RS-22-092, Nine and Quad Cities - Application to Revise Primary Containment Isolation Instrumentation Technical Specifications in Accordance with TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration

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Nine and Quad Cities - Application to Revise Primary Containment Isolation Instrumentation Technical Specifications in Accordance with TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration
ML22276A220
Person / Time
Site: Dresden, Nine Mile Point, Clinton, Quad Cities, LaSalle  Constellation icon.png
Issue date: 10/03/2022
From: Simpson P
Constellation Energy Generation
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-22-092
Download: ML22276A220 (40)
v • d • e


Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office 10 CFR 50.90 RS-22-092 October 3, 2022 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRC Docket No. 50-410 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Application to Revise Primary Containment Isolation Instrumentation Technical Specifications in Accordance with TSTF-306, Revision 2, "Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration"

Reference:

TSTF-306, Revision 2, " Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration," dated July 13, 2000 (ADAMS Accession No. ML003725864)

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests amendments to Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1 and Renewed Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3; Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS) Units 1 and 2; No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (NMP2); and Nos. DPR-29 and

October 3, 2022 U.S. Nuclear Regulatory Commission Page 2 DPR-30 for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. Specifically, CEG requests adoption of TSTF-306, " Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration," Revision 2 (Reference), an approved change to the Improved Standard Technical Specifications (ISTS), into each unit's TS.

The proposed change would revise TS 3.3.6.1, titled "Primary Containment and Drywell Isolation Instrumentation" at CPS and "Primary Containment Isolation Instrumentation" at DNPS, LSCS, NMP2, and QCNPS by adding an ACTIONS note allowing intermittent opening, under administrative control, of penetration flow paths that are isolated.

provides a description and assessment of the proposed change. Attachment 2 provides the existing TS pages marked-up to show the proposed TS change. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides the corresponding marked-up TS Bases pages and is provided for information only.

The proposed change has been reviewed by the CPS, DNPS, LSCS, NMP2, and QCNPS Plant Operations Review Committees, in accordance with the requirements of the CEG Quality Assurance Program.

CEG requests approval of the proposed license amendment by October 3, 2023. Once approved, the amendment shall be implemented within 60 days except for DNPS which requests a 90 day implementation period to accommodate their fall 2023 outage.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), a copy of this application, with attachments, is being provided to the designated State Officials.

There are no regulatory commitments contained in this submittal. Should you have any questions concerning this submittal, please contact Ms. Rebecca L. Steinman at (630) 657-2831.

I declare under penalty of perjury that the foregoing is true and correct. This statement was executed on the 3rd day of October 2022.

Respectfully, Patrick R. Simpson Sr. Manager Licensing Constellation Energy Generation, LLC

October 3, 2022 U.S. Nuclear Regulatory Commission Page 3 Attachments:

1. Evaluation of Proposed Changes
2. Mark-up of Technical Specifications Pages
3. Clean Technical Specifications Pages
4. Mark-up of Technical Specifications Bases Pages - For Information Only cc:

NRC Regional Administrator, Region I NRC Regional Administrator, Region III NRC Senior Resident Inspector, Clinton Power Station NRC Project Manager, Clinton Power Station NRC Senior Resident Inspector, Dresden Nuclear Power Station NRC Project Manager, Dresden Nuclear Power Station NRC Senior Resident Inspector, LaSalle County Station NRC Project Manager, Lasalle County Station NRC Senior Resident Inspector, Nine Mile Point Nuclear Station NRC Project Manager, Nine Mile Point Nuclear Station NRC Senior Resident Inspector, Quad Cities Nuclear Power Station NRC Project Manager, Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety A.L. Peterson, NYSERDA Bridget Frymire, NYSPSC

ATTACHMENT 1 Evaluation of Proposed Changes

Subject:

Application to Revise Primary Containment Isolation Instrumentation Technical Specifications in Accordance with TSTF-306, Revision 2, "Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Applicability 2.2 Variations 2.3 Detailed Description of Proposed Change

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration 4.3 Precedent 4.4 Conclusion

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

ATTACHMENT 1 Evaluation of Proposed Changes Page 2 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests amendments to Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1 and Renewed Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3; Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS) Units 1 and 2; No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (NMP2); and Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2.

