L-22-286, Supplement to Request for an Amendment to Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time

Supplement to Request for an Amendment to Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time

ML23045A105
Person / Time
Site:	Beaver Valley
Issue date:	02/14/2023
From:	Blair B Energy Harbor Nuclear Corp
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-22-286, EPID L-2022-LLA-0071
Download: ML23045A105 (1)

Text

energy Energy Harbor Nuclear Corp.

harbor Beaver Valley Power Station P.O. Box4 Shippingport, PA 15077 Barry N. Blair 440-280-7300 Site Vice President, Beaver Valley Nuclear February 14, 2023 L-22-286 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Supplement to Request for an Amendment to Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled "Decay Time" (EPID No. L-2022-LLA-0071)

By letter dated May 16, 2022 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML22137A049], Energy Harbor Nuclear Corp.

requested Nuclear Regulatory Commission (NRC) approval for a license amendment request (LAR). The LAR revises Beaver Valley Power Station, Unit 1 and 2 Technical Specifications (TS) to add a Limiting Condition for Operation (LCO) titled "Decay Time" restricting movement involving fuel or over fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. The current TS restrictions on fuel movement involving fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> appear in the applicability statements and conditions of several TS LCOs. The proposed LAR would consolidate those restrictions in the new LCO.

By letter dated November 8, 2022, the NRC staff requested additional information (RAI) regarding the Beaver Valley LAR. Energy Harbor Nuclear Corp. provided written response to the RAI by letter dated December 7, 2022 (ADAMS Accession No. ML22341A614). On December 16, 2022, the NRC staff requested a clarification call to be held between staff reviewers and Energy Harbor Nuclear Corp. personnel to discuss the Beaver Valley Power Station (BVPS) response to SCPB RAl-02. On December 21, 2022, (ADAMS Accession No. ML22350A109), a meeting was held between the NRC and Energy Harbor Nuclear Corp. to discuss the RAI response.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-22-286 Page 2 During the December 21, 2022, meeting the NRC staff expressed that the Energy Harbor Nuclear Corp. response, was inadequate because it did not address how operability of the control room emergency ventilation system (CREVS) is maintained with the proposed deletion of Table 3.3.7-1, "CREVS Actuation Instrumentation," from LCO 3.3.7.

As a result of these discussions, Energy Harbor Nuclear Corp. is proposing to retain Table 3.3.7-1 and remove function 2 and footnote (a) from TS 3.3.7. Therefore, updated information for TS 3.3. 7 is provided to supplement the original LAR.

Specifically, the description and basis of supplemental changes to TS 3.3.7 is provided in Attachment 1. Affected pages of TS 3.3.7, annotated to show the proposed changes, are provided in Attachment 2. Proposed supplemental changes to the TS Bases 3.3.7 are provided for information only in Attachment 3. The other originally proposed TS changes are not affected by this supplement.

The previously provided no significant hazards consideration concluded that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified. The conclusion remains the same.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Manager - Fleet Licensing, at (330) 696-7208.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February J!l!i, 2023.

Barry N. Blair

Beaver Valley Power Station, Unit Nos. 1 and 2 L-22-286 Page3 Attachments:

1. Evaluation of the Proposed Amendment (Supplement)

2. Proposed Technical Specification Changes, Annotated Copy (Supplement)

3. Proposed Technical Specification Bases Changes, Annotated Copy (Supplement) cc: NRC Region I Administrator NRC Resident Inspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative

Attachment 1 L-22-286 Evaluation of the Proposed Amendment (Supplement)

(4 pages follow)

L-22-286 Page 1 of 4 The following excerpt replaces the discussion regarding TS 3.3.7 changes, located in Section 3.0, Technical Evaluation, and beginning on Page 14 of Attachment 1 of letter L-22-053, in its entirety. Portions that are revised from the initial submittal are annotated with a revision bar. Energy Harbor Nuclear Corp. is proposing to retain Table 3.3.7-1 and remove function 2 and footnote (a) from TS 3.3.7. TS 3.3.7 Conditions A, B, and C are no longer being changed. Attachment 2 to this submittal contains a mark-up of the current TS 3.3.7 pages. The markups of the associated TS Bases in are provided for information only. The acronyms LR and LRM are used throughout the excerpt to indicate Licensing Requirement and Licensing Requirements Manual, respectively.

