TSTF-24-04, Transmittal of TSTF-600, Revision 0, Revise the Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) Leakage Testing Frequency

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Transmittal of TSTF-600, Revision 0, Revise the Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) Leakage Testing Frequency
ML24113A002
Person / Time
Site: Technical Specifications Task Force, 99902042
Issue date: 04/22/2024
From: Lashley P, Lueshen K, Richards A, Sparkman W, Vaughan J
PWR Owners Group, Technical Specifications Task Force
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
TSTF-24-04
Download: ML24113A002 (1)


Text

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 804-339-7034 Administration by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF April 22, 2024 TSTF-24-04 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Transmittal of TSTF-600, Revision 0, "Revise the Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) Leakage Testing Frequency" Enclosed for NRC review is TSTF-600, Revision 0, "Revise the Reactor Coolant System (RCS)

Pressure Isolation Valve (PIV) Leakage Testing Frequency."

The following information is provided to assist the NRC staff in prioritizing their review of TSTF-600:

  • Applicability: TSTF-600 is applicable to pressurized water reactors. Administrative changes are made to the boiling water reactor standard technical specifications.
  • Classification: TSTF-600 revises the Surveillance Requirement to perform RCS PIV leakage testing to only reference the Inservice Testing Program for the Frequency.
  • Specialized Resource Availability: TSTF-600 is a normal priority change. The TSTF requests that TSTF-600 be reviewed within 18 months and be made available for adoption under the Consolidated Line Item Improvement Process (CLIIP).

The Technical Specifications Task Force should be billed for the review of the traveler.

TSTF 24-04 April 22, 2024 Page 2 Should you have any questions, please do not hesitate to contact us.

Andrew M. Richards, Jr. (PWROG/W)

Phil H. Lashley (BWROG)

Kevin Lueshen (PWROG/CE)

Jordan L. Vaughan (PWROG/B&W)

Wesley A. Sparkman (PWROG/AP1000)

Enclosure cc:

Michelle Honcharik, Technical Specifications Branch Shivani Mehta, Technical Specifications Branch

TSTF-600, Rev. 0 PWROG-18, Rev. 0 NUREGs Affected:

Revise the Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) Leakage Testing Frequency Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler 1430 1431 1432 1433 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement:

Improvement NRC Fee Status:

Not Exempt Benefit:

Reduces Testing Changes Marked on ISTS Rev 5.0 2194 PWROG RISD & PA (if applicable): PA-LSC-1975 RS-2022-019 See attached.

Revision History OG Revision 0 Revision Status: Active Original Issue Revision

Description:

Revision Proposed by:

PWROG Owners Group Review Information Date Originated by OG:

08-Mar-24 Owners Group Comments (No Comments)

Date: 01-Apr-24 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

01-Apr-24 Date Distributed for Review 01-Apr-24 TSTF Comments:

(No Comments)

Date: 21-Apr-24 TSTF Resolution:

Approved NRC Review Information NRC Received Date:

22-Apr-24 Based on NRC comments on the draft, the justificaiton was revised to focus only on the proposed change and to reflect the NRC's approval of a similar Duke Energy amendment. In addition, two SR Notes were removed from the NUREG-1430, NUREG-1431, and NUREG-1432 SR.

NRC Comments:

22-Apr-24 Copyright(C) 2024, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-600, Rev. 0 PWROG-18, Rev. 0 Affected Technical Specifications SR 3.4.14.1 NUREG(s)- 1430 1431 1432 Only RCS PIV Leakage SR 3.4.14.1 Bases NUREG(s)- 1430 1431 1432 Only RCS PIV Leakage SR 3.4.5.1 NUREG(s)- 1433 Only RCS PIV Leakage SR 3.4.5.1 Bases NUREG(s)- 1433 Only RCS PIV Leakage SR 3.4.6.1 NUREG(s)- 1434 Only RCS PIV Leakage SR 3.4.6.1 Bases NUREG(s)- 1434 Only RCS PIV Leakage SR 3.4.15.1 NUREG(s)- 2194 Only RCS PIV Leakage SR 3.4.15.1 Bases NUREG(s)- 2194 Only RCS PIV Leakage 22-Apr-24 Copyright(C) 2024, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-600, Rev. 0 Page 1

1.

SUMMARY

DESCRIPTION The proposed change revises the Surveillance Requirement (SR) to perform Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage testing to only reference the Inservice Testing Program (IST Program) for the Frequency. The proposed change affects the Standard Technical Specifications (STS) in NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, NUREG-1434, and NUREG-21941.

2.

DETAILED DESCRIPTION 2.1. System Design and Operation RCS PIVs are two normally closed valves in series on a penetration of the reactor coolant pressure boundary (RCPB) that separate the high pressure RCS from an attached low pressure system, such as the Residual Heat Removal System and the low pressure Emergency Core Cooling System. The number, design, and function of the RCS PIVs is plant-specific. The RCS PIVs are described in the plant's Updated Final Safety Analysis Report (UFSAR) and IST Program documentation.

The RCS PIV Leakage Limiting Condition for Operation (LCO) limits the leakage through the RCS PIVs to amounts that do not compromise safety. The RCS PIV leakage limit applies to each valve in the series and is specified in the Technical Specifications (TS) and the ASME OM Code. Any leakage through both RCS PIVs on a penetration is included in "identified leakage,"

and is limited by the TS LCO on "RCS Operational LEAKAGE." All RCS PIVs required to be tested under the plant's TS are also governed by the plant's IST Program.

1 NUREG-1430 provides the STS for the Babcock & Wilcox plant designs.

NUREG-1431 provides the STS for the Westinghouse plant designs.

NUREG-1432 provides the STS for the Combustion Engineering plant designs.

NUREG-1433 provides the STS for the BWR/4 plant designs, but is also representative of the BWR/2, BWR/3, and, in this case, of the BWR/5 plant design.

NUREG-1434 provides the STS for the BWR/6 plant designs, but is also representative in some cases of the BWR/5 plant design.

NUREG-2194 provides the STS for the Westinghouse AP1000 plant design.

TSTF-600, Rev. 0 Page 2 2.2. Current Technical Specifications Requirements NUREG-1430, Specification 3.4.14, "RCS Pressure Isolation Valve (PIV) Leakage,"

SR 3.4.14.1, states:

SR 3.4.14.1


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

1. Not required to be performed in MODES 3 and 4.
2. Not required to be performed on the RCS PIVs located in the DHR flow path when in the DHR mode of operation.
3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.

Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure

[2215] psia and [2255] psia.