CEG requests adoption of TSTF-306, "Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration," Revision 2 (Reference 6.1), an approved change to the Improved Standard Technical Specifications (ISTS), into each unit's TS. The proposed change would revise TS 3.3.6.1, titled "Primary Containment and Drywell Isolation Instrumentation" at CPS and "Primary Containment Isolation Instrumentation" at DNPS, LSCS, NMP2, and QCNPS by adding an ACTIONS note allowing intermittent opening, under administrative control, of penetration flow paths that are isolated.

2.0 DETAILED DESCRIPTION 2.1 Applicability The NRC did not separately document their approval of TSTF-306, Revision 2 with a model SE.

However, TSTF-306, Revision 2 was incorporated in Revision 2 of the ISTS NUREGs. CEG has reviewed TSTF-306, Revision 2 and has determined that the proposed change and associated justification are applicable are applicable to CPS Unit 1; DNPS, Units 2 and 3; LSCS, Units 1 and 2; NMP2, and QCNPS, Units 1 and 2 and justify this amendment for incorporation into the corresponding site's TS.

2.2 Variations The approved Traveler includes two changes:

1. Adding an ACTIONS note allowing intermittent opening, under administrative control, of penetration flow paths that are isolated, and
2. Separating the traversing in-core probe (TIP) system isolation function from the Primary Containment Isolation function with a Required Action to isolate the penetration within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> rather than immediately initiating a unit shutdown.

The first change is the only portion of this traveler being adopted by this amendment request.

The only variation for this portion of the Traveler is that the title of CPS TS 3.3.6.1 is slightly different than the title in the TSTF, but the intent is the same. Therefore, this difference is administrative and does not affect the applicability of TSTF-306 Revision 2 to the CPS TS. Not adopting the second change is also an administrative variation to the Traveler that does not impact the applicability of the Traveler to the CPS, DNPS, LSCS, NMP2, or QCNPS TS.

ATTACHMENT 1 Evaluation of Proposed Changes Page 3 2.3 Detailed Description of Change On July 13, 2000, the NRC approved TSTF-306, a traveler that revises TS 3.3.6.1, "Primary Containment Isolation Instrumentation," by adding note to the TS 3.3.6.1 Actions table that states: "Penetration flow paths may be unisolated intermittently under administrative controls."

This addition is consistent with a similar note in TS 3.6.1.3, "Primary Containment Isolation Valves (PCIVs)."

A second option to breakout the TIP system isolation as a separate isolation Function in Table 3.3.6.1-1 with the associated Action of allowing penetration isolation rather than unit shutdown is not included in this request.

contains a marked-up version of the TS showing the proposed change for each site. Attachment 3 provides the revised (clean) TS pages.

Each site will make supporting changes to the TS Bases in accordance with TS 5.5.10, "Technical Specifications (TS) Bases Control Program." Attachment 4 provides the marked-up TS Bases pages. The TS Bases mark-up pages are being submitted for information only.

3.0 TECHNICAL EVALUATION

The addition of the note that the penetration flow path may be unisolated under administrative control is appropriate since the instrumentation is a support system for PCIVs that already have this allowance in TS 3.6.1.3. Therefore, the addition of the note to TS 3.3.6.1 provides consistency with TS 3.6.1.3. This addition is viewed as a correction of an inconsistency within the TS and is considered administrative in nature.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Appendix A to Title 10 of the Code of Federal Regulations (10 CFR), Part 50, "General Design Criteria for Nuclear Power Plants," contains the following pertinent criteria:

Criterion 54, Piping Systems Penetrating Containment, states:

Piping systems penetrating primary reactor containment shall be provided with leak detection, isolation, and containment capabilities having redundancy, reliability, and performance capabilities which reflect the importance to safety of isolating these piping systems. Such piping systems shall be designed with a capability to periodically test the operability of isolation valves and associated apparatus and to determine if valve leakage is within acceptable limits.

Criterion 55, Reactor Coolant Pressure Boundary Penetrating Containment, states:

Each line that is part of the RCPB and penetrates the primary reactor containment shall be provided with containment isolation valves as follows, unless it can be demonstrated that the containment isolation provisions for a specific class of lines, e.g., instrument lines, are

ATTACHMENT 1 Evaluation of Proposed Changes Page 4 acceptable on some other defined basis:

(1) One locked-closed isolation valve inside and one locked-closed isolation valve outside containment.

