ML24142A438

Enclosure 2: Hope Creek Generating Station Improved Technical Specifications Conversion - Volume 10

ML24142A438
Person / Time
Site:	Hope Creek
Issue date:	05/20/2024
From:	Public Service Enterprise Group
To:	Office of Nuclear Reactor Regulation
Shared Package
ML24142A428	List: LR-N24-0029, Enclosure 2: Hope Creek Generating Station Improved Technical Specifications Conversion - Volume 15 ML24142A407 ML24142A429 ML24142A430 ML24142A431 ML24142A432 ML24142A433 ML24142A434 ML24142A435 ML24142A436 ML24142A437 ML24142A438 ML24142A439 ML24142A440 ML24142A441 ML24142A442 ML24142A444 ML24142A446
References
LR-N24-0029, LAR H24-02
Download: ML24142A438 (1)

Text

ENCLOSURE 2 VOLUME 10 HOPE CREEK GENERATING STATION IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Revision 0

LIST OF ATTACHMENTS

1.

ITS 3.5.1, ECCS - Operating

2.

ITS 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control

3.

ITS 3.5.3, RCIC System

ATTACHMENT 1 ITS 3.5.1, ECCS - Operating

Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)

3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND RPV WATER INVENTORY CONTROL 3/4.5.1 ECCS - OPERATING LIMITING CONDITION FOR OPERATION 3.5.1 The emergency core cooling systems shall be OPERABLE with:

a.

The core spray system (CSS) consisting of two subsystems with each subsystem comprised of:

1.

Two OPERABLE core spray pumps, and

2.

An OPERABLE flow path capable of taking suction from the suppression chamber and transferring the water through the spray sparger to the reactor vessel.

b.

The low pressure coolant injection (LPCI) system of the residual heat removal system consisting of four subsystems with each subsystem comprised of:

1.

One OPERABLE LPCI pump, and

2.

An OPERABLE flow path capable of taking suction from the suppression chamber and transferring the water to the reactor vessel.

c.

The high pressure coolant injection (HPCI) system consisting of:

1.

One OPERABLE HPCI pump, and

2.

An OPERABLE flow path capable of taking suction from the suppression chamber and transferring the water to the reactor vessel.

d.

The automatic depressurization system (ADS) with five OPERABLE ADS valves.

APPLICABILITY:

OPERATIONAL CONDITION 1, 2*,** #, and 3*,**,##.

The HPCI system is not required to be OPERABLE when reactor steam dome pressure is less than or equal to 200 psig.

The ADS is not required to be OPERABLE when reactor steam dome pressure is less than or equal to 100 psig.

See Special Test Exception 3.10.6.

Two LPCI subsystems of the RHR system may be inoperable in that they are aligned in the shutdown cooling mode when the reactor vessel pressure is less than the RHR shutdown cooling permissive setpoint.

HOPE CREEK 3/4 5-1 Amendment 213 A01 ITS 3.5.1 ITS LCO 3.5.1

, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM function of safety/relief LA01 Each ECCS injection/spray subsystem and LCO 3.5.1 Applicability LCO 3.5.1 Applicability LCO 3.5.1 NOTE with with valves are Low pressure coolant injection (LPCI) considered OPERABLE during alignment and operation for decay heat removal with Residual Heat Removal (RHR)

SDC pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

A02 MODE MODES steam dome A05 200 L01 A09

EMERGENCY CORE COOLING SYSTEMS (ECCS) AND RPV WATER INVENTORY CONTROL LIMITING CONDITION FOR OPERATION ACTION:

NOTE: LCO 3.0.4.b is not applicable to HPCI.

a.

For the Core Spray system:

1.

With one core spray subsystem inoperable, provided that at least two LPCI subsystem are OPERABLE, restore the inoperable core spray subsystem to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2.

With both core spray subsystems inoperable, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b.

For the LPCI system:

1.

With one LPCI subsystem inoperable, provided that at least one core spray subsystem is OPERABLE, restore the inoperable LPCI subsystem to OPERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2.

With two LPCI subsystems inoperable, provided that at least one core spray subsystem is operable, restore at least one LPCI subsystem to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3.

With three LPCI subsystems inoperable, provided that both core spray subsystems are OPERABLE, restore at least two LPCI subsystems to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

4.

