ML22240A059

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Changes Related to AP1000 Gts Subsection 3.4.5, Pressurizer
ML22240A059
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Issue date: 05/27/2015
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Craig Harbuck NRR/DSS 301-415-3140
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Download: ML22240A059 (24)


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GTST AP1000-O26-3.4.5, Rev. 1 Advanced Passive 1000 (AP1000)

Generic Technical Specification Traveler (GTST)

Title:

Changes Related to LCO 3.4.5, Pressurizer 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-425-A, Rev 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b STS NUREGs Affected:

TSTF-425-A, Rev 3: NUREGs 1430, 1431, 1432, 1433, and 1434 NRC Approval Date:

TSTF-425-A, Rev. 3: 06-Jul-09 TSTF Classification:

TSTF-425-A, Rev 3: Technical Change Date report generated:

Wednesday, May 27, 2015 Page 1

GTST AP1000-O26-3.4.5, 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 departures applicable to Specification 3.4.5.

RCOL COL Item Number and

Title:

There are no Vogtle COL items applicable to Specification 3.4.6.

RCOL PTS Change Number and

Title:

VEGP LAR DOC A003: References to various Chapters and Sections of the Final Safety Analysis Report (FSAR) are revised to include FSAR.

VEGP LAR DOC A043: TS 3.4.5 Required Action A.1 is deleted VEGP LAR DOC L07: Certain TS Required Actions requiring the RTBs to be opened are revised into two Required Actions.

Date report generated:

Wednesday, May 27, 2015 Page 2

GTST AP1000-O26-3.4.5, 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(1) applicable to operating reactor designs, but not to the AP1000 design; (2) already incorporated in the GTS; or (3) superseded by another change.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-425-A deferred for future consideration.

Date report generated:

Wednesday, May 27, 2015 Page 3

GTST AP1000-O26-3.4.5, 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)

APOG Recommended Changes to Improve the Bases 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:

Wednesday, May 27, 2015 Page 4

GTST AP1000-O26-3.4.5, Rev. 1 V. Applicability Affected Generic Technical Specifications and Bases:

Section 3.4.5, Pressurizer Changes to the Generic Technical Specifications and Bases:

Required Action A.1 is deleted and the corresponding Bases are updated. The Required Action is a restatement of the LCO and is not required by the TS Writer's Guide (Reference 4).

(DOC A043)

Required Action A.2.1 (new A.1) is revised to break the RTB statement into two parts. This eliminates the potential for undesirable secondary effects of opening the reactor trip breakers.

(DOC L07)

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:

Wednesday, May 27, 2015 Page 5

GTST AP1000-O26-3.4.5, 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:

VEGP LAR DOC A043 deletes Required Action A.1, Restore pressurizer water level within limit, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

VEGP LAR DOC L07 replaces Required Actions to open the reactor trip breakers with two Required Actions.

A more detailed description of each DOC can be found in Reference 2, VEGP TSU LAR , and 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 in Reference 5 and the Southern Nuclear Operating Company RAI Response in Reference 6.

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

Deletion of Required Action A.1 per VEGP LAR DOC A043 is consistent with the TS Writer's Guide (Reference 4). Unless an action to restore a parameter to within limit is the only required action for the associated Condition, such an action is implicitly specified and does not need to be explicitly stated.

VEGP LAR DOC L07 notes that when the RTBs are opened, certain other interlocks can be initiated. The initiation of the associated interlocks may have an undesirable secondary effect on the ease of operation of the plant such as the initiation of the P-4 interlock, which, in the event of low RCS temperature, can result in isolation of main feedwater to the steam generators.

Description of additional changes proposed by NRC staff/preparer of GTST:

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:

Wednesday, May 27, 2015 Page 6

GTST AP1000-O26-3.4.5, Rev. 1 Rationale for additional changes proposed by NRC staff/preparer of GTST:

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

Date report generated:

Wednesday, May 27, 2015 Page 7

GTST AP1000-O26-3.4.5, Rev. 1 VII. GTST Safety Evaluation Technical Analysis:

VEGP LAR DOC L07 replaces Required Actions to open the reactor trip breakers with two Required Actions. Each of the Required Actions to open the RTBs is intended to assure that rods cannot be withdrawn thereby eliminating the possibility for control rod related positive reactivity additions and associated heat input into the reactor coolant. Additionally, opening the RTBs would result in all rods being inserted. Therefore, replacing the Required Actions to open RTBs with two actions to initiate action to fully insert all rods and place the Plant Control System in a condition incapable of rod withdrawal, maintains the intent of the existing requirement. This change replaces the specific method of precluding rod withdrawal and ensuring all rods are inserted while maintaining the requirement for establishing the plant conditions equivalent to opening RTBs.