(2) One automatic valve inside and one locked-closed isolation valve outside containment.

(3) One locked closed isolation valve inside and one automatic isolation valve outside containment - A simple check valve may not be used as the automatic isolation valve outside containment.

(4) One automatic isolation valve in inside and one automatic isolation valve outside containment - A simple check valve may not be used as the automatic isolation valve outside containment.

Isolation valves outside containment shall be located as close to containment as practical and upon loss of actuating power, automatic isolation valves shall be designed to take the position that provides greater safety.

Other appropriate requirements to minimize the probability or consequences of an accidental rupture of these lines or of lines connected to them shall be provided as necessary to assure adequate safety. Determination of the appropriateness of these requirements, such as higher quality in design, fabrication, and testing, additional provisions for inservice inspection, protection against more severe natural phenomena, and additional isolation valves and containment, shall include consideration of the population density, use characteristics, and physical characteristics of the site environs.

Criterion 56, Primary Containment Isolation, states:

Each line connecting directly to the containment atmosphere and penetrating the primary reactor containment shall be provided with containment isolation valves as follows, unless it can be demonstrated that the containment isolation provisions for a specific class of lines, e.g.,

instrument lines, are acceptable on some other defined basis:

(1) One locked-closed isolation valve inside and one locked-closed isolation valve outside containment.

(2) One automatic valve inside and one locked-closed isolation valve outside containment.

(3) One locked closed isolation valve inside and one automatic isolation valve outside containment - A simple check valve may not be used as the automatic isolation valve outside containment.

(4) One automatic isolation valve in inside and one automatic isolation valve outside containment - A simple check valve may not be used as the automatic isolation valve outside containment.

Isolation valves outside containment shall be located as close to the containment as practical and upon loss of actuating power, automatic isolation valves shall be designed to take the position that provides greater safety.

Criterion 57, Closed System Isolation Valves, states:

Each line penetrating the primary reactor containment that is neither part of the RCPB nor

ATTACHMENT 1 Evaluation of Proposed Changes Page 5 connected directly to the containment atmosphere shall have at least one containment isolation valve which shall be either automatic, locked-closed, or capable of remote-manual operation.

This valve shall be located outside and as close to the containment as practical DNPS and QCNPS were not licensed to the 10 CFR 50, Appendix A, GDC. DNPS and QCNPS UFSAR Section 3.1 "Conformance with NRC Design Criteria," provide an assessment against the 70 draft GDC published in 1967 and concludes that the plant specific requirements are sufficiently similar to the Appendix A GDC. Therefore, this difference does not alter the conclusion that the proposed change is applicable to both DNPS and QCNPS.

4.2 Precedents The NRC approved TSTF-306, Revision 2, on July 13, 2000 (Reference 6.1). The following are examples of BWR/4 and BWR/6 plant-specific NRC-approved adoptions of TSTF-306, Revision 2.

Grand Gulf Nuclear Station, Unit 1, Amendment Number 162, dated January 8, 2004 (Reference 6.4)

Peach Bottom Atomic Power Station, Units 2 and 3, Amendment Numbers 259 and 262, dated May 10, 2006 (Reference 6.3)

River Bend Station, Unit 1, Amendment Number 165, dated August 11, 2009 (Reference 6.5)

Brunswick Steam Electric Plant, Units 1 and 2, Amendments 255 and 283, dated July 23, 2010 (Reference 6.6)

Fermi, Unit 2, Amendment Number 189, dated August 29, 2012 (Reference 6.2) 4.3 No Significant Hazards Consideration Overview CEG requests adoption of TSTF-306, "Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration," an approved change to the Improved Standard Technical Specifications (ISTS),

into the Clinton Power Station (CPS), Unit 1; Dresden Nuclear Power Station (DNPS), Units 2 and 3; LaSalle County Station (LSCS) Units 1 and 2; Nine Mile Point Nuclear Station, Unit 2 (NMP2); and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2 Technical Specifications (TS). The proposed change would revise requirements in TS 3.3.6.1, "Primary Containment Isolation Instrumentation," by adding an ACTIONS note allowing intermittent opening, under administrative control, of penetration flow paths that are isolated.