[ In accordance with the INSERVICE TESTING PROGRAM OR

[ [18] months]

OR In accordance with the Surveillance Frequency Control Program ]

AND Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months

TSTF-600, Rev. 0 Page 3 AND

[ Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve ]

NUREG-1431, Specification 3.4.14, "RCS Pressure Isolation Valve (PIV) Leakage,"

SR 3.4.14.1, states:

SR 3.4.14.1


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

1. Not required to be performed in MODES 3 and 4.
2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.
3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.

Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure

[2215] psig and [2255] psig.

In accordance with the INSERVICE TESTING PROGRAM, and

[ [18] months OR In accordance with the Surveillance Frequency Control Program ]

AND Prior to entering MODE 2 whenever the unit

TSTF-600, Rev. 0 Page 4 NUREG-1432, Specification 3.4.14, "RCS Pressure Isolation Valve (PIV) Leakage,"

SR 3.4.14.1, states:

SR 3.4.14.1


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

1. Not required to be performed in MODES 3 and 4.
2. Not required to be performed on the RCS PIVs located in the SDC flow path when in the shutdown cooling mode of operation.
3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.

Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure

[2215] psia and [2255] psia.

In accordance with the INSERVICE TESTING PROGRAM, and

[ [18] months OR In accordance with the Surveillance has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve

TSTF-600, Rev. 0 Page 5 Frequency Control Program ]

AND Prior to entering MODE 2 determine the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve NUREG-1433, Specification 3.4.5, "RCS Pressure Isolation Valve (PIV) Leakage," SR 3.4.5.1, states:

SR 3.4.5.1


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

Not required to be performed in MODE 3.

Verify equivalent leakage of each RCS PIV is 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm, at an RCS pressure [ ] and

[ ] psig.

[ In accordance with the INSERVICE TESTING PROGRAM OR

[ [18] months]

OR In accordance with the Surveillance

TSTF-600, Rev. 0 Page 6 Frequency Control Program ]

NUREG-1434, Specification 3.4.5, "RCS Pressure Isolation Valve (PIV) Leakage," SR 3.4.6.1, states:

SR 3.4.6.1


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

Not required to be performed in MODE 3.

Verify equivalent leakage of each RCS PIV is 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm, at an RCS pressure [ ] and

[ ] psig.

[ In accordance with the INSERVICE TESTING PROGRAM OR

[ [18] months]

OR In accordance with the Surveillance Frequency Control Program ]

NUREG-2194, Specification 3.4.15, "RCS Pressure Isolation Valve (PIV) Integrity,"

SR 3.4.15.1, states:

SR 3.4.15.1 Verify leakage of each RCS PIV is equivalent to 0.5 gpm per nominal inch valve size up to a maximum of 5 gpm at an RCS pressure 2215 and 2255 psig.

24 months 2.3. Reason for the Proposed Change The RCS PIV leakage testing required by the STS is also required by the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) as implemented in a site's IST Program. However, NUREG-1430, NUREG-1431, and NUREG-1432 require more frequent testing than is required by the ASME OM Code. The proposed change would align the STS testing frequency with the requirements of the ASME OM Code and eliminate unnecessary testing. Eliminating unnecessary RCS PIV testing could potentially lower outage dose and reduce outage time.

TSTF-600, Rev. 0 Page 7 The proposed change also provides the opportunity for licensees to leverage industry experience.

In addition to publishing a new edition of the OM Code periodically, the ASME OM Committee also publishes new approved or modified Code Cases that provide alternatives developed and approved by ASME or explain the intent of existing Code requirements. Those approved by the NRC may be used voluntarily by licensees as an alternative to compliance with ASME Code provisions that have been incorporated by reference into 10 CFR 50.55a. Revising the Frequency of the RCS PIV leakage verification SR to reference only the IST Program provides licensees with the opportunity to stay aligned with updates in regulation afforded by 10 CFR 50.55a(b). Paragraph (b)(6) of 10 CFR 50.55a allows for the application of the ASME Code Cases listed in Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code," without prior NRC approval subject to the conditions listed in 10 CFR 50.55a(b)(6), paragraphs (i) through (iii). For example, Revision 4 of Regulatory Guide 1.192, endorses ASME OM Code Case OMN-23, "Alternative Rules for Testing Pressure Isolation Valves." This Code Case provides an alternative to the fixed 2-year leakage rate test frequency specified by ASME OM Code Section ISTC-3630(a) and permits the implementation of a condition monitoring program for RCS PIVs. The Code Case does not replace or exclude any test method requirement specified in ISTC-3630, but does allow for the possibility of interval extensions, not to exceed a maximum interval of 6 years, dependent on analysis of tests results and maintenance history of the RCS PIVs. The existing STS testing requirements restrict the ability to implement the condition monitoring program because of the refueling interval and event-driven SR Frequencies. Note that the proposed change does not include permission to use Code Case OMN-23. Licensees will need to follow the appropriate regulatory process to use the Code Case.

NUREG-2194 (AP1000 plants), TS 3.4.15, "RCS Pressure Isolation Valve (PIV) Integrity,"

requires verification of RCS PIV leakage every 24 months with no event-driven Frequencies.

The Bases state that the 24-month frequency is based on the ASME OM Code, and is consistent with the testing Frequency in ASME OM Code Section ISTC 3630(a). The AP1000 SR Frequency is revised to be in accordance with the IST Program for the same reasons given above.

NUREG-1433 and NUREG-1434 (BWR plants) require verification of RCS PIV leakage in accordance with the IST Program or at a fixed Frequency or in accordance with the Surveillance Frequency Control Program (SFCP). There are no testing frequencies related to shutdown conditions or valve actuation. However, all BWR plants with a PIV TS have a frequency that only references the IST Program. The traveler will revise the NUREG-1433 and NUREG-1434 SR Frequency to be in accordance with the IST Program in order to make the BWR STS consistent with the BWR plant TS.

2.4. Description of the Proposed Change The Frequency for NUREG-1430, NUREG-1431, and NUREG-1432, SR 3.4.14.1, is replaced with, "In accordance with the INSERVICE TESTING PROGRAM." Notes 2 and 3 of SR 3.4.14.1 are deleted.

The Frequency for NUREG-1433, SR 3.4.5.1, and for NUREG-1434, SR 3.4.6.1, is replaced with, "In accordance with the INSERVICE TESTING PROGRAM."

TSTF-600, Rev. 0 Page 8 The Frequency for NUREG-2194, SR 3.4.15.1, is replaced with, "In accordance with the Inservice Testing Program." NUREG-2194 has not incorporated TSTF-545, Revision 3, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," which eliminated the TS Section 5.5, "Inservice Testing Program," and added a defined term with the same name.

Only the SR Frequency is revised. The proposed change does not add or remove any RCS PIVs from the plant's TS or ASME OM Code requirements. The proposed change does not alter the method of testing or the SR acceptance criteria.