With all four LPCI subsystems inoperable, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.*

Whenever two or more RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

HOPE CREEK 3/4 5-2 Amendment No. 213 A01 ITS 3.5.1 ITS

, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Actions Note ACTION B ACTION J L02 MODE 3 ACTION L Two M01 L02 ACTION A ACTION J ACTION C ACTION D ACTION L Enter LCO 3.0.3 immediately.

MODE 3 MODE 3 ACTION J MODE 3 ACTION J L02 L02 M01 or more low pressure ECCS injection/spray Enter LCO 3.0.3 immediately.

A06 s

EMERGENCY CORE COOLING SYSTEMS (ECCS) AND RPV WATER INVENTORY CONTROL LIMITING CONDITION FOR OPERATION ACTION: (Continued)

c.

For the HPCI system:

1.

With the HPCI system inoperable, provided the Core Spray System, the LPCI system, the ADS and the RCIC system are OPERABLE, restore the HPCI system to OPERABLE status within 14 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to 200 psig within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2.

With the HPCI system inoperable, provided the ADS and RCIC system are OPERABLE:

a. With either one LPCI subsystem or one CSS subsystem inoperable, restore the HPCI system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or restore the LPCI subsystem/CSS subsystem to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to 200 psig within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b. With one LPCI subsystem and one CSS subsystem inoperable, restore the HPCI system to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or restore the LPCI subsystem or CSS subsystem to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to 200 psig within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

d.

For the ADS:

1.

With one of the above required ADS valves inoperable, provided the HPCI system, the core spray system and the LPCI system are OPERABLE, restore the inoperable ADS valve to OPERABLE status within 14 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to 100 psig within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2.

With two or more of the above required ADS valves inoperable, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to 100 psig within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

e.

With a CSS and/or LPCI header P instrumentation channel inoperable, restore the inoperable channel to OPERABLE status within 7 days or determine the ECCS header P locally at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; otherwise, declare the associated ECCS subsystem inoperable.

f.

The discharge line "keep filled" alarm instrumentation associated with a LPCI and/or CSS subsystem(s) may be in an inoperable status for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for required surveillance testing* provided that the "keep filled" alarm instrumentation associated with at least one LPCI or CSS subsystem serviced by the affected "keep filled" system remains OPERABLE; otherwise, perform Surveillance Requirement 4.5.1.a.1.a.

g.

In the event an ECCS system is actuated and injects water into the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date. The current value of the usage factor for each affected safety injection nozzle shall be provided in this Special Report whenever its value exceeds 0.70.

This includes testing of the "Reactor Coolant System Interface Valves Leakage Pressure Monitors" associated with LPCI and CSS in accordance with Surveillance 4.4.3.2.3 HOPE CREEK 3/4 5-3 Amendment No. 226 A01 ITS 3.5.1 ITS

, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM ACTION E Required Action E.1 Required Action E.2 ACTION J L02 LA04 LA03 L04 Immediately Verify by administrative means is AND ACTION J MODE 3 ACTION F Required Action F.1 Required Action F.2 low pressure ECCS injection/spray AND inoperable core spray MODE 3 L02 L02 MODE 3 ACTION G Required Action G.1 Required Action G.2 Required Action G.3 ACTION J to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> restore core spray ACTION J L02 ACTION H MODE 3 ACTION K 36 A03 Add proposed ACTION I L03 LA02 Add proposed ACTION L Condition: One ADS valve inoperable and two or more low pressure ECCS injection/spray subsystems inoperable.

A07 Add proposed ACTION L Condition: HPCI System and two or more LPCI subsystems inoperable.

A07 L01 200 Add proposed ACTION L Condition: HPCI System and one or more ADS valves A07

EMERGENCY CORE COOLING SYSTEMS (ECCS) AND RPV WATER INVENTORY CONTROL SURVEILLANCE REQUIREMENTS 4.5.1 The emergency core cooling systems shall be demonstrated OPERABLE by:

a.

In accordance with the Surveillance Frequency Control Program:

1.

For the core spray system, the LPCI system, and the HPCI system:

a)

Verifying by venting at the high point vents that the system piping from the pump discharge valve to the system isolation valve is filled with water.

b)

Verifying that each valve, manual, power operated or automatic, in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct* position.

c)

Verify the RHR System cross tie valves on the discharge side of the pumps are closed and power, if any, is removed from the valve operators.