3.3.7 Control Room Emergency Ventilation (CREVS) Actuation Instrumentation For consistency with the original LAR, the Table 3.3.7-1 changes are addressed first.

Table 3.3.7-1 CREVS Actuation Instrumentation Applicable Applicable MODES or MODES or Other Other Specified Specified Function Conditions Function Conditions

1. Manual Initiation 1, 2, 3, 4, (a) 1. Manual Initiation 1, 2, 3, 4, (a)

2. Control Room Area (a) 2. Control Room Area (a)

Radiation Monitors Radiation Monitors

3. Containment Isolation - Refer to 32. Containment Isolation - Refer to Phase B LCO 3.3.2 Phase B LCO 3.3.2 Footnote (a) Footnote (a)

During movement of recently irradiated fuel During movement of recently irradiated fuel assemblies, and during movement of fuel assemblies, and during movement of fuel assemblies over recently irradiated fuel assemblies over recently irradiated fuel assemblies. assemblies.

For entirety of Table 3.3.7-1 see Attachment 2, For entirety of Table 3.3.7-1 changes, see Proposed Technical Specification Changes Attachment 2, Proposed Technical Annotated Copy (Supplement). Specification Changes Annotated Copy (Supplement).

Basis The CREVS actuation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). Footnote (a) appears in the Applicable Modes or Other Specified Conditions column for the Manual Initiation and Control Room Area Radiation Monitors Functions. Footnote (a) is the following applicability statement:

During movement of recently irradiated fuel assemblies, and during movement of fuel assemblies over recently irradiated fuel assemblies.

Manual Initiation The CREVS Manual Initiation function is applicable in MODES 1, 2, 3, 4, and in the condition specified in footnote (a). The CREVS manual initiation function is credited in DBAs in MODES 1 through 4. The MODES 1 through 4 Operability requirements for the CREVS manual initiation function are unchanged by this LAR.

L-22-286 Page 2 of 4 The CREVS Manual Initiation function has been retained in the TS in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, an FHA involving recently irradiated fuel cannot occur and the CREVS instrumentation for Manual Initiation is only required in MODES 1 through 4. Addition of LCO 3.9.7, Decay Time, obviates the need for the CREVS instrumentation for Manual Initiation operability in the condition described in footnote (a).

Control Room Area Radiation Monitors The CREVS Control Room Area Radiation Monitors actuation instrumentation is applicable in the condition specified in footnote (a). The CREVS Control Room Area Radiation Monitors actuation function has been retained in the TS in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future.

As discussed in Section 2.1, the CREVS instrumentation for Manual Initiation and initiation by the Control Room Area Radiation Monitors is not required to mitigate the consequences of an FHA involving non-recently irradiated fuel, that is, fuel that has decayed at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

The instrumentation for CREVS initiation by the Control Room Area Radiation Monitors is required to be operable if fuel movement involving recently irradiated fuel is taking place. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, an FHA involving recently irradiated fuel cannot occur and there are no MODES or other plant conditions for which the instrumentation for CREVS initiation by the Control Room Area Radiation Monitors meets the 10 CFR 50.36 criterion for inclusion in the Technical Specifications.