The SR Bases are revised to reflect the changes to the SR Frequency. In addition, a typographical error in the SR Bases, which refers to 10 CFR 50.55a(g) instead of 10 CFR 50.55a(f), is corrected. The terminology in the SR Bases is updated for consistency.

A model application is attached. The model may be used by licensees desiring to adopt the traveler following NRC approval.

3.

TECHNICAL EVALUATION The traveler replaces RCS PIV testing Frequency with a reference to the IST Program. This results in the following changes:

  • Elimination of a fixed Frequency or a Frequency based on the SFCP and retention or addition of a reference to the IST Program;
  • Elimination of a Frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve, as well as an SR Note associated with the Frequency;
  • Elimination of a Frequency of 9 months prior to entering MODE 2 if the unit has been in Mode 5 for 7 days or more;
  • Elimination of an SR Note that exempts performance for valves associated with an in-service decay heat removal system; and

Each of these changes are evaluated below.

Testing in Accordance with IST Program Instead of the Surveillance Frequency Control Program (SFCP) or on a Fixed Frequency All operating plants except Vogtle 3 & 4 (of the AP1000 design) have adopted a SFCP. If a plant had a fixed Frequency in the RCS PIV testing SR, it would have been replaced with a reference to the SFCP as part of adopting that program. Therefore the [18] month optional Frequency does not appear in any plant's TS and can be removed from the STS.

TSTF-600, Rev. 0 Page 9 Under the SFCP, changes to the Frequencies must be made in accordance with NEI 04-10, Revision 1, "Risk-Informed Method for Control of Surveillance Frequencies." NEI 04-10, Step 7, requires identification of qualitative considerations that must be addressed, such as test intervals specified in applicable industry codes and standards, e.g., ASME, IEEE, etc. Because an RCS PIV testing frequency of 24 months is specified in the ASME OM Code, Section ISTC-3630, paragraph (a), the SR Frequency cannot be extended beyond 24 months under the SFCP without NRC approval of a relief request per 10 CFR 50.55a, paragraph (z), "Alternatives to codes and standards requirements." As a result, the appropriate reference is the ASME OM Code and 10 CFR 50.55a instead of the SFCP. In addition, replacing the NUREG-2194 Frequency of 24 months with a reference to the IST Program is equivalent as the Code specifies a testing frequency of 24 months.

Therefore, changing the SR Frequency to be in accordance with the IST Program instead of a reference to the SFCP or to a fixed Frequency of 24 months has no detrimental effect on testing as the controlling requirement continues to be the ASME OM Code as referenced in 10 CFR 50.55a(f).

Testing Within 24 Hours of Valve Actuation The proposed change would eliminate the requirement to perform the surveillance within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve.

Although the SR provides a limit on allowable RCS PIV leakage rate, its main purpose is to prevent overpressure failure of the low-pressure portions of connecting systems that would result from gross failure of the associated PIVs. Leakage is an indication that the PIVs between the RCS and the connecting systems are degraded or degrading. As such, performing the valve leakage test in conjunction with the other valve tests specified in the ASME OM Code (e.g.,

exercise testing per ASME OM Code Subsection ISTC-3520 and position indication verification per ASME OM Code Subsection ISTC-3700) provides an acceptable method of determining valve integrity. The capability of the valves to transition from open to closed provides assurance that the valves can perform their pressure isolation functions as required. Performance of the separate PIV leak rate testing following valve actuation does not contribute any additional assurance of pressure isolation functional capability but rather provides added assurance of valve integrity, thereby reducing the probability of gross valve failure.

In removing the Frequency requiring performance of leakage testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valves, the TS will instead require a Frequency in accordance with the IST Program, which reinforces the established requirements of the OM Code that are endorsed by the NRC and incorporated by reference in 10 CFR 50.55a(a)(1)(iv). The testing requirements contained within the OM Code are intended to assess the operational readiness of the stated components. Therefore, leakage testing of the RCS PIVs at the frequency established by the IST Program is satisfactory for determining valve integrity, particularly as it relates to operational readiness. Furthermore, this change in frequency would also align with the corresponding SR 3.4.5.1 in NUREG-1433, SR 3.4.6.1 in NUREG-1434, and SR 3.4.15.1 in NUREG-2194.

On October 24, 2023 (Reference 3), the NRC approved a license amendment request submitted by Duke Energy that revised the SR Frequency for RCS PIV leakage testing in the same manner

TSTF-600, Rev. 0 Page 10 that is proposed by this traveler and using a similar justification. See Section 5, "References." In Reference 3, the NRC stated, "the NRC staff has determined that the TS requirement to perform leakage testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation is directed to the same end as testing at a frequency in accordance with the IST Program, which meets the established requirements of the OM Code that are incorporated by reference in 10 CFR 50.55a(a)(1)(iv). Accordingly, the NRC staff finds that the requirement for leakage testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation is unnecessary and may be deleted from the TS."

NUREG-1430, NUREG-1431, and NUREG-1432, SR 3.4.14.1, Note 3, states, "RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided." This Note is discussed in the Bases for the 24-hour testing requirement as, "In addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PIVs disturbed in the performance of this Surveillance should also be tested unless documentation shows that an infinite testing loop cannot practically be avoided." With the elimination of the 24-hour testing Frequency, the Note is no longer needed. The Note does not appear in the STS NUREGs that do not have the 24-hour testing Frequency.

Testing Every 9 Months NUREG-1430, NUREG-1431, and NUREG-1432 require RCS PIV testing every 9 months prior to entering Mode 2 if the plant has been in Mode 5 for seven days or more. The proposed change would remove this SR Frequency. In removing the 9-month Frequency, the TS will instead require leakage testing at a Frequency in accordance with the IST Program, which reinforces the established requirements of the OM Code that are endorsed by the NRC and incorporated by reference in 10 CFR 50.55a(a)(1)(iv). The testing requirements contained within the OM Code are intended to assess the operational readiness of the stated components.

Therefore, leakage testing of the RCS PIVs at the frequency established by the IST Program is satisfactory for determining valve integrity, particularly as it relates to operational readiness.

In Reference 3, the NRC stated, "Despite the IST Program Frequency being based on the requirements of the ASME OM Code incorporated by reference into 10 CFR 50.55a, the site TS SR reflect a requirement to test after any cold shutdown for 7 days or more, effectively restricting the ability of the IST Program and the SFCP to govern the frequency of leakage testing. The proposed change to each sites TS SR Frequency would ensure ASME OM Code testing requirements for the RCS PIVs will be retained in the IST Program and duplicative testing requirements in the TS SR will be removed."