The remaining changes 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 3.4.5 is an acceptable model Specification for the AP1000 standard reactor design.

References to Previous NRC Safety Evaluation Reports (SERs):

None Date report generated:

Wednesday, May 27, 2015 Page 8

GTST AP1000-O26-3.4.5, 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 5/16/2014.

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 # 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.
3. (Internal #13) Many GTSTs evaluated TSTF-425 with the following note: Risk-informed TS changes will be considered at a later time for application to the AP1000 STS.

The NRC approval of TSTF-425, and model safety evaluation provided in the CLIIP for TSTF-425, are generically applicable to any designs Technical Specifications. As such, the replacement of certain Frequencies with a Surveillance Frequency Control Program should be included in the GTST for AP1000 STS NUREG.

However, implementation in the AP1000 STS should not reflect optional (i.e., bracketed) material showing retention of fixed Surveillance Frequencies where relocation to a Surveillance Frequency Control Program is acceptable. Since each represented AP1000 Utility is committed to maintaining standardization, there is no rationale for an AP1000 STS that includes bracketed options.

Consistent with TSTF-425 criteria, replace applicable Surveillance Frequencies with In accordance with the Surveillance Frequency control Program and add that Program as new AP1000 STS Specification 5.5.15.

NRC Staff disagreed with implementing TSTF-425 in the initial version of the STS.

Although the APOG thinks the analysis supporting this traveler is general enough to be applicable to AP1000, staff thinks an AP1000-specific proposal from APOG is needed to Date report generated:

Wednesday, May 27, 2015 Page 9

GTST AP1000-O26-3.4.5, Rev. 1 identify any GTS SRs that should be excluded. Also, with the adoption of a Surveillance Frequency Control Program (SFCP) in the AP1000 STS, bracketed Frequencies, which provide a choice between the GTS Frequency and the SFCP Frequency, are needed because the NRC will use the AP1000 STS as a reference, and to be consistent with NUREG-1431, Rev. 4. APOG was requested to consider proposing an AP1000 version of TSTF-425 for a subsequent revision of the STS.

NRC Final Approval Date: 5/27/2015 NRC

Contact:

Hien Le United States Nuclear Regulatory Commission 301-415-1511 Hien.Le@nrc.gov Date report generated:

Wednesday, May 27, 2015 Page 10

GTST AP1000-O26-3.4.5, Rev. 1 IX. Evaluator Comments for Consideration in Finalizing Technical Specifications and Bases None Date report generated:

Wednesday, May 27, 2015 Page 11

GTST AP1000-O26-3.4.5, 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:

Wednesday, May 27, 2015 Page 12

GTST AP1000-O26-3.4.5, 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:

Wednesday, May 27, 2015 Page 13

GTST AP1000-O26-3.4.5, 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:

Wednesday, May 27, 2015 Page 14

GTST AP1000-O26-3.4.5, Rev. 1 Pressurizer 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 Pressurizer LCO 3.4.5 The pressurizer water level shall be 92% of span.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressurizer water level A.1 Restore pressurizer water 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> not within limit. level within limit.

OR A.2.1 Be in MODE 3 with reactor 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> trip breakers open.

AND A.2 Initiate action to fully 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> insert all rods.

AND A.3 Place the Plant Control 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> System in a condition incapable of rod withdrawal.

AND A.2.24 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AP1000 STS 3.4.5-1 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 15

GTST AP1000-O26-3.4.5, Rev. 1 Pressurizer 3.4.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify pressurizer water level 92% of span. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AP1000 STS 3.4.5-2 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 16

GTST AP1000-O26-3.4.5, Rev. 1 Pressurizer B 3.4.5 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.5 Pressurizer BASES BACKGROUND The pressurizer provides a point in the RCS where liquid and vapor are maintained in equilibrium under saturated conditions for pressure control purposes to prevent bulk boiling in the remainder of the RCS. Key functions include maintaining required primary system pressure during steady state operation, and limiting the pressure changes caused by reactor coolant thermal expansion and contraction during normal load transients.