Removal of the Control Room Area Radiation Monitors function from Table 3.3.7-1, as discussed above, includes removal of the trip setpoints for both units specified in Table 3.3.7-1. The Unit 1 control room area radiation monitors, designated as RM-1RM-218 A & B, are required to be FUNCTIONAL in MODES 1 through 4 as specified in the Unit 1 LRM LR 3.3.14, Control Room Isolation Radiation Monitors. Removal of the setpoint requirement from Table 3.3.7-1 during fuel movement involving recently irradiated fuel is appropriate because proposed LCO 3.9.7, Decay Time, will prohibit this activity. The setpoint requirement in MODES 1 through 4, as specified in Unit 1 LRM LR 3.3.14, is unchanged.

Similarly, the Unit 2 control room area radiation monitors, designated as 2RMC-RQ201 & 202, are required to be FUNCTIONAL in MODES 1 through 4 as specified in the Unit 2 LRM LR 3.3.14, Control Room Isolation Radiation Monitors. Removal of the setpoint requirement from Table 3.3.7-1 during fuel movement involving recently irradiated fuel is appropriate because proposed LCO 3.9.7, Decay Time, will prohibit this activity. The setpoint requirement in MODES 1 through 4, as specified in Unit 2 LRM LR 3.3.14, is unchanged.

Therefore, deletion of footnote (a) and Table 3.3.7-1 Item 2, Control Room Area Radiation Monitors, is consistent with 10 CFR 50.36 and is acceptable.

Containment Isolation - Phase B Table 3.3.7-1 Item 3, Containment Isolation - Phase B (CIB), is renumbered as Function 2.

Currently, Table 3.3.7-1 lists CIB as part of the CREVS Actuation Instrumentation but does not list any requirements for the instrumentation. Instead, Table 3.3.7-1 simply states: Refer to LCO 3.3.2, ESFAS Instrumentation, Function 3.b, for all initiation functions and requirements.

L-22-286 Page 3 of 4 References to LCO 3.3.2 for the CIB appear in the TS Bases.

In Modes 1 through 4, the LOCA accident analysis assumes an automatic Control Room Ventilation System isolation on a CIB signal and subsequent manual initiation of a CREVS fan for filtered makeup and pressurization of the control room. As stated in Table 3.3.7-1, the Operability requirements for CIB, in Modes 1 through 4, are specified in LCO 3.3.2, Engineered Safety Feature Actuation System (ESFAS).

Removal of the SRs is discussed below.

Current CONDITION D Proposed CONDITION D Required Action and associated Completion Required Action and associated Completion Time for Condition A or B not met during Time for Condition A or B not met during movement of recently irradiated fuel movement of recently irradiated fuel assemblies, or during movement of fuel assemblies, or during movement of fuel assemblies over recently irradiated fuel assemblies over recently irradiated fuel assemblies. assemblies.

Basis Condition D requires the immediate suspension of movement of recently irradiated fuel assemblies and immediate suspension of movement of fuel assemblies over recently irradiated fuel assemblies. The addition of LCO 3.9.7, Decay Time, will ensure that movement of recently irradiated fuel assemblies and movement of fuel over recently irradiated fuel assemblies does not occur, obviating the need for this LCO entry Condition. Therefore, deletion of Condition D is acceptable.

- NOTE - - NOTE -

Refer to Table 3.3.7-1 to determine which Refer to Table 3.3.7-1 to determine which SRs apply for each CREVS Actuation SRs apply for each CREVS Actuation Function. Function.

SR 3.3.7.1 Perform CHANNEL CHECK. SR 3.3.7.1 Perform CHANNEL CHECK.

SR 3.3.7.2 Perform COT. SR 3.3.7.2 Perform COT.

SR 3.3.7.3 -----------NOTE------------------ SR 3.3.7.31 -----------NOTE------------------

Verification of setpoint is not Verification of setpoint is not required. required.

Perform TADOT. Perform TADOT.

SR 3.3.7.4 Perform CHANNEL SR 3.3.7.4 Perform CHANNEL CALIBRATION. CALIBRATION.

