel inoperable. A.1 Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months B. Required Action and -------------------NOTE--------------------

associated Completion Flow path(s) may be unisolated Time of Condition A not intermittently under administrative met. controls.

OR B.1 Isolate the affected flow 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Two or more channels path(s).

inoperable.

AND B.2.1 Isolate the affected flow 7 days path(s) by use of at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

OR B.2.2 Verify the affected flow path Once per 7 days is isolated.

AP1000 STS 3.3.14-1 Amendment 0Rev. 0 Revision 19 Date report generated:

Monday, June 29, 2015 Page 18

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation 3.3.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.14.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.14.2 Perform CHANNEL OPERATIONAL TEST (COT) in 92 days accordance with Setpoint Program.

SR 3.3.14.3 --------------------------------NOTE--------------------------------

This surveillance shall include verification that the time constants are adjusted to within limits the prescribed values.

Perform CHANNEL CALIBRATION in accordance with 24 months Setpoint Program.

SR 3.3.14.4 Verify ESF RESPONSE TIME is within limit. 24 months on a STAGGERED TEST BASIS AP1000 STS 3.3.14-2 Amendment 0Rev. 0 Revision 19 Date report generated:

Monday, June 29, 2015 Page 19

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation B 3.3.14 B 3.3 INSTRUMENTATION B 3.3.14 Engineered Safety Feature Actuation System (ESFAS) Spent Fuel Pool Level Instrumentation BASES BACKGROUND A description of the ESFAS Instrumentation is provided in the Bases for LCO 3.3.8, Engineered Safety Feature Actuation System (ESFAS)

Instrumentation.

APPLICABLE The required channels of ESFAS instrumentation provide plant protection SAFETY in the event of any of the analyzed accidents. ESFAS protective functions ANALYSES, LCO, include the Refueling Cavity Isolation.

and APPLICABILITY The instrument Function required by this LCO is the Spent Fuel Pool Level - Low.

In the event of a leak in the non-safety Spent Fuel Pool Cooling System, closure of the containment isolation valves on low spent fuel pool level in two of three channels will terminate draining of the refueling cavity.

Since the transfer canal is open in MODE 6, the spent fuel pool level is the same as the refueling cavity.

Draining of the spent fuel pool, directly, through a leaking Spent Fuel Pool Cooling System is limited by the location of the suction piping, which is near the top of the pool. Therefore, closure of the containment isolation valves between the refueling cavity and the Spent Fuel Pool Cooling System is sufficient to terminate refueling cavity and spent fuel pool leakage through the Spent Fuel Pool Cooling System. Three channels of ESFAS Spent Fuel Pool Level - Low Function are required to be OPERABLE in MODE 6 to maintain water inventory in the refueling cavity.

ESFAS Spent Fuel Pool Level instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

ACTIONS In the event a channels as-found condition is outside the as-found tolerance described in the Setpoint Program, or the channel is not functioning as required, or the transmitter, or the Protection and Safety Monitoring System (PMS) Division, associated with a specific Function is found inoperable, then all affected protection Functions provided supported by or dependent on that channel must be declared AP1000 STS B 3.3.14-1 Amendment 0Rev. 0 Revision 19 Date report generated:

Monday, June 29, 2015 Page 20

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation B 3.3.14 BASES ACTIONS (continued) inoperable and the LCO Condition(s) entered for the particular protection Function(s) affected.

A.1 Condition A addresses the situation where one channel is inoperable.

With one spent fuel pool level channel inoperable, the inoperable channel must be placed in a trip condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . If one of the three spent fuel pool level channels is tripped, the logic becomes one-out-of-two, while still meeting the single failure criterion. The specified Completion Time is reasonable considering the time required to complete this action.

B.1 and B.2 If the Required Action and associated Completion Time of Condition A is not met, or two or more channels are inoperable, the plant must be placed in a condition where the instrumentation Function for valve isolation is no longer applicable. To achieve this, the affected flow path(s) must be isolated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Additionally, to assure that the flow path remains closed, the flow path shall be isolated by the use of one of the specified means (Required Action B.2.1) or the flow path shall be verified to be isolated (Required Action B.2.2). A means of isolating the affected flow path(s) includes at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured within 7 days. If one of the Required Action B.2.1 specified isolation means is not used, the affected flow path shall be verified to be isolated once per 7 days.