CEG has evaluated the proposed change against the criteria of 10 CFR 50.92(c) to determine if the proposed changes result in any significant hazards. The following is the evaluation of each of the 10 CFR 50.92(c) criteria:

1.

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

Response

No

ATTACHMENT 1 Evaluation of Proposed Changes Page 6 The addition of a note that the penetration flow path may be unisolated under administrative control simply provides consistency with what is already allowed elsewhere in TS. The Required Actions and their associated Completion Times are not initiating conditions for any accident previously evaluated. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

Response

No No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed change. All systems, structures, and components previously required for the mitigation of a transient remain capable of fulfilling their intended design functions. The proposed changes have no adverse effects on any safety-related system or component and do not challenge the performance or integrity of any safety related system. As a result, no new failure modes are being introduced. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response

No The proposed change will not affect the operation of the plant equipment or the function of any equipment assumed in the accident analysis. The allowance to unisolate a penetration flow path will not have a significant effect on the margin of safety because the penetration flow path can be manually isolated, if needed. This change simply provides consistency with what is already allowed elsewhere in TS. The proposed change does not impact any safety analysis assumptions or results. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

3.3 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.

5.0 ENVIRONMENTAL CONSIDERATION

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, or would change an inspection or surveillance requirement. 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 effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed

ATTACHMENT 1 Evaluation of Proposed Changes Page 7 amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 TSTF-306, Revision 2, " Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration," dated July 13, 2000 (ADAMS Accession No. ML003725864) 6.2 Letter from Mahesh L. Chawla, Project Manager, Office of Nuclear Reactor Regulation, to Mr. Jack M. Davis Senior Vice President and Chief Nuclear Officer Detroit Edison Company, " Fermi 2 - Issuance of Amendment For Adoption of TSTF-306 (TAC No.

ME7720)," dated August 29, 2012 (ADAMS Accession No. ML12207A504) 6.3 Letter from Richard Guzman, Project Manager, Office of Nuclear Reactor Regulation, to Mr. Christopher Crane, President and Chief Nuclear Officer Exelon Nuclear, "Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance Of Amendments Re:

Incorporation Of Previously NRC-Approved Generic Technical Specification Changes, "

dated May 10, 2006 (ADAMS Accession No. ML061070292) 6.4 Letter from Bhalchandra Vaidya, Project Manager, Office of Nuclear Reactor Regulation, to Mr. George A. Williams, Site Vice President, Grand Gulf Nuclear Station, "Grand Gulf Nuclear Station, Unit 1 - Issuance of Amendment Re: Changes to Primary Containment and Drywell Isolation Instrumentation Requirements," dated January 8, 2004 (ADAMS Accession No. ML040090316).

6.5 Letter from Alan B. Wang, Project Manager, Office of Nuclear Reactor Regulation, to Vice President, Operations, River Bend Station, "River Bend Station, Unit 1 - Issuance of Amendment Re: Adoption of Technical Specification Task Force Improved Standard Technical Specification Change Travelers TSTF-163, TSTF-222, TSTF-230, and TSTF-306," dated August 11, 2009 (ADAMS Accession No. ML092010370).

6.6 Letter from Farideh E. Saba, Senior Project Manager, Office of Nuclear Reactor Regulation, to Michael J. Annacone, Vice President, Brunswick Steam Electric Plant, "Brunswick Steam Electric Plant, Units 1 and 2 - Issuance of Amendments Regarding Primary Containment Isolation Instrumentation per TSTF-306, Revision 2," dated July 23, 2010 (ADAMS Accession No. ML100470005).

ATTACHMENT 2a CLINTON POWER STATION UNIT 1 Docket No. 50-461 Facility Operating License No. NPF-62 MARK-UP OF CPS, UNIT 1 TECHNICAL SPECIFICATIONS PAGE

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 CLINTON 3.3-49 Amendment No. 238 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment and Drywell Isolation Instrumentation LCO 3.3.6.1 The primary containment and drywell isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6.1-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME

NOTE----------

Only applicable to Main Steam Line (MSL) isolation Functions.