Basis SR 3.3.7.1, CHANNEL CHECK, ensures that a gross failure of the Control Room Area Radiation Monitors instrumentation has not occurred and is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. SR 3.3.7.2, CHANNEL OPERATIONAL TEST (COT), is performed to ensure the entire channel will perform the intended function. SR 3.3.7.4, CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. Per Table 3.3.7-1, these SRs are only applicable during fuel movements involving recently irradiated fuel. The addition of LCO 3.9.7, Decay Time, will ensure that fuel movement involving recently irradiated fuel assemblies does not occur. Consequently, these SR will no longer be applicable.

L-22-286 Page 4 of 4 The Unit 1 and Unit 2 LR 3.3.14, The Control Room Isolation Radiation Monitors, include the following SRs, which are applicable in MODES 1 through 4: LRS 3.3.14.1, CHANNEL CHECK, which ensures that a gross failure of the Control Room Isolation Radiation Monitors instrumentation has not occurred and is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION; LRS 3.3.14.2, CHANNEL OPERATIONAL TEST, which is performed to ensure the entire channel will perform the intended function; and LRS 3.3.14.3, CHANNEL CALIBRATION, which is a complete check of the instrument loop, including the sensor. The Unit 1 and Unit 2 LRM LR 3.3.14, Control Room Isolation Radiation Monitors, and associated surveillance requirements ensure functionality of the Control Room Isolation Radiation Monitors in MODES 1 through 4 and are unchanged by this LAR.

SR 3.3.7.3 is renumbered as SR 3.3.7.1 as an administrative change.

Based on the above, removing the applicability requirements for these SRs during fuel movement involving recently irradiated fuel, an activity prohibited by the new LCO 3.9.7, Decay Time, is acceptable.

Attachment 2 L-22-286 Proposed Technical Specification Changes, Annotated Copy (Supplement)

(3 pages follow)

CREVS Actuation Instrumentation 3.3.7 3.3 INSTRUMENTATION 3.3.7 Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation LCO 3.3.7 The CREVS actuation instrumentation for each Function in Table 3.3.7-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.7-1 ACTIONS

- NOTE -

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Place one CREVS train in 7 days with one channel or train emergency pressurization inoperable. mode of operation.

B. One or more Functions B.1 Place one CREVS train in Immediately with two channels or two emergency pressurization trains inoperable. mode of operation.

AND B.2 Enter applicable Conditions Immediately and Required Actions of LCO 3.7.10, "CREVS," for one CREVS train made inoperable by inoperable CREVS actuation instrumentation.

C. Required Action and C.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 /> associated Completion Time for Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Beaver Valley Units 1 and 2 3.3.7 - 1 Amendments 278 / 161

CREVS Actuation Instrumentation 3.3.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Suspend movement of Immediately associated Completion recently irradiated fuel Time for Condition A or B assemblies.

not met during movement of recently irradiated fuel AND assemblies, or during movement of fuel D.2 Suspend movement of fuel Immediately assemblies over recently assemblies over recently irradiated fuel assemblies. irradiated fuel assemblies.

SURVEILLANCE REQUIREMENTS

- NOTE -

Refer to Table 3.3.7-1 to determine which SRs apply for each CREVS Actuation Function.

SURVEILLANCE FREQUENCY SR 3.3.7.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.7.2 Perform COT. In accordance with the Surveillance Frequency Control Program SR 3.3.7.31 ------------------------------------------------------------------------

- NOTE -

Verification of setpoint is not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.7.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Beaver Valley Units 1 and 2 3.3.7 - 2 Amendments 292 / 179

CREVS Actuation Instrumentation 3.3.7 Table 3.3.7-1 (page 1 of 1)

CREVS Actuation Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE FUNCTION CONDITIONS CHANNELS REQUIREMENTS TRIP SETPOINT

1. Manual Initiation 1, 2, 3, 4, (a) 2 trains SR 3.3.7.31 NA

2. Control Room Area Radiation (a) 2 SR 3.3.7.1 Unit 1 Monitors SR 3.3.7.2 0.47 mR/hr SR 3.3.7.4 above background Unit 2 0.476 mR/hr above background 3.2 Containment Isolation - Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 3.b, for Phase B all initiation functions and requirements.