Elimination of an SR Note that Exempts Performance for Valves Associated with an In-Service Decay Heat Removal System NUREG-1430, NUREG-1431, and NUREG-1432, SR 3.4.14.1, Note 2 states, "Not required to be performed on the RCS PIVs located in the [DHR/ RHR/SDC] flow path when in the shutdown cooling mode of operation." The NUREG-1430 Note refers to the Decay Heat Removal (DHR) system, NUREG-1431 refers to the Residual Heat Removal (RHR) system, and NUREG-1432 refers to the Shutdown Cooling (SDC) system. This Note is not needed and is eliminated.

TSTF-600, Rev. 0 Page 11 The Applicability of TS 3.4.14 states:

APPLICABILITY:

MODES 1, 2, and 3, MODE 4, except valves in the [decay heat removal (DHR) /

residual heat removal (RHR) / shutdown cooling (SDC)]

flow path when in, or during the transition to or from, the

[DHR/RHR/SDC] mode of operation.

The Applicability already exempts the RCS PIVs associated with the decay heat removal flow path from testing in Mode 4. Further, SR 3.4.14.1, Note 1, states that the testing is not required to be performed in MODES 3 and 4. The decay heat removal system is only used in Modes 3 and 4 of the Applicability. Therefore, Note 2 is not required and is eliminated. There is no similar note in NUREG-1433, NUREG-1434, or NUREG-2194.

Change to NUREG-1433 and NUREG-1434 The proposed change updates the NUREG-1433 and NUREG-1434 RCS PIV leakage testing frequency as an administrative change. The BWR STS require verification of RCS PIV leakage in accordance with the IST Program and in accordance with the SFCP. However, all BWR plants with an RCS PIV TS have an SR Frequency that references the IST Program and does not reference the SFCP. Therefore, the STS frequency is revised to be consistent with the TS of the BWR plants and to be consistent with the proposed change to the PWR plants.

Additional Considerations In Reference 3, the NRC stated, "The NRC staff finds that the proposed changes to each sites TS SR Frequency would ensure ASME OM Code testing requirements for the RCS PIVs will be retained in the IST Program and duplicative testing requirements in the TS SR will be removed.

Accordingly, the proposed TS SR Frequency change to 'INSERVICE TESTING PROGRAM,' is consistent with the previously approved TSTF-545, 'TS Inservice Testing Program Removal &

Clarify SR Usage Rule Application to Section 5.5 Testing'."

On December 11, 2015, the NRC approved (ADAMS Accession No. ML15314A365) TSTF-545 (ADAMS Accession No. ML15294A555). TSTF-545 removed detailed IST Program requirements from the Administrative Controls section of TS and added a new TS definition for INSERVICE TESTING PROGRAM, which is defined as "the licensee program that fulfills the requirements of 10 CFR 50.55a(f)." The Safety Evaluation states (emphasis added):

Furthermore, the NRC staff notes that the licensee's IST, which is required by 10 CFR 50.54 and 50.55a(f), and which is outside the scope of this amendment request, already contains requirements and considerations similar to those of [the Administrative Controls requirement]. First, the NRC staff finds that the proposed deletion of [the Administrative Controls requirement] is acceptable on the basis that each licensee has its self-contained IST program developed and implemented in accordance with the requirements of the ASME OM Code which adequately defines frequencies. Including testing frequencies and [the Administrative Controls requirement] is duplicative of the requirements in the ASME OM Code as required by 10 CFR 50.55a(f). Therefore, the NRC staff finds the proposed deletion of [the Administrative Controls requirement]

TSTF-600, Rev. 0 Page 12 acceptable on the basis that the changes eliminate an inconsistency between TS and IST program with regard to test delays and are in conformance with 10 CFR 50.55a(f)(5)(ii).

Last, concerning any conflict between IST Code requirements and TS, 10 CFR 50.55a(f)(5)(ii) already specifies that, if a revised inservice test program for a facility conflicts with the TS, then the licensee must apply for an appropriate amendment.

Therefore, deleting the contrary statement from the TS is acceptable.

The same logic is applicable to removing the event-driven and fixed Frequencies from the RCS PIV SR.

In updating the Frequency for verifying RCS PIV leakage, the Frequency would instead reflect being in accordance with the IST Program, which is required by regulation per both 10 CFR 50.54, Condition of licenses, and 10 CFR 50.55a(f). Specifically, paragraph (jj) of 10 CFR 50.54 states that structures, systems, and components (SSCs) subject to the codes and standards in 10 CFR 50.55a must be designed, fabricated, erected, constructed, tested, and inspected to quality standards commensurate with the importance of the safety function to be performed. Paragraph 10 CFR 50.55a(f), "lnservice Testing Requirements," requires, in part, that inservice testing of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda incorporated by reference in the regulations. Exceptions are allowed where alternatives have been authorized by the NRC pursuant to paragraphs 10 CFR 50.55a(z)(1) and 10 CFR 50.55a(z)(2).

The SR 3.0.2 Bases discuss testing performed in accordance with the IST Program. It states, "Examples of where SR 3.0.2 does not apply are the Containment Leakage Rate Testing Program required by 10 CFR 50, Appendix J, and the inservice testing of pumps and valves in accordance with applicable American Society of Mechanical Engineers Operation and Maintenance Code, as required by 10 CFR 50.55a. These programs establish testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot in and of themselves extend a test interval specified in the regulations directly or by reference."

Therefore, the proposed change is consistent with the NRC staff's approval of TSTF-545, the NRC staff's approval of a similar change as documented in Reference 3, 10 CFR 50.54 and 10 CFR 50.55a(f), and the treatment of similar Frequencies in the TS.

4.

REGULATORY EVALUATION 4.1. Applicable Regulatory Requirements/Criteria The RCS PIVs are referred to in 10 CFR 50.2, "Definitions," under "Reactor coolant pressure boundary," and 10 CFR 50.55a(c), "Reactor coolant pressure boundary," as two normally closed valves in series within the reactor coolant pressure boundary, which separate the high pressure RCS from attached lower pressure systems.

Section 50.55a, Codes and standards, in 10 CFR in 50.55a(f)(4), Inservice testing standards requirement for operating plants, states, in part, that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants (OM) Code, Division 1 must meet the inservice testing (IST) requirements (except

TSTF-600, Rev. 0 Page 13 design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in 10 CFR 50.55a(f)(2) and (3) and that are incorporated by reference in 10 CFR 50.55a(a)(1)(iv), to the extent practical within the limitations of design, geometry, and materials of construction of the components.

Section 50.55a(f)(5)(ii), IST program update: Conflicting IST Code requirements with technical specifications, states, in part, that if a revised inservice test program for a facility conflict with the TS for the facility the licensee must apply for an amendment of the TS to conform the TS to the revised program.

The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) requires:

Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 ["Contents of applications; technical information"]. The Commission may include such additional technical specifications as the Commission finds appropriate.