2.

For the HPCI system, verifying that the HPCI pump flow controller is in the correct position.

b.

Verifying that, when tested pursuant to the INSERVICE TESTING PROGRAM:

1.

The two core spray system pumps in each subsystem together develop a flow of at least 6150 gpm against a test line pressure corresponding to a reactor vessel pressure of 105 psi above suppression pool pressure.

2.

Each LPCI pump in each subsystem develops a flow of at least 10,000 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of 20 psid.

3.

The HPCI pump develops a flow of at least 5600 gpm against a test line pressure corresponding to a reactor vessel pressure of 1000 psig when steam is being supplied to the turbine at 1000, +20, -80 psig.**

c.

In accordance with the Surveillance Frequency Control Program:

1.

For the core spray system, the LPCI system, and the HPCI system, performing a system functional test which includes simulated automatic actuation of the system throughout its emergency operating sequence and verifying that each automatic valve in the flow path actuates to its correct position. Actual injection of coolant into the reactor vessel may be excluded from this test.

Except that an automatic valve capable of automatic return to its ECCS position when an ECCS signal is present may be in position for another mode of operation.

The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure is adequate to perform the test.

HOPE CREEK 3/4 5-4 Amendment No. 213 A01 ITS 3.5.1 ITS

, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM SR 3.5.1.1 SR 3.5.1.2 SR 3.5.1.4 SR 3.5.1.5 (CS)

SR 3.5.1.5 (LPCI)

SR 3.5.1.6 (HPCI)

SR 3.5.1.8 SR 3.5.1.8 Note

, for each ECCS injection/spray subsystem, ECCS injection/spray subsystem and valve A01 Add SR 3.5.1.2 NOTE L05 LA05 In accordance with Verify the following ECCS pumps develop the specified flow rate against a system head system head system head SR 3.5.1.6 NOTE Not required to be until and flow are L06 can rate system head Verify each ECCS injection/spray subsystem actuates on an actual or initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

A08 Vessel injection/spray L07 A04 Each ECCS injection/spray subsystem and LCO 3.5.1 LA05 1020 psig and 920 psig above primary containment pressure associated injection LA06 each (s)

EMERGENCY CORE COOLING SYSTEMS (ECCS) AND RPV WATER INVENTORY CONTROL SURVEILLANCE REQUIREMENTS (Continued)

2.

For the HPCI system, verifying that:

a)

The system develops a flow of at least 5600 gpm against a test line pressure corresponding to a reactor vessel pressure of 200 psig, when steam is being supplied to the turbine at 200 + 15, -0 psig.**

b)

The suction is automatically transferred from the condensate storage tank to the suppression chamber on a condensate storage tank water level - low signal and on a suppression chamber -

water level high signal.

3.

Performing a CHANNEL CALIBRATION of the CSS, and LPCI system discharge line "keep filled" alarm instrumentation.

4.

Performing a CHANNEL CALIBRATION of the CSS header P instrumentation and verifying the setpoint to be the allowable value of 4.4 psid.

5.

Performing a CHANNEL CALIBRATION of the LPCI header P instrumentation and verifying the setpoint to be the allowable value of 1.0 psid.

d.

For the ADS:

1.

In accordance with the Surveillance Frequency Control Program, performing a CHANNEL FUNCTIONAL TEST of the Primary Containment Instrument Gas System low-low pressure alarm system.

2.

In accordance with the Surveillance Frequency Control Program:

a)

Performing a system functional test which includes simulated automatic actuation of the system throughout its emergency operating sequence, but excluding actual valve actuation.

b)

Verify that when tested pursuant to the INSERVICE TESTING PROGRAM, that each ADS valve is capable of being opened.

c)

Performing a CHANNEL CALIBRATION of the Primary Containment Instrument Gas System low-low pressure alarm system and verifying an alarm setpoint of 85 +/- 2 psig on decreasing pressure.

The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure is adequate to perform the test.