This action is modified by a Note allowing the flow path(s) to be unisolated intermittently under administrative control. These administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication with the control room. In this way the flow path can be rapidly isolated when a need for flow path isolation is indicated.

AP1000 STS B 3.3.14-2 Amendment 0Rev. 0 Revision 19 Date report generated:

Monday, June 29, 2015 Page 21

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation B 3.3.14 BASES SURVEILLANCE SR 3.3.14.1 REQUIREMENTS Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or even something more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the match criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside their corresponding limits.

The Surveillance Frequency is based on operating experience that demonstrates that channel failure is rare. Automated operator aids may be used to facilitate performance of the CHANNEL CHECK.

SR 3.3.14.2 SR 3.3.14.2 is the performance of a CHANNEL OPERATIONAL TEST (COT) every 92 days. The test is performed in accordance with the SP. If the actual setting of the channel is found to be outside the as-found tolerance, the channel is considered inoperable. This condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTS (within the allowed as-left tolerance), and evaluating the channels response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.

A COT is performed on each required channel to provide reasonable assurance that the entire channel will perform the intended Engineered Safety Features (ESF) Function.

AP1000 STS B 3.3.14-3 Amendment 0Rev. 0 Revision 19 Date report generated:

Monday, June 29, 2015 Page 22

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation B 3.3.14 BASES SURVEILLANCE REQUIREMENTS (continued)

A test subsystem is provided with the PMS protection and safety monitoring system to aid the plant staff in performing the COT. The test subsystem is designed to allow for complete functional testing by using a combination of system self-checking features, functional testing features, and other testing features. Successful functional testing consists of verifying that the capability of the system to perform the safety function has not failed or degraded.

For hardware functions this would involve verifying that the hardware components and connections have not failed or degraded. Generally this verification includes a comparison of the outputs from two or more redundant subsystems or channels.

Since software does not degrade, software functional testing involves verifying that the software code has not changed and that the software code is executing.

To the extent possible, PMS protection and safety monitoring system functional testing is accomplished with continuous system self-checking features and the continuous functional testing features. The COT shall include a review of the operation of the test subsystem to verify the completeness and adequacy of the results.

If the COT cannot be completed using the built-in test subsystem, either because of failures in the test subsystem or failures in redundant channel hardware used for functional testing, the COT can be performed using portable test equipment.

The 92 day Frequency is based on Reference 2 and the use of continuous diagnostic test features, such as deadman timers, cross-check of redundant channels, memory checks, numeric coprocessor checks, and tests of timers, counters and crystal time bases, which will report a failure within the integrated protection cabinets (IPCs) to the operator.

During the COT, the PMS protection and safety monitoring system cabinets in the division under test may be placed in bypass.

AP1000 STS B 3.3.14-4 Amendment 0Rev. 0 Revision 19 Date report generated:

Monday, June 29, 2015 Page 23

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation B 3.3.14 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.14.3 SR 3.3.14.3 is the performance of a CHANNEL CALIBRATION every 24 months or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor and the IPC. The test is performed in accordance with the SP. If the actual setting of the channel is found to be outside the as-found tolerance, the channel is considered inoperable. This condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTS (within the allowed as-left tolerance), and evaluating the channels response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation. Transmitter calibration must be performed consistent with the assumptions of the setpoint methodology. The difference between the current as-found values and the previous as-left values must be consistent with the transmitter drift allowance used in the setpoint methodology.

The setpoint methodology requires that 30 months drift be used (1.25 times the surveillance calibration interval, 24 months).

The Frequency is based on operating experience and consistency with the refueling cycle.

This Surveillance Requirement is modified by a Note. The Note states that this test should include verification that the time constants are adjusted to within limits.

SR 3.3.14.4 This SR ensures the individual channel ESF RESPONSE TIME is less than or equal to the maximum value assumed in the accident analysis.

Individual component response times are not modeled in the analyses.

The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the NTS value at the sensor, to the point at which the equipment reaches the required functional state (e.g., valves in full open or closed position).

AP1000 STS B 3.3.14-5 Amendment 0Rev. 0 Revision 19 Date report generated:

Monday, June 29, 2015 Page 24

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation B 3.3.14 BASES SURVEILLANCE REQUIREMENTS (continued)

For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer functions set to one with the resulting measured response time compared to the appropriate FSAR Chapter 7 (Ref. 2) response time. Alternately, the response time test can be performed with the time constants set to their nominal value provided the required response time is analytically calculated assuming the time constants are set at their nominal values.