Per 10 CFR 50.90, whenever a holder of a license desires to amend the license, application for an amendment must be filed with the Commission, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.

Per 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate.

Section IV, "The Commission Policy," of the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58FR39132), dated July 22, 1993, states in part that improved STS have been developed and will be maintained for each NSSS owners group. The Commission Policy encourages licensees to use the improved STS as the basis for plant-specific Technical Specifications. The industry's proposal of travelers and the NRC's approval of travelers is the method used to maintain the improved STS as described in the Commission's Policy. Following NRC approval, licensees adopt travelers into their plant-specific technical specifications following the requirements of 10 CFR 50.90. Therefore, the traveler process facilitates the Commission's policy while satisfying the requirements of the applicable regulations.

The regulation at 10 CFR 50.36(a)(1) also requires the application to include a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls." The proposed traveler revises the Bases to be consistent with the Technical Specifications, and therefore, is in compliance with 10 CFR 50.36(a)(1).

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3)

TSTF-600, Rev. 0 Page 14 the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

4.2. Precedent On February 1, 2023, Duke Energy submitted a license amendment request (Reference 1) for Catawba Nuclear Station, McGuire Nuclear Station, Oconee Nuclear Station, H. B. Robinson Steam Electric Plant, and Shearon Harris Nuclear Power Plant, that proposed to revise the SR Frequency for RCS PIV leakage testing in the same manner that is proposed by this traveler and using a similar justification. A supplement was submitted on July 7, 2023 (Reference 2) which confirmed that all RCS PIVs required to be tested by the TS are included in the respective site's IST Program. The model application of this traveler requires each licensee adopting the traveler to make a similar confirmation. The license amendment was approved on October 24, 2023 (Reference 3). The NRC's technical evaluation of the Duke Energy change is also applicable to the proposed traveler.

5.

REFERENCES

1. Letter from Shawn Gibby (Duke Energy) to the Document Control Desk (NRC),

"License Amendment Request to Revise Restrictive Technical Specification Surveillance Requirement Frequencies," dated February 1, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23032A162).

2. Letter from Shawn Gibby (Duke Energy) to Document Control Desk (NRC),

"Response to Request for Additional Information Regarding the License Amendment Request to Revise Restrictive Technical Specification Surveillance Requirement Frequencies," dated July 7, 2023 (ADAMS Accession No. ML23188A176).

3. Letter from Shawn A. Williams (NRC) to Shawn Gibby (Duke Energy), "Catawba Nuclear Station, Unit Nos. 1 and 2; Shearon Harris Nuclear Power Plant, Unit No. 1; McGuire Nuclear Station, Unit Nos. 1 and 2; Oconee Nuclear Station, Unit Nos. 1, 2, and 3; and H. B. Robinson Steam Electric Plant, Unit No. 2 - Issuance of Amendments to Revise Restrictive Technical Specification Surveillance Requirement Frequencies,"

dated October 24, 2023 (ADAMS Accession No. ML23241A987).

TSTF-600, Rev. 0 Model Application

TSTF-600, Rev. 0 Page 1

[DATE]

10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 DOCKET NO. PLANT NAME

[5X]-[xxx]

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-600, "Revise the Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) Leakage Testing Frequency" Pursuant to 10 CFR 50.90, [LICENSEE] is submitting a request for an amendment to the Technical Specifications (TS) for [PLANT NAME, UNIT NOS.].

[LICENSEE] requests adoption of TSTF-600, "Revise the Reactor Coolant System (RCS)

Pressure Isolation Valve (PIV) Leakage Testing Frequency," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-600 revises the Surveillance Requirement (SR) to perform RCS PIV leakage testing to only reference the Inservice Testing Program (IST Program) for the Frequency.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. [Attachment 2 provides revised (clean) TS pages.] Attachment 3 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

[LICENSEE] requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within [90] days.

There are no regulatory commitments in this letter.

[In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated [STATE] Official.]

[In accordance with 10 CFR 50.30(b), a license amendment request must be executed in a signed original under oath or affirmation. This can be accomplished by attaching a notarized affidavit confirming the signature authority of the signatory, or by including the following statement in the cover letter: "I declare under penalty of perjury that the foregoing is true and correct.

Executed on (date)." The alternative statement is pursuant to 28 USC 1746. It does not require notarization.]

TSTF-600, Rev. 0 Page 2 If you should have any questions regarding this submittal, please contact [NAME, TELEPHONE NUMBER].

Sincerely,

[Name, Title]

Enclosure:

Description and Assessment Attachments: 1.

Proposed Technical Specification Changes (Mark-Up)

[2. Revised Technical Specification Pages]

3.

Proposed Technical Specification Bases Changes (Mark-Up) - For Information Only

[The attachments are to be provided by the licensee and are not included in the model application.]

cc:

NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact

TSTF-600, Rev. 0 Page 3 ENCLOSURE DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

[LICENSEE] requests to adoption of TSTF-600, "Revise the Reactor Coolant System (RCS)

Pressure Isolation Valve (PIV) Leakage Testing Frequency," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-600 revises the Surveillance Requirement (SR) to perform RCS PIV leakage testing to only reference the Inservice Testing Program (IST Program) for the Frequency.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation

[LICENSEE] has reviewed the safety evaluation for TSTF-600 provided to the Technical Specifications Task Force in a letter dated [DATE]. This review included the NRC staffs evaluation, as well as the information provided in TSTF-600. [LICENSEE] has concluded that the justifications presented in TSTF-600 and the safety evaluation prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this amendment for the incorporation of the changes to the [PLANT] TS.

[LICENSEE] confirms that the RCS PIVs required to be tested by the [PLANT] TS are included in the [PLANT] IST Program.

2.2 Variations

[LICENSEE is not proposing any variations from the TS changes described in TSTF-600 or the applicable parts of the NRC staffs safety evaluation.] [LICENSEE is proposing the following variations from the TS changes described in TSTF-600 or the applicable parts of the NRC staffs safety evaluation:]

[The [PLANT] TS utilize different [numbering][and][titles] than the STS on which TSTF-600 was based. Specifically, [describe differences between the plant-specific TS numbering and/or titles and the TSTF-600 numbering and titles.] These differences are administrative and do not affect the applicability of TSTF-600 to the [PLANT] TS.]

[The [PLANT] TS contain requirements that differ from the STS on which TSTF-600 was based but are encompassed by the TSTF-600 justification. (Describe the differences)]

[The [PLANT] TS do not include the changes in TSTF-545, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing." As a result, the

[PLANT] TS include a TS Section [5.5], "Inservice Testing Program," and do not include a defined term, "INSERVICE TESTING PROGRAM." Therefore, the proposed SR Frequency does not use a capitalized defined term.]