A. One or more Functions with one channel inoperable.

A.1 Place one channel in affected Function in trip.

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> OR In accordance with the Risk Informed Completion Time Program

NOTE----------

Only applicable to MSL isolation Functions.

B.

One or more Functions with two channels inoperable.

B.1 Place one channel in affected Function in trip.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> OR In accordance with the Risk Informed Completion Time Program

NOTE----------

Only applicable to MSL isolation Functions.

C. One or more Functions with three or more channels inoperable.

C.1 Restore two channels in affected Function to OPERABLE status.

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

1. Penetration flow paths may be unisolated intermittently under administrative controls.

S 2.

ATTACHMENT 2b DRESDEN NUCLEAR POWER STATION UNITS 2 AND 3 Docket Nos. 50-237 and 50-249 Facility Operating License Nos. DPR-19 and DPR-25 MARK-UP OF DNPS, UNITS 2 AND 3 TECHNICAL SPECIFICATIONS PAGES

Primary Containment Isolation Instrumentation 3.3.6.1 Dresden 2 and 3 3.3.6.1-1 Amendment No. 185/180 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6.1-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more required channels inoperable.

A.1 Place channel in trip.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Functions 1.a, 2.a, 2.b, 5.b, and 6.b AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Functions other than Functions 1.a, 2.a, 2.b, 5.b, and 6.b B.

One or more automatic Functions with isolation capability not maintained.

B.1 Restore isolation capability.

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

1. Penetration flow paths may be unisolated intermittently under administrative controls.

S 2.

ATTACHMENT 2c LASALLE COUNTY STATION UNITS 1 AND 2 Docket Nos. 50-373 and 50-374 Facility Operating License Nos. NPF-11 and NPF-18 MARK-UP OF LSCS, UNITS 1 AND 2 TECHNICAL SPECIFICATIONS PAGE

Primary Containment Isolation Instrumentation 3.3.6.1 LaSalle 1 and 2 3.3.6.1-1 Amendment No. 251/237 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6.1-1.

ACTIONS

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

1.

Separate Condition entry is allowed for each channel.

2.

For Function 1.e, when automatic isolation capability is inoperable for required Reactor Building Ventilation System corrective maintenance, filter changes, damper cycling, or required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

3.

For Function 1.e, when automatic isolation capability is inoperable due to loss of reactor building ventilation or for performance of SR 3.6.4.1.3 or SR 3.6.4.1.4, entry into associated Conditions and Required Action may be delayed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

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

A.1 Place channel in trip.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or in accordance with the Risk Informed Completion Time Program for Functions 2.b, 2.f, and 5.a (continued)

1. Penetration flow paths may be unisolated intermittently under administrative controls.

2.

3.

4.

ATTACHMENT 2d NINE MILE POINT NUCLEAR STATION UNIT 2 Docket No. 50-410 Facility Operating License No. NPF-69 MARK-UP OF NMP, UNIT 2 TECHNICAL SPECIFICATIONS PAGES

Primary Containment Isolation Instrumentation 3.3.6.1 NMP2 3.3.6.1-1 Amendment 91, 186 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6.1-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Place channel in trip.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Functions 2.b, 5.b, and 5.c OR

NOTE---------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Functions other than Functions 2.b, 5.b, and 5.c (continued)

1. Penetration flow paths may be unisolated intermittently under administrative controls.

S 2.

ATTACHMENT 2e QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2 Docket Nos. 50-254 and 50-265 Facility Operating License Nos. DPR-29 and DPR-30 MARK-UP OF QCNPS, UNITS 1 AND 2 TECHNICAL SPECIFICATIONS PAGES

Primary Containment Isolation Instrumentation 3.3.6.1 Quad Cities 1 and 2 3.3.6.1-1 Amendment No. 199/195 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6.1-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more required channels inoperable.

A.1 Place channel in trip.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Functions 1.a, 2.a, 2.b, 3.d, 5.b, and 6.b AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Functions other than Functions 1.a, 2.a, 2.b, 3.d, 5.b, and 6.b B.

One or more automatic Functions with isolation capability not maintained.

B.1 Restore isolation capability.

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

S 2.