The normal level and pressure control components addressed by this LCO include the pressurizer water level, the heaters, their controls, and power supplies. Pressurizer safety valves and automatic depressurization valves are addressed by LCO 3.4.6, Pressurizer Safety Valves, and LCO 3.4.11, Automatic Depressurization System (ADS) - Operating, respectively.

The intent of the LCO is to ensure that a steam bubble exists in the pressurizer prior to power operation to minimize the consequences of potential overpressure transients. The presence of a steam bubble is consistent with analytical assumptions. Relatively small amounts of noncondensable gases can inhibit the condensation heat transfer between the pressurizer spray and the steam, and diminish the spray effectiveness for pressure control.

Electrical immersion heaters, located in the lower section of the pressurizer vessel, keep the water in the pressurizer at saturation temperature and maintain a constant operating pressure.

APPLICABLE In MODES 1, 2, and 3, the LCO requirement for a steam bubble is SAFETY reflected implicitly in the accident analyses. Safety analyses performed ANALYSES for lower MODES are not limiting. All analyses performed from a critical reactor condition assume the existence of a steam bubble and saturated conditions in the pressurizer. In making this assumption, the analyses neglect the small fraction of noncondensable gases normally present.

Safety analyses presented in FSAR Chapter 15 (Ref. 1) do not take credit for pressurizer heater operation, however, an implicit initial condition assumption of the safety analyses is that the RCS is operating at normal pressure.

AP1000 STS B 3.4.5-1 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 17

GTST AP1000-O26-3.4.5, Rev. 1 Pressurizer B 3.4.5 BASES APPLICABLE SAFETY ANALYSES (continued)

The maximum pressurizer water level limit satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requirement for the pressurizer water volume 92% of span, ensures that an adequate steam bubble exists. Limiting the LCO maximum operating water level preserves the steam space for pressure control. The LCO has been established to ensure the capability to establish and maintain pressure control for steady state operation and to minimize the consequences of potential overpressure transients.

Requiring the presence of a steam bubble is also consistent with analytical assumptions.

APPLICABILITY The need for pressure control is most pertinent when core heat can cause the greatest effect on RCS temperature, resulting in the greatest effect on pressurizer level and RCS pressure control. Thus, applicability has been designated for MODES 1 and 2. The applicability is also provided for MODE 3. The purpose is to prevent solid water RCS operation during heatup and cooldown to avoid rapid pressure rises caused by normal operational perturbation, such as reactor coolant pump startup.

ACTIONS A.1, A.2, A.3, and A.24 Pressurizer water level control malfunctions or other plant evolutions may result in a pressurizer water level above the nominal upper limit, even with the plant at steady state conditions.

If the pressurizer water level is above the limit, action must be taken to restore the plant to operation within the bounds of the safety analyses.

This is done by restoring the level to within limit, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or by placing the unit in MODE 3 with the reactor trip breakers open placing the unit in MODE 3 with the Plant Control System in a condition incapable of rod withdrawal and action initiated to fully insert all control rods within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and placing the unit in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This takes the unit out of the applicable MODES and restores the unit to operation within the bounds of the safety analyses.

AP1000 STS B 3.4.5-2 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 18

GTST AP1000-O26-3.4.5, Rev. 1 Pressurizer B 3.4.5 BASES ACTIONS (continued)

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

SURVEILLANCE This SR requires that during steady state operation, pressurizer level is REQUIREMENTS maintained below the nominal upper limit to provide a minimum space for a steam bubble. The Surveillance is performed by observing the indicated level. The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> corresponds to verifying the parameter each shift. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval has been shown by operating practice to be sufficient to regularly assess the level for any deviation and verify that operation is within safety analyses assumptions. Alarms are also available for early detection of abnormal level indications.

REFERENCES 1. FSAR Chapter 15, Accident Analysis.

AP1000 STS B 3.4.5-3 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 19

GTST AP1000-O26-3.4.5, 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:

Wednesday, May 27, 2015 Page 20

GTST AP1000-O26-3.4.5, Rev. 1 Pressurizer 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 Pressurizer LCO 3.4.5 The pressurizer water level shall be 92% of span.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressurizer water level A.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> not within limit.

AND A.2 Initiate action to fully insert 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> all rods.

AND A.3 Place the Plant Control 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> System in a condition incapable of rod withdrawal.