TSTF-600, Rev. 0 Page 4

[The [PLANT] TS are not based on the standard TS on which TSTF-600 is based. (Describe the differences. For example, changes to SR 4.0.5, SRs that reference the IST or 4.0.5, and SRs that contain requirements that are in STS programs.)]

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis

[LICENSEE] requests adoption of TSTF-600, "Revise the Reactor Coolant System (RCS)

Pressure Isolation Valve (PIV) Leakage Testing Frequency," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] Technical Specifications (TS). TSTF-600 revises the Surveillance Requirement (SR) to perform RCS PIV leakage testing to only reference the Inservice Testing Program (IST Program) for the Frequency.

[LICENSEE] has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Response: No The proposed change revises the SR to perform RCS PIV leakage testing to only reference the IST Program for the Frequency. Performance of the RCS PIV leakage testing is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The RCS PIVs for which the Surveillance Frequencies are revised are still required to be operable, meet the acceptance criteria for the SRs, and be capable of performing any mitigative function assumed in the accident analysis. The proposed test frequency has been endorsed in the American Society of Mechanical Engineers (ASME) Operations and Maintenance Code for Nuclear Power Plants, and in NRC regulation 10 CFR 50.55a. As a result, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

Response: No The proposed change revises the SR to perform RCS PIV leakage testing to only reference the IST Program for the Frequency. No new or different accidents result from utilizing the proposed change. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any

TSTF-600, Rev. 0 Page 5 new or different requirements on the affected components. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

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

Response: No The proposed change revises the SR to perform RCS PIV leakage testing to only reference the IST Program for the Frequency. The proposed change does not change the SR acceptance criteria or adversely affect existing plant safety margins. The reliability of the equipment assumed to operate in the safety analysis is not significantly affected. As such, there are no changes being made to safety analysis assumptions, safety limits or limiting safety system settings that would significantly affect plant safety as a result of the proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, [LICENSEE] concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

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

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, 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 a 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 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.

TSTF-600, Rev. 0 Technical Specifications Changes

RCS PIV Leakage 3.4.14 Babcock & Wilcox STS 3.4.14-3 Rev. 5.0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1


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

1. Not required to be performed in MODES 3 and 4.
2. Not required to be performed on the RCS PIVs located in the DHR flow path when in the DHR mode of operation.
3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.

Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure

[2215] psia and [2255] psia.

[ In accordance with the INSERVICE TESTING PROGRAM OR

[ [18] months]

OR In accordance with the Surveillance Frequency Control Program ]

AND TSTF-600, Rev. 0

RCS PIV Leakage 3.4.14 Babcock & Wilcox STS 3.4.14-4 Rev. 5.0 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND

[ Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve ]

SR 3.4.14.2


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

[ Not required to be met when the DHR System autoclosure interlock is disabled in accordance with LCO 3.4.12.

Verify DHR System autoclosure interlock prevents the valves from being opened with a simulated or actual RCS pressure signal [425] psig.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ] ]

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.14 Babcock & Wilcox STS B 3.4.14-4 Rev. 5.0 BASES ACTIONS (continued)

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time after exceeding the limit allows for the restoration of the leaking PIV to OPERABLE status. This timeframe considers the time required to complete this Action and the low probability of a second valve failing during this period. ]


REVIEWERS NOTE-----------------------------------

Two options are provided for Required Action A.2. The second option (72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> restoration) is appropriate if isolation of a second valve would place the unit in an unanalyzed condition.

B.1 and B.2 If leakage cannot be reduced, [the system isolated,] or other Required Actions accomplished, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant 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 to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This Required Action may reduce the leakage and also reduces the potential for a LOCA outside the containment. The allowed Completion Times are reasonable based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

C.1 The inoperability of the DHR autoclosure interlock renders the DHR suction isolation valves incapable of isolating in response to a high pressure condition and preventing inadvertent opening of the valves at RCS pressures in excess of the DHR systems design pressure. If the DHR autoclosure interlock is inoperable, operation may continue as long as the DHR suction penetration is closed by at least one closed manual or deactivated automatic valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This action accomplishes the purpose of the autoclosure function.

SURVEILLANCE SR 3.4.14.1 REQUIREMENTS Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 or A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition.

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.14 Babcock & Wilcox STS B 3.4.14-5 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)

For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.

Testing is to be performed every 9 months, but may be extended, if the plant does not go into MODE 5 for at least 7 days.


REVIEWERS NOTE-----------------------------------

If the testing is within the scope of the licensee's INSERVICE TESTING PROGRAM, the Frequency "In accordance with the INSERVICE TESTING PROGRAM" should be used. Otherwise, the periodic Frequency of [18] months or the reference to the Surveillance Frequency Control Program should be used.

[ The [18 month] Frequency is in accordance with the requirements of consistent with 10 CFR 50.55a(fg) (Ref. 8) as contained in the INSERVICE TESTING PROGRAM, is within frequency allowed by the American Society of Mechanical Engineers (ASME) Code (Ref. 7), and is based on the need to perform such surveillances under conditions that apply during an outage and the potential for an unplanned transient if the Surveillance were performed with the plant at power.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

[ In addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PIVs disturbed in the performance of this Surveillance should also be tested unless documentation shows that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the valve has been reseated. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable and practical time limit for performing this test after opening or reseating a valve. ]

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.14 Babcock & Wilcox STS B 3.4.14-6 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)

The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures.

Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complimentary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. In addition, this Surveillance is not required to be performed on the DHR System when the DHR System is aligned to the RCS in the decay heat removal mode of operation. PIVs contained in the DHR flow path must be leakage rate tested after DHR is secured and stable unit conditions and the necessary differential pressures are established.


REVIEWERS NOTE-----------------------------------

The "24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />..." Frequency of performance for Surveillance Requirement 3.4.14.1 is not required for B&W Owner's Group plants licensed prior to 1980. These plants were licensed prior to the NRC establishing formal Technical Specification controls for pressure isolation valves. Subsequently, these earlier plants had their licenses modified by NRC Order to require certain PIV testing Frequencies (excluding the "24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />..." Frequency) be included in that plant's Technical Specifications. Based upon the information available to the Staff at the time, the content of those Orders was considered acceptable. Since 1980, the NRC Staff has determined an additional PIV leakage rate determination is required within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following actuation of the valve and flow through the valve. This is necessary in order to ensure the PIV's ability to support the integrity of the reactor coolant pressure boundary.

The Revised Standard Technical Specifications include the "24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />..."

Frequency to reflect current NRC Staff position on the need to include this test requirement within Technical Specifications.