HOPE CREEK 3/4 5-5 Amendment No. 213 A01 ITS 3.5.1 ITS

, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM SR 3.5.1.7 (HPCI)

SR 3.5.1.9 SR 3.5.1.9 Note SR 3.5.1.10 SR 3.5.1.7 NOTE Not required to be until and flow are L06 The HPCI pump can rate system head In accordance with may be excluded Verify the ADS actuates on an actual or initiation signal, A04 L07 LA05 LA03 LA04 LA04 SR 3.5.1.3 L08 L08 Add proposed SR 3.1.5.3 215 psig

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 1 of 15 ADMINISTRATIVE CHANGES A01 In the conversion of the Hope Creek Generating Station (HCGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 5.0, "Standard Technical Specifications-General Electric BWR/4 Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.5.1 Applicability states, in part, OPERATIONAL CONDITION 1, 2 *, **,

and 3 *, **. Footnote

• states The HPCI system is not required to be OPERABLE when reactor steam dome pressure is less than or equal to 200 psig. Footnote ** states The ADS is not required to be OPERABLE when reactor steam dome pressure is less than or equal to 100 psig. ITS 3.5.1 Applicability states MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure 200 psig. This changes the CTS by incorporating the ITS MODE definition, and stating LCO 3.5.1 is required in MODE 1, and MODES 2 and 3 except high pressure coolant injection (HPCI) and Automatic Depressurization System (ADS) valves are not required to be OPERABLE with reactor steam dome pressure 200 psig. See Discussion of Change (DOC) L01 for the ADS applicability change.

The purpose of CTS 3.5.1 Applicability is to establish the Operational Condition (i.e., ITS MODE) in which the LCO is required. This change is acceptable because the Applicability of MODE is not changed. This change is designated as an administrative change and is acceptable because it does not result in a technical change to the CTS.

A03 CTS 3.5.1 Action c.1 requires, in part, with the HPCI system inoperable, operation may continue provided the RCIC system is OPERABLE. ITS 3.5.1 ACTION E states, in part, with the HPCI System inoperable, immediately verify by administrative means RCIC System is OPERABLE. This changes the CTS Action by clarifying the time to verify the RCIC System is OPERABLE.

The purpose of the CTS action is to immediately verify the RCIC System is OPERABLE, since an OPERABLE RCIC is required to allow the 14 day completion time to restore the HPCI System to OPERABLE status. If the OPERABILITY of the RCIC System cannot be verified, the unit must be in at least MODE 3 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This change clarifies the intent of the existing action and is acceptable because ITS Section 1.3 defines the Immediately Completion Time as the Required Action be pursued without delay and in a controlled manner. This change is acceptable because the intent of the action is not changed. This change is designated as administrative because it does not result in technical changes to the CTS.

A04 CTS 4.5.1.b.3 (HPCI high pressure flow verification) and CTS 4.5.1.c.2 (HPCI low pressure flow verification) are modified by footnote ** that states, "The

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 2 of 15 provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure is adequate to perform the test." ITS SR 3.5.1.6 and ITS SR 3.5.1.7 do not include this statement in the Surveillance Note. The statement "the provisions of Specification 4.0.4 are not applicable" is not required in the ITS because the current surveillance footnote is specifically designed to allow entry into a Mode of the LCO Applicability before the Surveillance is required if the Surveillance can only be performed in the applicable MODE. This change is designated as an administrative change and is acceptable because it does not result in a technical change to the CTS.

A05 CTS 3.5.1 OPERATIONAL CONDITION 2 includes footnote # which states See Special Test Exception 3.10.6. The CTS 3.10.6 special test exception permits training startups to be performed while in MODE 2 to provide plant startup experience for reactor operators. Similarly, ISTS 3.10.10, Training Startups, permits training startups to be performed while in MODE 2 to provide plant startup experience for reactor operators. However, Hope Creek Generating Station (HCGS) is not adopting ISTS 3.10.10 special operation since it is no longer needed. HCGS uses the plant simulator to train operators on plant startups. This changes the CTS by eliminating a special test exception.

This change is designated as an administrative change and is acceptable because it does not result in a technical change to the CTS.

A06 CTS 3.5.1, Action b.4 footnote

• states Whenever two or more RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods. This footnote is deleted because it does not establish any additional requirements or restrictions on plant operation.