AND A.4 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify pressurizer water level 92% of span. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AP1000 STS 3.4.5-1 Rev. 0 Date report generated:

Wednesday, May 27, 2015 Page 21

GTST AP1000-O26-3.4.5, Rev. 1 Pressurizer B 3.4.5 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.5 Pressurizer BASES BACKGROUND The pressurizer provides a point in the RCS where liquid and vapor are maintained in equilibrium under saturated conditions for pressure control purposes to prevent bulk boiling in the remainder of the RCS. Key functions include maintaining required primary system pressure during steady state operation, and limiting the pressure changes caused by reactor coolant thermal expansion and contraction during normal load transients.

The normal level and pressure control components addressed by this LCO include the pressurizer water level, the heaters, their controls, and power supplies. Pressurizer safety valves and automatic depressurization valves are addressed by LCO 3.4.6, Pressurizer Safety Valves, and LCO 3.4.11, Automatic Depressurization System (ADS) - Operating, respectively.

The intent of the LCO is to ensure that a steam bubble exists in the pressurizer prior to power operation to minimize the consequences of potential overpressure transients. The presence of a steam bubble is consistent with analytical assumptions. Relatively small amounts of noncondensable gases can inhibit the condensation heat transfer between the pressurizer spray and the steam, and diminish the spray effectiveness for pressure control.

Electrical immersion heaters, located in the lower section of the pressurizer vessel, keep the water in the pressurizer at saturation temperature and maintain a constant operating pressure.

APPLICABLE In MODES 1, 2, and 3, the LCO requirement for a steam bubble is SAFETY reflected implicitly in the accident analyses. Safety analyses performed ANALYSES for lower MODES are not limiting. All analyses performed from a critical reactor condition assume the existence of a steam bubble and saturated conditions in the pressurizer. In making this assumption, the analyses neglect the small fraction of noncondensable gases normally present.

Safety analyses presented in FSAR Chapter 15 (Ref. 1) do not take credit for pressurizer heater operation, however, an implicit initial condition assumption of the safety analyses is that the RCS is operating at normal pressure.

AP1000 STS B 3.4.5-1 Rev. 0 Date report generated:

Wednesday, May 27, 2015 Page 22

GTST AP1000-O26-3.4.5, Rev. 1 Pressurizer B 3.4.5 BASES APPLICABLE SAFETY ANALYSES (continued)

The maximum pressurizer water level limit satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requirement for the pressurizer water volume 92% of span ensures that an adequate steam bubble exists. Limiting the LCO maximum operating water level preserves the steam space for pressure control. The LCO has been established to ensure the capability to establish and maintain pressure control for steady state operation and to minimize the consequences of potential overpressure transients.

Requiring the presence of a steam bubble is also consistent with analytical assumptions.

APPLICABILITY The need for pressure control is most pertinent when core heat can cause the greatest effect on RCS temperature, resulting in the greatest effect on pressurizer level and RCS pressure control. Thus, applicability has been designated for MODES 1 and 2. The applicability is also provided for MODE 3. The purpose is to prevent solid water RCS operation during heatup and cooldown to avoid rapid pressure rises caused by normal operational perturbation, such as reactor coolant pump startup.

ACTIONS A.1, A.2, A.3, and A.4 Pressurizer water level control malfunctions or other plant evolutions may result in a pressurizer water level above the nominal upper limit, even with the plant at steady state conditions.

If the pressurizer water level is above the limit, action must be taken to restore the plant to operation within the bounds of the safety analyses.

This is done by placing the unit in MODE 3 with the Plant Control System in a condition incapable of rod withdrawal and action initiated to fully insert all control rods within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and placing the unit in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This takes the unit out of the applicable MODES and restores the unit to operation within the bounds of the safety analyses.

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

AP1000 STS B 3.4.5-2 Rev. 0 Date report generated:

Wednesday, May 27, 2015 Page 23

GTST AP1000-O26-3.4.5, Rev. 1 Pressurizer B 3.4.5 BASES SURVEILLANCE This SR requires that during steady state operation, pressurizer level is REQUIREMENTS maintained below the nominal upper limit to provide a minimum space for a steam bubble. The Surveillance is performed by observing the indicated level. The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> corresponds to verifying the parameter each shift. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval has been shown by operating practice to be sufficient to regularly assess the level for any deviation and verify that operation is within safety analyses assumptions. Alarms are also available for early detection of abnormal level indications.

REFERENCES 1. FSAR Chapter 15, Accident Analysis.

AP1000 STS B 3.4.5-3 Rev. 0 Date report generated:

Wednesday, May 27, 2015 Page 24