[ SR 3.4.14.2 and SR 3.4.14.3 Verifying that the DHR autoclosure interlocks are OPERABLE ensures that RCS pressure will not pressurize the DHR system beyond 125% of its design pressure of [600] psig. The interlock setpoint that prevents the valves from being opened is set so the actual RCS pressure must be

< [425] psig to open the valves. This setpoint ensures the DHR design pressure will not be exceeded and the DHR relief valves will not lift. [ The 18 month Frequency is based on the need to perform this Surveillance TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.14 Babcock & Wilcox STS B 3.4.14-7 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued) under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance was performed with the reactor at power. The 18 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

These SRs are modified by Notes allowing the DHR autoclosure function to be disabled when using the DHR System suction relief valve for cold overpressure protection in accordance with LCO 3.4.12. ]

REFERENCES

1.

10 CFR 50.2.

2.

10 CFR 55a(c).

3.

10 CFR 50, Appendix A, Section V, GDC 55.

4.

NUREG-75/014, Appendix V, October 1975.

5.

NUREG-0677, NRC, May 1980.

6.

[Document containing list of PIVs.]

7.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

8.

10 CFR 50.55a(fg).

TSTF-600, Rev. 0

RCS PIV Leakage 3.4.14 Westinghouse STS 3.4.14-3 Rev. 5.0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1


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

1. Not required to be performed in MODES 3 and 4.
2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.
3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.

Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure

[2215] psig and [2255] psig.

In accordance with the INSERVICE TESTING PROGRAM, and

[ [18] months OR In accordance with the Surveillance Frequency Control Program ]

AND Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND TSTF-600, Rev. 0

RCS PIV Leakage 3.4.14 Westinghouse STS 3.4.14-4 Rev. 5.0 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve SR 3.4.14.2


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

[ Not required to be met when the RHR System autoclosure interlock is disabled in accordance with SR 3.4.12.7.

Verify RHR System autoclosure interlock prevents the valves from being opened with a simulated or actual RCS pressure signal [425] psig.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ] ]

SR 3.4.14.3


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

[ Not required to be met when the RHR System autoclosure interlock is disabled in accordance with SR 3.4.12.7.

Verify RHR System autoclosure interlock causes the valves to close automatically with a simulated or actual RCS pressure signal [600] psig.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ] ]

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.14 Westinghouse STS B 3.4.14-5 Rev. 5.0 BASES ACTIONS (continued)

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

C.1 The inoperability of the RHR autoclosure interlock renders the RHR suction isolation valves incapable of isolating in response to a high pressure condition and preventing inadvertent opening of the valves at RCS pressures in excess of the RHR systems design pressure. If the RHR autoclosure interlock is inoperable, operation may continue as long as the affected RHR suction penetration is closed by at least one closed manual or deactivated automatic valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This Action accomplishes the purpose of the autoclosure function.

SURVEILLANCE SR 3.4.14.1 REQUIREMENTS Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 and Required Action A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition.

For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.14 Westinghouse STS B 3.4.14-6 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)

Testing is to be performed every [9] months, but may be extended, if the plant does not go into MODE 5 for at least 7 days. [ The [18 month]

Frequency is in accordance with the requirements of consistent with 10 CFR 50.55a(fg) (Ref. 9) and the INSERVICE TESTING PROGRAM, is within frequency allowed by the American Society of Mechanical Engineers (ASME) Code (Ref. 8), and is based on the need to perform such surveillances under the conditions that apply during an outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

In addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PIVs disturbed in the performance of this Surveillance should also be tested unless documentation shows that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the valve has been reseated. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable and practical time limit for performing this test after opening or reseating a valve.

The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures.

Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complementary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. In addition, this Surveillance is not required to be performed on the RHR System when the RHR System is aligned to the RCS in the shutdown cooling mode of operation. PIVs contained in the RHR shutdown cooling flow path must be leakage rate tested after RHR is secured and stable unit conditions and the necessary differential pressures are established.

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.14 Westinghouse STS B 3.4.14-8 Rev. 5.0 BASES REFERENCES (continued)

7.

WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

8.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

9.

10 CFR 50.55a(fg).

TSTF-600, Rev. 0

RCS PIV Leakage 3.4.14 Combustion Engineering STS 3.4.14-3 Rev. 5.0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1


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

1. Not required to be performed in MODES 3 and 4.
2. Not required to be performed on the RCS PIVs located in the SDC flow path when in the shutdown cooling mode of operation.
3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.

Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure

[2215] psia and [2255] psia.

In accordance with the INSERVICE TESTING PROGRAM, and

[ [18] months OR In accordance with the Surveillance Frequency Control Program ]

AND Prior to entering MODE 2 determine the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND TSTF-600, Rev. 0

RCS PIV Leakage 3.4.14 Combustion Engineering STS 3.4.14-4 Rev. 5.0 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve SR 3.4.14.2


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

[ Not required to be met when the SDC System autoclosure interlock is disabled in accordance with SR 3.4.12.7.

Verify SDC System autoclosure interlock prevents the valves from being opened with a simulated or actual RCS pressure signal [425] psig.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ] ]

SR 3.4.14.3


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

[ Not required to be met when the SDC System autoclosure interlock is disabled in accordance with SR 3.4.12.7.

Verify SDC System autoclosure interlock causes the valves to close automatically with a simulated or actual RCS pressure signal [600] psig.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ] ]

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.14 Combustion Engineering STS B 3.4.14-5 Rev. 5.0 BASES SURVEILLANCE SR 3.4.14.1 REQUIREMENTS Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 or A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition.

For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.

Testing is to be performed every 9 months, but may be extended if the plant does not go into MODE 5 for at least 7 days. [ The [18] month Frequency is in accordance with the requirements of consistent with 10 CFR 50.55a(fg) (Ref. 8) and the INSERVICE TESTING PROGRAM and is within frequency allowed by the American Society of Mechanical Engineers (ASME) Code (Ref. 7), and is based on the need to perform the Surveillance under conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

In addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PIVs disturbed in the performance of this Surveillance should also be tested unless documentation shows that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the valve has been reseated. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable and practical time limit for performing this test after opening or reseating a valve.

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.14 Combustion Engineering STS B 3.4.14-6 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)

The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures.

Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complimentary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. In addition, this Surveillance is not required to be performed on the SDC System when the SDC System is aligned to the RCS in the shutdown cooling mode of operation. PIVs contained in the SDC shutdown cooling flow path must be leakage rate tested after SDC is secured and stable unit conditions and the necessary differential pressures are established.