Furthermore, this footnote could be interpreted as a relaxation of the requirement to achieve COLD SHUTDOWN. ITS 3.5.1 Action L requires entry into LCO 3.0.3 when all four LPCI subsystems are inoperable since the plant is in a condition outside of the accident analyses and may result in the ECCS not being able to perform its intended safety function. In addition, ITS Specifications 3.4.8, RHR Shutdown Cooling System - Hot Shutdown, and 3.4.9, RHR Shutdown Cooling System - Cold Shutdown, provide requirements for RHR SDC for Hot Shutdown and Cold Shutdown conditions. This change is designated as an administrative change because deleting the footnote does not alter the requirements or restrictions on plant operation regarding RHR SDC. This change is designated as an administrative change and is acceptable because it does not result in a technical change to the CTS.

A07 CTS 3.5.1 provides Actions for the ECCS injection/spray subsystems (i.e., HPCI, LPCI, core spray) and ADS. Three configurations of inoperable ECCS injection/spray subsystems and ADS do not have a dedicated action, and therefore require entry into CTS 3.0.3. Specifically, the condition of: 1) HPCI System and two or more LPCI subsystems inoperable, 2) One ADS valve inoperable and two or more low pressure ECCS injection/spray subsystems inoperable, and 3) HPCI System and one or more ADS valves inoperable.

Consistent with the ITS presentation, ITS 3.5.1 ACTION L directs immediate entry into LCO 3.0.3. This changes the CTS by adding an action directing entry into LCO 3.0.3 when the HPCI System and two or more LPCI subsystems are inoperable, and when one ADS valve and two or more low pressure ECCS

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 3 of 15 injection/spray subsystems are inoperable. This change is consistent with the intent of CTS for the specified combination of ECCS inoperabilities and is an ITS presentation preference, ensuring the appropriate action is taken. This change is designated as an administrative change and is acceptable because it does not result in a technical change to the CTS.

A08 CTS 4.5.1.c.1 requires verifying that each automatic valve in the flow path actuates to its correct position. ITS SR 3.5.1.8 requires verifying that the core spray, LPCI, or HPCI System actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position. This changes the CTS by adding the exception for valves that are locked, sealed, or otherwise secured in the actuated position to the surveillance requirement.

The purpose of CTS 4.5.1.c is to verify the core spray, LPCI, or HPCI System actuates on an automatic initiation signal. CTS 4.5.1.c implies that the position of valves is not in the correct (i.e., actuated) position. However, system valves that are locked, sealed, or otherwise secured in the actuated position are in the actuated position and will not change. This change is acceptable because ITS SR 3.5.1.8 retains the requirement to verify the core spray, LPCI, or HPCI System actuates on an automatic initiation signal. This change provides additional clarification to the existing requirement and is designated as an administrative change because it does not result in a technical change to the CTS.

A09 CTS 3.5.1 Applicability is modified by footnote ## which states that two LPCI subsystems of the RHR system may be inoperable in that they are aligned in the shutdown cooling mode when the reactor vessel pressure is less than the RHR shutdown cooling permissive setpoint. The Note to ITS LCO 3.5.1 includes this allowance by stating that low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) shutdown cooling permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable. This changes the CTS by modifying the presentation in the ITS consistent with the ISTS.

The purpose of the CTS allowance is to modify the LPCI System requirements to allow two LPCI subsystems to be aligned to the RHR SDC mode while the LPCI injection mode is required in MODE 3 provided the plant is operating below the SDC permissive pressure interlock. The presentation modifies the LCO instead of the Applicability, which allows the LPCI subsystems to be aligned to the RHR SDC mode of operation and still be considered OPERABLE provided the subsystem can be manually realigned to the LPCI injection mode. The HCGS LPCI System design includes only two RHR SDC subsystems, therefore, it is unnecessary to specify two in the Note. This change is considered a presentation preference change and does not alter the intent of the current allowance. Therefore, this change is designated as an administrative change and is acceptable because it does not result in a technical change to the CTS.

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 4 of 15 MORE RESTRICTIVE CHANGES M01 CTS 3.5.1, Action a.2 (two CS subsystems inoperable) and Action b.4 (four LPCI subsystems inoperable) require the unit be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS 3.5.1 ACTION L states, in part, two core spray subsystems inoperable, or four or more low pressure ECCS injection/spray subsystems inoperable (e.g., four LPCI subsystems inoperable), immediately enter LCO 3.0.3. This changes the CTS by requiring additional requirements of initiating action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit in MODE 2 in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />.