(a) During movement of recently irradiated fuel assemblies, and during movement of fuel assemblies over recently irradiated fuel assemblies.

Beaver Valley Units 1 and 2 3.3.7 - 3 Amendments 278 / 161

Attachment 3 L-22-286 Proposed Technical Specification Bases Changes, Annotated Copy (Supplement)

(8 pages follow)

CREVS Actuation Instrumentation INFORMATION ONLY B 3.3.7 B 3.3 INSTRUMENTATION B 3.3.7 Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation BASES BACKGROUND The CREVS provides an enclosed common control room environment from which both units can be operated following an uncontrolled release of radioactivity. During normal operation, the Control Room Ventilation System recirculates the control room air and provides unfiltered makeup air and cooling. Upon receipt of a CREVS actuation signal from either unit, the Unit 1 and 2 control room ventilation intake and exhaust ducts are isolated to prevent unfiltered makeup air from entering the control room. In addition, the CREVS actuation signal from either unit will also automatically start one Unit 2 CREVS fan to provide filtered makeup air to pressurize the control room. If the preferred Unit 2 CREVS fan does not start, the backup Unit 2 fan will automatically start. Unit 1 may take credit for the operation of one or both of the Unit 2 CREVS fans and filters. One of the two Unit 1 CREVS fans and single filter must be manually aligned and placed in service if required. Once the control room ventilation intake and exhaust ducts are isolated, and the CREVS fan is providing filtered makeup, control room ventilation is in the emergency pressurization mode of operation. The CREVS is described in the Bases for LCO 3.7.10, "Control Room Emergency Ventilation System."

The CREVS actuation instrumentation credited in the safety analyses consists of redundant control room area radiation monitors for each unit, Containment Isolation - Phase B (CIB) signal from each unit, and two train related manual switches (pushbuttons) in each unit's control room.

A high radiation signal from the radiation monitors in either unit, a A CIB from either unit, or manual switch actuation from either unit such that both trains of CREVS receive an actuation signal, will initiate the CREVS actuation sequence described above. The CIB Function is discussed in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation." The Function of the Control Room Area Radiation Monitors is discussed in LRM LR 3.3.14.

APPLICABLE The control room must be kept habitable for the operators stationed there SAFETY during accident recovery and post accident operations. The CREVS acts ANALYSES to terminate the supply of unfiltered outside air to the control room, initiate intake air filtration, and pressurize the control room. These actions are necessary to ensure the control room is kept habitable for the operators stationed there during accident recovery and post accident operations by minimizing the radiation exposure of control room personnel.

The applicable safety analyses for all design basis accidents considered in MODES 1, 2, 3, and 4 (except LOCA) assume manual initiation of the emergency pressurization mode of operation of control room ventilation (i.e., control room ventilation isolation, filtered makeup, and Beaver Valley Units 1 and 2 B 3.3.7 - 1 Revision 0

CREVS Actuation Instrumentation INFORMATION ONLY B 3.3.7 BASES APPLICABLE SAFETY ANALYSES (continued) pressurization). The LOCA accident analysis assumes an automatic Control Room Ventilation System isolation on a CIB signal and subsequent manual initiation of a CREVS fan for filtered makeup and pressurization of the control room. Although the CIB signal will automatically start a CREVS fan and filtered flow path, a 30-minute delay to allow for manual initiation of a CREVS fan and filtered flow path is specifically assumed in all analyses to permit the use of a Unit 1 CREVS fan and filtration flow path which require manual operator action to place in service (Ref. 1).