SR 3.4.14.2 and SR 3.4.14.3 Verifying that the SDC autoclosure interlocks are OPERABLE ensures that RCS pressure will not pressurize the SDC system beyond 125% of its design pressure of [600] psig. The interlock setpoint that prevents the valves from being opened is set so the actual RCS pressure must be

< [425] psig to open the valves. This setpoint ensures the SDC design pressure will not be exceeded and the SDC relief valves will not lift. [ The 18 month Frequency is based on the need to perform these Surveillances under conditions that apply during a plant outage. The 18 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.14 Combustion Engineering STS B 3.4.14-7 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)

The SRs are modified by Notes allowing the SDC autoclosure function to be disabled when using the SDC System suction relief valves for cold overpressure protection in accordance with SR 3.4.12.7.

REFERENCES

1.

10 CFR 50.2.

2.

10 CFR 50.55a(c).

3.

10 CFR 50, Appendix A, Section V, GDC 55.

4.

WASH-1400 (NUREG-75/014), Appendix V, October 1975.

5.

NUREG-0677, May 1980.

6. [ Document containing list of PIVs. ]
7.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

8.

10 CFR 50.55a(fg).

TSTF-600, Rev. 0

RCS PIV Leakage 3.4.5 General Electric BWR/4 STS 3.4.5-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2 Isolate the high pressure portion of the affected system from the low pressure portion by use of a second closed manual, de-activated automatic, or check valve.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1


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

Not required to be performed in MODE 3.

Verify equivalent leakage of each RCS PIV is 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm, at an RCS pressure [ ] and

[ ] psig.

[ In accordance with the INSERVICE TESTING PROGRAM OR

[ [18] months]

OR In accordance with the Surveillance Frequency Control Program ]

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.5 General Electric BWR/4 STS B 3.4.5-4 Rev. 5.0 BASES ACTIONS (continued)

B.1 and B.2 If leakage cannot be reduced or the system isolated, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This action may reduce the leakage and also reduces the potential for a LOCA outside the containment. The Completion Times are reasonable, based on operating experience, to achieve the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS Performance of leakage testing on each RCS PIV is required to verify that leakage is below the specified limit and to identify each leaking valve.

The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition. For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.


REVIEWERS NOTE-----------------------------------

If the testing is within the scope of the licensee's INSERVICE TESTING PROGRAM, the Frequency "In accordance with the INSERVICE TESTING PROGRAM" should be used. Otherwise, the periodic Frequency of 18 months or the reference to the Surveillance Frequency Control Program should be used.

[ The 18 month Frequency is in accordance with the requirements of required by 10 CFR 50.55a(f) (Ref. 8) the INSERVICE TESTING PROGRAM is within the ASME Code Frequency requirement and is based on the need to perform this Surveillance during an outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

OR The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.5 General Electric BWR/4 STS B 3.4.5-5 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This SR is modified by a Note that states the leakage Surveillance is not required to be performed in MODE 3. Entry into MODE 3 is permitted for leakage testing at high differential pressures with stable conditions not possible in the lower MODES.

REFERENCES

1.

10 CFR 50.2.

2.

10 CFR 50.55a(c).

3.

10 CFR 50, Appendix A, GDC 55.

4.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

5.

NUREG-0677, May 1980.

6.

FSAR, Section [ ].

7.

NEDC-31339, November 1986.

8.

10 CFR 50.55a(f).

TSTF-600, Rev. 0

RCS PIV Leakage 3.4.6 General Electric BWR/6 STS 3.4.6-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2 Isolate the high pressure portion of the affected system from the low pressure portion by use of a second closed manual, deactivated automatic, or check valve.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1


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

Not required to be performed in MODE 3.

Verify equivalent leakage of each RCS PIV is 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm, at an RCS pressure

[1040] psig and [1060] psig.

[ In accordance with INSERVICE TESTING PROGRAM OR

((18] months OR In accordance with the Surveillance Frequency Control Program ]

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.6 General Electric BWR/6 STS B 3.4.6-4 Rev. 5.0 BASES ACTIONS (continued) reduces the potential for a LOCA outside the containment. The Completion Times are reasonable, based on operating experience, to achieve the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.6.1 REQUIREMENTS Performance of leakage testing on each RCS PIV is required to verify that leakage is below the specified limit and to identify each leaking valve.

The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition. For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.


REVIEWERS NOTE-----------------------------------

If the testing is within the scope of the licensee's INSERVICE TESTING PROGRAM, the Frequency "In accordance with the INSERVICE TESTING PROGRAM" should be used. Otherwise, the periodic Frequency of 18 months or the reference to the Surveillance Frequency Control Program should be used.

[ The 18 month Frequency is in accordance with the requirements of required by 10 CFR 50.55a(f) (Ref. 8)the INSERVICE TESTING PROGRAM is within the ASME Code Frequency requirement and is based on the need to perform this Surveillance under the conditions that apply during an outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

TSTF-600, Rev. 0

RCS PIV Leakage B 3.4.6 General Electric BWR/6 STS B 3.4.6-5 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)

Therefore, thisThis SR is modified by a Note that states the leakage Surveillance is not required to be performed in MODE 3. Entry into MODE 3 is permitted for leakage testing at high differential pressures with stable conditions not possible in the lower MODES.

REFERENCES

1.

10 CFR 50.2.

2.

10 CFR 50.55a(c).

3.

10 CFR 50, Appendix A, GDC 55.

4.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

5.

NUREG-0677, May 1980.

6.

FSAR, Section [ ].

7.

NEDC-31339, November 1986.

8.

10 CFR 50.55a(f).

TSTF-600, Rev. 0

RCS PIV Integrity 3.4.15 AP1000 STS 3.4.15-2 Rev. 0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.2 Verify a second OPERABLE PIV can meet the leakage limits. This valve is required to be a check valve, or a closed valve, if it isolates a line that penetrates containment.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> B.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 /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Verify leakage of each RCS PIV is equivalent to 0.5 gpm per nominal inch valve size up to a maximum of 5 gpm at an RCS pressure 2215 and 2255 psig.

In accordance with the Inservice Testing Program24 months TSTF-600, Rev. 0

RCS PIV Integrity B 3.4.15 AP1000 STS B 3.4.15-5 Rev. 0 BASES SURVEILLANCE REQUIREMENTS SR 3.4.15.1 Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 and Required Action A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch nominal valve size up to a minimum of 5 gpm applies to each valve. Leakage testing requires a stable pressure condition.

For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.

The Frequency is in accordance with the requirements of established by the ASME Codetesting Testing shall be performed every 24 months, a typical refueling cycle. The 24 month Frequency is consistent with 10 CFR 50.55a(fg) (Ref. 4) as contained in the Inservice Testing Program and is within frequency allowed by the American Society of Mechanical Engineers (ASME) OM Code (Ref. 5).

REFERENCES

1.

10 CFR 50.2.

2.

10 CFR 50.55a(c).

3.

10 CFR 50, Appendix A, Section V, GDC 55.

4.

10 CFR 50.55a(fg).

5.

ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants.

TSTF-600, Rev. 0