The response time may be measured by a series of overlapping tests such that the entire response time is measured.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g.,

vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements (Ref. 4), provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test.

ESF RESPONSE TIME tests are conducted on a 24 month STAGGERED TEST BASIS. Testing of the devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel. Therefore, staggered testing results in response time verification of these devices every 24 months. The 24 month Frequency is consistent with the typical refueling cycle and is based on unit operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences.

AP1000 STS B 3.3.14-6 Amendment 0Rev. 0 Revision 19 Date report generated:

Monday, June 29, 2015 Page 25

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation B 3.3.14 BASES REFERENCES 1. FSAR Chapter 15.0, Accident Analysis.

2. FSAR Chapter 7.0, Instrumentation and Controls.

3. APP-GW-GSC-020, Technical Specification Completion Time and Surveillance Frequency Justification.

4. WCAP-13632-P-A (Proprietary) and WCAP-13787-A (Non Proprietary), Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements, January 1996.

AP1000 STS B 3.3.14-7 Amendment 0Rev. 0 Revision 19 Date report generated:

Monday, June 29, 2015 Page 26

GTST AP1000-O67-3.3.14, Rev. 1 XII. Applicable STS Subsection After Incorporation of this GTSTs Modifications The entire subsection of the Specifications and the Bases associated with this GTST, following incorporation of the modifications, is presented next.

Date report generated:

Monday, June 29, 2015 Page 27

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation 3.3.14 3.3 INSTRUMENTATION 3.3.14 Engineered Safety Feature Actuation System (ESFAS) Spent Fuel Pool Level Instrumentation LCO 3.3.14 Three channels of ESFAS Spent Fuel Pool Level - Low instrumentation shall be OPERABLE.

APPLICABILITY: MODE 6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One channel inoperable. A.1 Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months B. Required Action and -------------------NOTE--------------------

associated Completion Flow path(s) may be unisolated Time of Condition A not intermittently under administrative met. controls.

OR B.1 Isolate the affected flow 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Two or more channels path(s).

inoperable.

AND B.2.1 Isolate the affected flow 7 days path(s) by use of at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

OR B.2.2 Verify the affected flow path Once per 7 days is isolated.

AP1000 STS 3.3.14-1 Rev. 0 Date report generated:

Monday, June 29, 2015 Page 28

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation 3.3.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.14.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.14.2 Perform CHANNEL OPERATIONAL TEST (COT) in 92 days accordance with Setpoint Program.

SR 3.3.14.3 --------------------------------NOTE--------------------------------

This surveillance shall include verification that the time constants are adjusted to within limits.

Perform CHANNEL CALIBRATION in accordance with 24 months Setpoint Program.

SR 3.3.14.4 Verify ESF RESPONSE TIME is within limit. 24 months on a STAGGERED TEST BASIS AP1000 STS 3.3.14-2 Rev. 0 Date report generated:

Monday, June 29, 2015 Page 29

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation B 3.3.14 B 3.3 INSTRUMENTATION B 3.3.14 Engineered Safety Feature Actuation System (ESFAS) Spent Fuel Pool Level Instrumentation BASES BACKGROUND A description of the ESFAS Instrumentation is provided in the Bases for LCO 3.3.8, Engineered Safety Feature Actuation System (ESFAS)

Instrumentation.

APPLICABLE The required channels of ESFAS instrumentation provide plant protection SAFETY in the event of any of the analyzed accidents. ESFAS protective functions ANALYSES, LCO, include the Refueling Cavity Isolation.

and APPLICABILITY The instrument Function required by this LCO is the Spent Fuel Pool Level - Low.

In the event of a leak in the non-safety Spent Fuel Pool Cooling System, closure of the containment isolation valves on low spent fuel pool level in two of three channels will terminate draining of the refueling cavity.

Since the transfer canal is open in MODE 6, the spent fuel pool level is the same as the refueling cavity.

Draining of the spent fuel pool, directly, through a leaking Spent Fuel Pool Cooling System is limited by the location of the suction piping, which is near the top of the pool. Therefore, closure of the containment isolation valves between the refueling cavity and the Spent Fuel Pool Cooling System is sufficient to terminate refueling cavity and spent fuel pool leakage through the Spent Fuel Pool Cooling System. Three channels of ESFAS Spent Fuel Pool Level - Low Function are required to be OPERABLE in MODE 6 to maintain water inventory in the refueling cavity.