The current safety analyses do not assume the control room area radiation monitors provide a CREVS actuation signal for any design basis accident. However, requirements for the radiation monitors to be OPERABLE are retained in case the monitors are required to support the assumptions of a fuel handling accident analysis for the movement of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) or the movement of fuel over recently irradiated fuel consistent with the guidance of Ref. 2.

The CREVS actuation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requirements ensure that instrumentation necessary to initiate the CREVS is OPERABLE.

1. Manual Initiation The LCO requires two trains OPERABLE. The operator can initiate the CREVS at any time by using either of two switches (pushbuttons) in the control room. This action will cause actuation of all components in the same manner as a single train of the automatic actuation signals (i.e., isolate control room ventilation and start one Unit 2 CREVS fan aligned for filtration and pressurization).

However, when Unit 1 is relying on the Unit 1 CREVS train, as one of the two required trains, only one of the Unit 1 manual pushbuttons is required to start a Unit 2 Fan, but both Unit 1 pushbuttons must be capable of isolating the control room. In this case, the Unit 1 requirement (on Table 3.3.7-1) for two trains of manual initiation is met by one train of manual initiation that is capable of isolating the control room and starting a Unit 2 fan and one train of manual initiation that is capable of isolating the control room. The capability to manually place the Unit 1 CREVS fan and filtered flow path in service is addressed by the OPERABILITY requirements for the Unit 1 CREVS equipment contained in LCO 3.7.10, "Control Room Emergency Ventilation System."

Beaver Valley Units 1 and 2 B 3.3.7 - 2 Revision 0

CREVS Actuation Instrumentation INFORMATION ONLY B 3.3.7 BASES LCO (continued)

The LCO for Manual Initiation ensures the proper amount of redundancy is maintained in the manual actuation circuitry to ensure the operator has manual initiation capability.

Each manual initiation train consists of a switch (pushbutton) in the control room, and the interconnecting wiring to the actuating relays.

2. Control Room Radiation The LCO specifies two required Control Room Area Radiation Monitors to ensure that the radiation monitoring instrumentation necessary to initiate the CREVS remains OPERABLE.

The required Unit 1 radiation monitors are designated RM-1RM-218 A & B with a measurement range of 10-2 to 103 mR/hr. The required Unit 2 radiation monitors are designated 2RMC-RQ201 & 202 with a measurement range of 10-2 to 103 mR/hr.

32. Containment Isolation Phase B (CIB)

Refer to LCO 3.3.2, Function 3.b, for all initiating Functions and requirements.

If one or more of the CIB functions becomes inoperable in such a manner that only the CREVS function is affected, the Conditions applicable to their CIB function need not be entered. The less restrictive Actions specified for inoperability of the CREVS Functions specify sufficient compensatory measures for this case.

APPLICABILITY The CREVS manual actuation instrumentation must be OPERABLE in MODES 1, 2, 3, and 4 to provide the required CREVS initiation assumed in the applicable safety analyses. In MODES 5 and 6, when no fuel movement involving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) is taking place, there are no requirements for CREVS instrumentation OPERABILITY consistent with the safety analyses assumptions applicable in these MODES. In addition, both manual and radiation monitor instrument channels are required OPERABLE when moving recently irradiated fuel or moving fuel over recently irradiated fuel.

Although the movement of recently irradiated fuel is not currently permitted, these requirements are retained in the Technical Specifications in case the CREVS instrumentation is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel, consistent with the guidance of Reference 2.

Beaver Valley Units 1 and 2 B 3.3.7 - 3 Revision 0

CREVS Actuation Instrumentation INFORMATION ONLY B 3.3.7 BASES APPLICABILITY (continued)

The Applicability for the CREVS actuation on the ESFAS CIB Functions are specified in LCO 3.3.2. Refer to the Bases for LCO 3.3.2 for discussion of the CIB Function Applicability. The Applicability for the CREVS actuation on the Control Room Area Radiation Monitors Function is specified in LRM LR 3.3.14.