1. Penetration flow paths may be unisolated intermittently under administrative controls.

ATTACHMENT 3a CLINTON POWER STATION UNIT 1 Docket No. 50-461 Facility Operating License No. NPF-62 CLEAN CPS, UNIT 1 TECHNICAL SPECIFICATIONS PAGES

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 CLINTON 3.3-49 Amendment No. 238 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment and Drywell Isolation Instrumentation LCO 3.3.6.1 The primary containment and drywell isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6.1-1.

ACTIONS

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

1. Penetration flow paths may be unisolated intermittently under administrative controls.
2. Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME

NOTE----------

Only applicable to Main Steam Line (MSL) isolation Functions.

A. One or more Functions with one channel inoperable.

A.1 Place one channel in affected Function in trip.

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> OR In accordance with the Risk Informed Completion Time Program

NOTE----------

Only applicable to MSL isolation Functions.

B.

One or more Functions with two channels inoperable.

B.1 Place one channel in affected Function in trip.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> OR In accordance with the Risk Informed Completion Time Program

NOTE----------

Only applicable to MSL isolation Functions.

C. One or more Functions with three or more channels inoperable.

C.1 Restore two channels in affected Function to OPERABLE status.

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

ATTACHMENT 3b DRESDEN NUCLEAR POWER STATION UNITS 2 AND 3 Docket Nos. 50-237 and 50-249 Facility Operating License Nos. DPR-19 and DPR-25 CLEAN DNPS, UNITS 2 AND 3 TECHNICAL SPECIFICATIONS PAGES

Primary Containment Isolation Instrumentation 3.3.6.1 Dresden 2 and 3 3.3.6.1-1 Amendment No. 185/180 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6.1-1.

ACTIONS

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

1. Penetration flow paths may be unisolated intermittently under administrative controls.
2. Separate Condition entry is allowed for each channel.

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

A.1 Place channel in trip.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Functions 1.a, 2.a, 2.b, 5.b, and 6.b AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Functions other than Functions 1.a, 2.a, 2.b, 5.b, and 6.b B. One or more automatic Functions with isolation capability not maintained.

B.1 Restore isolation capability.

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

ATTACHMENT 3c LASALLE COUNTY STATION UNITS 1 AND 2 Docket Nos. 50-373 and 50-374 Facility Operating License Nos. NPF-11 and NPF-18 CLEAN LSCS, UNITS 1 AND 2 TECHNICAL SPECIFICATIONS PAGES

Primary Containment Isolation Instrumentation 3.3.6.1 LaSalle 1 and 2 3.3.6.1-1 Amendment No. 251/237 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6.1-1.

ACTIONS

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

1.

Penetration flow paths may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each channel.

3.

For Function 1.e, when automatic isolation capability is inoperable for required Reactor Building Ventilation System corrective maintenance, filter changes, damper cycling, or required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

4.

For Function 1.e, when automatic isolation capability is inoperable due to loss of reactor building ventilation or for performance of SR 3.6.4.1.3 or SR 3.6.4.1.4, entry into associated Conditions and Required Action may be delayed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

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

A.1 Place channel in trip.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or in accordance with the Risk Informed Completion Time Program for Functions 2.b, 2.f, and 5.a (continued)

ATTACHMENT 3d NINE MILE POINT NUCLEAR STATION UNIT 2 Docket No. 50-410 Facility Operating License No. NPF-69 CLEAN NMP, UNIT 2 TECHNICAL SPECIFICATIONS PAGES

Primary Containment Isolation Instrumentation 3.3.6.1 NMP2 3.3.6.1-1 Amendment 91, 186 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6.1-1.

ACTIONS

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

1.

Penetration flow paths may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Place channel in trip.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Functions 2.b, 5.b, and 5.c OR

NOTE---------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Functions other than Functions 2.b, 5.b, and 5.c (continued)

ATTACHMENT 3e QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2 Docket Nos. 50-254 and 50-265 Facility Operating License Nos. DPR-29 and DPR-30 CLEAN QCNPS, UNITS 1 AND 2 TECHNICAL SPECIFICATIONS PAGES

Primary Containment Isolation Instrumentation 3.3.6.1 Quad Cities 1 and 2 3.3.6.1-1 Amendment No. 199/195 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6.1-1.