ESFAS Spent Fuel Pool Level instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

ACTIONS In the event a channels as-found condition is outside the as-found tolerance described in the Setpoint Program, or the channel is not functioning as required, or the transmitter, or the Protection and Safety Monitoring System (PMS) Division, associated with a specific Function is found inoperable, then all affected protection Functions supported by or AP1000 STS B 3.3.14-1 Rev. 0 Date report generated:

Monday, June 29, 2015 Page 30

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation B 3.3.14 BASES ACTIONS (continued) dependent on that channel must be declared inoperable and the LCO Condition(s) entered for the particular protection Function(s) affected.

A.1 Condition A addresses the situation where one channel is inoperable.

With one spent fuel pool level channel inoperable, the inoperable channel must be placed in a trip condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . If one of the three spent fuel pool level channels is tripped, the logic becomes one-out-of-two, while still meeting the single failure criterion. The specified Completion Time is reasonable considering the time required to complete this action.

B.1 and B.2 If the Required Action and associated Completion Time of Condition A is not met, or two or more channels are inoperable, the plant must be placed in a condition where the instrumentation Function for valve isolation is no longer applicable. To achieve this, the affected flow path(s) must be isolated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Additionally, to assure that the flow path remains closed, the flow path shall be isolated by the use of one of the specified means (Required Action B.2.1) or the flow path shall be verified to be isolated (Required Action B.2.2). A means of isolating the affected flow path(s) includes at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured within 7 days. If one of the Required Action B.2.1 specified isolation means is not used, the affected flow path shall be verified to be isolated once per 7 days.

This action is modified by a Note allowing the flow path(s) to be unisolated intermittently under administrative control. These administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication with the control room. In this way the flow path can be rapidly isolated when a need for flow path isolation is indicated.

AP1000 STS B 3.3.14-2 Rev. 0 Date report generated:

Monday, June 29, 2015 Page 31

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation B 3.3.14 BASES SURVEILLANCE SR 3.3.14.1 REQUIREMENTS Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or even something more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the match criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside their corresponding limits.

The Surveillance Frequency is based on operating experience that demonstrates that channel failure is rare. Automated operator aids may be used to facilitate performance of the CHANNEL CHECK.

SR 3.3.14.2 SR 3.3.14.2 is the performance of a CHANNEL OPERATIONAL TEST (COT) every 92 days. The test is performed in accordance with the SP. If the actual setting of the channel is found to be outside the as-found tolerance, the channel is considered inoperable. This condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTS (within the allowed as-left tolerance), and evaluating the channels response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.

A COT is performed on each required channel to provide reasonable assurance that the entire channel will perform the intended Engineered Safety Features (ESF) Function.

AP1000 STS B 3.3.14-3 Rev. 0 Date report generated:

Monday, June 29, 2015 Page 32

GTST AP1000-O67-3.3.14, Rev. 1 ESFAS Spent Fuel Pool Level Instrumentation B 3.3.14 BASES SURVEILLANCE REQUIREMENTS (continued)

A test subsystem is provided with the PMS to aid the plant staff in performing the COT. The test subsystem is designed to allow for complete functional testing by using a combination of system self-checking features, functional testing features, and other testing features.

Successful functional testing consists of verifying that the capability of the system to perform the safety function has not failed or degraded.

For hardware functions this would involve verifying that the hardware components and connections have not failed or degraded. Generally this verification includes a comparison of the outputs from two or more redundant subsystems or channels.

Since software does not degrade, software functional testing involves verifying that the software code has not changed and that the software code is executing.

To the extent possible, PMS functional testing is accomplished with continuous system self-checking features and the continuous functional testing features. The COT shall include a review of the operation of the test subsystem to verify the completeness and adequacy of the results.

If the COT cannot be completed using the built-in test subsystem, either because of failures in the test subsystem or failures in redundant channel hardware used for functional testing, the COT can be performed using portable test equipment.

The 92 day Frequency is based on Reference 2 and the use of continuous diagnostic test features, such as deadman timers, cross-check of redundant channels, memory checks, numeric coprocessor checks, and tests of timers, counters and crystal time bases, which will report a failure within the integrated protection cabinets (IPCs) to the operator.

During the COT, the PMS cabinets in the division under test may be placed in bypass.

AP1000 STS B 3.3.14-4 Rev. 0 Date report generated:

Monday, June 29, 2015 Page 33