ACTIONS If the Trip Setpoint is less conservative than required in Table 3.3.7-1, the channel must be declared inoperable immediately and the appropriate Condition entered.

A Note has been added to the ACTIONS indicating that separate Condition entry is allowed for each Function. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.7-1 in the accompanying LCO (i.e., Manual Initiation and CIB Actuation of CREVS). The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

A.1 Condition A applies to the manual initiation train functions and CIB actuation of CREVS. radiation monitor channel Functions, and the manual initiation train Functions.

If one train of CREVS Manual Initiation or CIB actuation of CREVS is inoperable, or one radiation monitor channel is inoperable in one or more Functions, 7 days are permitted to restore it to OPERABLE status. The 7 day Completion Time is the same as is allowed if one train of the mechanical portion of the system is inoperable. The basis for this Completion Time is the same as provided in LCO 3.7.10. If the channel/train cannot be restored to OPERABLE status, one CREVS train must be placed in the emergency pressurization mode of operation as described in LCO 3.7.10 bases. This accomplishes the actuation instrumentation Function and places the unit in a conservative mode of operation.

B.1 and B.2 Condition B applies to the failure of two radiation monitor channels, or two manual CREVS Manual Initiation trains or two channels of CIB actuation of CREVS. The first Required Action is to place one CREVS train in the emergency pressurization mode of operation immediately. This accomplishes the actuation instrumentation Function that may have been lost and places the unit in a conservative mode of operation. The applicable Conditions and Required Actions of LCO 3.7.10 must also be entered for the remaining CREVS train made inoperable by the inoperable actuation instrumentation. This ensures appropriate limits are placed upon train inoperability as discussed in the Bases for LCO 3.7.10.

Beaver Valley Units 1 and 2 B 3.3.7 - 4 Revision 0 INFORMATION ONLY

CREVS Actuation Instrumentation INFORMATION ONLY B 3.3.7 BASES ACTIONS (continued)

C.1 and C.2 Condition C applies when the Required Action and associated Completion Time for Condition A or B have not been met and the unit is in MODE 1, 2, 3, or 4. The unit must be brought to a MODE in which the LCO requirements are not applicable. To achieve this status, the unit must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

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

D.1 and D.2 Condition D applies when the Required Action and associated Completion Time for Condition A or B have not been met when moving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) or fuel assemblies over recently irradiated fuel. Fuel movement involving recently irradiated fuel assemblies must be suspended immediately to reduce the risk of accidents that would require CREVS actuation.

SURVEILLANCE A Note has been added to the SR Table to clarify that Table 3.3.7-1 REQUIREMENTS determines which SRs apply to which CREVS Actuation Functions.

SR 3.3.7.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally 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 of something even 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 unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

Beaver Valley Units 1 and 2 B 3.3.7 - 5 Revision 29

CREVS Actuation Instrumentation INFORMATION ONLY B 3.3.7 BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.

SR 3.3.7.2 A COT is performed on each required channel to ensure the entire channel will perform the intended function. This test verifies the capability of the instrumentation to provide the CREVS actuation. A successful test of any required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications Surveillance Requirements. The setpoints shall be left consistent with the unit specific calibration procedure tolerance.

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

SR 3.3.7.31 SR 3.3.7.31 is the performance of a TADOT. This test is a check of the Manual Actuation Functions. Each Manual Actuation Function is tested.

A successful test of any required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications Surveillance Requirements.

The test may either include actuation of the end device (i.e., dampers close, and fan starts, etc.), or test up to the point of overlap with other tests that demonstrate actuation of the end devices.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Functions tested have no setpoints associated with them.

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CREVS Actuation Instrumentation INFORMATION ONLY B 3.3.7 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.7.4 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

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

REFERENCES 1. Unit 1 UFSAR Table 14.1-1A and Unit 2 UFSAR Table 15.0-13.

2. NUREG-1431, "Standard Technical Specifications for Westinghouse Plants," Rev. 2, April 2001.

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