ACTIONS

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

1. Penetration flow paths may be unisolated intermittently under administrative controls.
2. Separate Condition entry is allowed for each channel.

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

A.1 Place channel in trip.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Functions 1.a, 2.a, 2.b, 3.d, 5.b, and 6.b AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Functions other than Functions 1.a, 2.a, 2.b, 3.d, 5.b, and 6.b B. One or more automatic Functions with isolation capability not maintained.

B.1 Restore isolation capability.

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

ATTACHMENT 4a CLINTON POWER STATION UNIT 1 Docket No. 50-461 Facility Operating License No. NPF-62 MARK-UP OF CPS, UNIT 1 TECHNICAL SPECIFICATIONS BASES PAGE (For Information Only)

Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 CLINTON B 3.3-162 Revision No. 0 BASES APPLICABLE 5.g. Manual Initiation SAFETY ANALYSES, LCO, and The Manual Initiation push button channels introduce signals APPLICABILITY into the RHR System isolation logic that are redundant to (continued) the automatic protective instrumentation and provide manual isolation capability. There is no specific USAR safety analysis that takes credit for this Function. It is retained for the isolation function as required by the NRC in the plant licensing basis.

There are two push buttons for the logic, one manual initiation push button per trip system. There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons.

Two channels of the Manual Initiation Function are available and are required to be OPERABLE.

ACTIONS A Note has been provided to modify the ACTIONS related to primary containment and drywell isolation instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition.

Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable primary containment and drywell isolation instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable primary containment and drywell isolation instrumentation channel.

A.1 Because of the diversity of sensors available to provide isolation signals and the redundancy of the isolation design, an allowable out of service time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> has been shown to be acceptable (Ref. 6) to permit restoration of any MSL Function inoperable channel to OPERABLE status.

This out of service time is only acceptable provided the associated Function's inoperable channel is the only (continued) 2 The ACTIONS are modified by two Notes. Note 1 allows penetration flow path(s) to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room. ln this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

ATTACHMENT 4b DRESDEN NUCLEAR POWER STATION UNITS 2 AND 3 Docket Nos. 50-237 and 50-249 Facility Operating License Nos. DPR-19 and DPR-25 MARK-UP OF DNPS, UNITS 2 AND 3 TECHNICAL SPECIFICATIONS BASES PAGES (For Information Only)

Primary Containment Isolation Instrumentation B 3.3.6.1 Dresden 2 and 3 B 3.3.6.1-20 Revision 75 BASES (continued)

ACTIONS A Note has been provided to modify the ACTIONS related to primary containment isolation instrumentation channels.

Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition.

Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable primary containment isolation instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable primary containment isolation instrumentation channel.

A.1 Because of the diversity of sensors available to provide isolation signals and the redundancy of the isolation design, an allowable out of service time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, depending on the Function (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for those Functions that have channel components common to RPS instrumentation and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for those Functions that do not have channel components common to RPS instrumentation), has been shown to be acceptable (Refs. 8 and 9) to permit restoration of any inoperable channel to OPERABLE status.

This out of service time is only acceptable provided the associated Function is still maintaining isolation capability (refer to Required Action B.1 Bases). If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action A.1.

Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue with no further restrictions. Alternately, if it is not desired to place the channel in trip (e.g., as in the case where placing the inoperable channel in trip would result in an isolation), Condition C must be entered and its Required Action taken.

(continued)

The ACTIONS are modified by two Notes. Note 1 allows penetration flow path(s) to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

2

ATTACHMENT 4c LASALLE COUNTY STATION UNITS 1 AND 2 Docket Nos. 50-373 and 50-374 Facility Operating License Nos. NPF-11 and NPF-18 MARK-UP OF LSCS, UNITS 1 AND 2 TECHNICAL SPECIFICATIONS BASES PAGE (For Information Only)

Primary Containment Isolation Instrumentation B 3.3.6.1 LaSalle 1 and 2 B 3.3.6.1-29 Revision 0 BASES APPLICABLE 5.c. Manual Initiation (continued)

SAFETY ANALYSES, LCO, and There is no Allowable Value for this Function, since the APPLICABILITY channels are mechanically actuated based solely on the position of the push buttons.

This Function isolates the Group 6 valves.

ACTIONS Note 1 has been provided to modify the ACTIONS related to primary containment isolation instrumentation channels.

Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition.

Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable primary containment isolation instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable primary containment isolation instrumentation channel.

Note 2 indicates that when automatic isolation capability is lost for Function 1.e, Main Steam Line Tunnel Differential TemperatureHigh (i.e., when both trip systems are inoperable for Function 1.e) due to required Reactor Building Ventilation System corrective maintenance, filter changes, damper cycling, or for performance of required Surveillances, entry into the associated Conditions and Required Actions may be delayed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Similarly, Note 3 indicates that when automatic isolation capability is lost for Function 1.e due to a loss of reactor building ventilation or for performance of SR 3.6.4.1.3 or SR 3.6.4.1.4, entry into the associated Conditions and Required Actions may be delayed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Upon completion of the activities or expiration of the time allowance, the channels must be returned to OPERABLE status or the applicable Conditions entered and Required Actions taken. These Notes are necessary so that testing and (continued)

The ACTIONS are modified by four Notes.

Note 1 allows penetration flow path(s) to be unisolated intermittently under administrative controls.

These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

2 3

4

ATTACHMENT 4d NINE MILE POINT NUCLEAR STATION UNIT 2 Docket No. 50-410 Facility Operating License No. NPF-69 MARK-UP OF NMP, UNIT 2 TECHNICAL SPECIFICATIONS BASES PAGES (For Information Only)

Primary Containment Isolation Instrumentation B 3.3.6.1 NMP2 B 3.3.6.1-28 Revision 0 BASES APPLICABLE 5.f. Manual Initiation SAFETY ANALYSES, LCO, and The Manual Initiation switch and push button channels APPLICABILITY introduce signals into the RHR Shutdown Cooling System isolation (continued) logic that are redundant to the automatic protective instrumentation and provide manual isolation capability.

There is no specific USAR safety analysis that takes credit for this Function. It is retained for overall redundancy and diversity of the isolation function as required by the NRC in the plant licensing basis.

There are four switch and push buttons (with two channels per switch and push button) for the logic, two switch and push button per trip system. Eight channels of the Manual Initiation Function are available and are required to be OPERABLE in MODES 1, 2, and 3 since these are the MODES in which the RHR Shutdown Cooling System Isolation automatic Functions are required to be OPERABLE. While certain automatic Functions are required in MODES 4 and 5, the Manual Initiation Function is not required in MODES 4 and 5, since there are other means (ie., means other than the Manual Initiation switch and push buttons) to manually isolate the RHR Shutdown Cooling System from the control room.

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

This Function isolates the Group 5 valves.

ACTIONS A Note has been provided to modify the ACTIONS related to primary containment isolation instrumentation channels.

Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition.

Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable primary containment isolation instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that (continued)

The ACTIONS are modified by two Notes. Note 1 allows penetration flow path(s) to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

2

ATTACHMENT 4e QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2 Docket Nos. 50-254 and 50-265 Facility Operating License Nos. DPR-29 and DPR-30 MARK-UP OF QCNPS, UNITS 1 AND 2 TECHNICAL SPECIFICATIONS BASES PAGES (For Information Only)

Primary Containment Isolation Instrumentation B 3.3.6.1 Quad Cities 1 and 2 B 3.3.6.1-20 Revision 61 BASES APPLICABLE 6.b. Reactor Vessel Water LevelLow (continued)

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

The Reactor Vessel Water LevelLow Function is only required to be OPERABLE in MODE 3 to prevent this potential flow path from lowering the reactor vessel level to the top of the fuel. In MODES 1 and 2, interlocks and administrative controls ensure that this flow path remains isolated to prevent unexpected loss of inventory via this flow path.

This Function is in the logic for the Group 2 isolation of residual heat removal shutdown cooling suction and injection valves.

ACTIONS A Note has been provided to modify the ACTIONS related to primary containment isolation instrumentation channels.

Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition.

Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable primary containment isolation instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable primary containment isolation instrumentation channel.

(continued) 2 The ACTIONS are modified by two Notes. Note 1 allows penetration flow path(s) to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

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