The purpose of CTS Actions for the stated conditions is to place the plant in a safe condition when multiple ECCS subsystems are inoperable. When multiple ECCS subsystems are inoperable, as stated in Condition L, the plant is in a condition outside of the accident analyses. The LOCA analysis shown in NEDC-33172P, SAFER/GESTR-LOCA Loss of Coolant Accident Analysis for Hope Creek Generating Station at Power Uprate," March 2005 (ADAMS Accession No. ML053250469; not publicly available), assumes at least one CS subsystem and three LPCI subsystems, and either the ADS function of five S/RVs or the HPCI System are available. Therefore, with two core spray subsystems inoperable, or four or more low pressure ECCS injection/spray subsystems inoperable, continued operation is not warranted and LCO 3.0.3 must be entered immediately. LCO 3.0.3 requires initiating action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in MODE 2 in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, MODE 3 in 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and MODE 4 in 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. The change is designated as more restrictive because more stringent actions are imposed in ITS than in CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.5.1 requires the emergency core cooling systems (ECCS) be OPERABLE with:

a. The core spray system consisting of two subsystems with each subsystem comprised of two OPERABLE core spray pumps, and an OPERABLE flow path capable of taking suction from the suppression chamber and transferring the water through the spray sparger to the reactor vessel.

b. The low pressure coolant injection (LPCI) system consisting of four subsystems with each subsystem comprised of one OPERABLE LPCI pump, and an OPERABLE flow path capable of taking suction from the suppression chamber and transferring the water to the reactor vessel.

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 5 of 15

c. The high pressure coolant injection (HPCI) system consisting of one OPERABLE HPCI pump, and an OPERABLE flow path capable of taking suction from the suppression chamber and transferring the water to the reactor vessel.

ITS LCO 3.5.1 requires each ECCS injection/spray subsystem be OPERABLE (i.e., core spray, LPCI, and HPCI subsystems). ITS 3.5.1 does not include these details of ECCS injection/spray subsystems. This changes the CTS by moving these system design details to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS LCO 3.5.1 retains the requirement that each ECCS injection/spray subsystem shall be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 4 Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS 3.5.1 Action f footnote

• states This includes testing of the "Reactor Coolant System Interface Valves Leakage Pressure Monitors" associated with LPCI and CSS in accordance with Surveillance 4.4.3.2.3. CTS 4.4.3.2.3 requires the high/low pressure interface valve leakage pressure monitors be demonstrated OPERABLE with alarm setpoints per Table 3.4.3.2-2, which provides the Reactor Coolant System (RCS) interface valves leakage pressure monitor alarm setpoints and allowable values. ITS 3.4.5 does not contain a list of the interface valve leakage pressure monitors and does not require verification of the alarm setpoints. This alarm only function is not assumed in any accident analysis. Alarm only functions do not relate directly to the Operability requirements for the RCS or the ECCS. ITS does not specify indication only, alarm only, or test equipment to be Operable to support Operability of a system or component. This changes the CTS by relocating the CTS high/low pressure interface valve leakage pressure monitors action, surveillance, and table to the Technical Requirements Manual (TRM).

The removal of these details, which are related to system design and operation, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.4.5 retains the requirement that the leakage from each RCS PIV shall be within limits (OPERABLE) and ITS SR 3.4.5.1 requires periodic Surveillances to determine RCS PIV leakage is within limits. It is not necessary for the list of high/low pressure interface valve leakage pressure monitors to be in the Technical Specifications to ensure that the RCS PIVs are OPERABLE. Additionally, ITS 5.5.2, Primary Coolant Sources Outside Containment, program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 6 of 15 fluids during a serious transient or accident to levels as low as practicable. The systems include the Core Spray System and the Residual Heat Removal System. This program, in part, periodically requires an integrated leak rate test of the specified systems. Also, this change is acceptable because these types of procedural details will be adequately controlled in the TRM. The TRM is incorporated by reference into the UFSAR and any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information relating to high/low pressure interface valve leakage pressure monitors and associated alarm function is being removed from the Technical Specification LA03 (Type 4 Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS 4.5.1.c.3 requires a Channel Calibration of the core spray and LPCI keep fill instrumentation. ITS 3.5.1 does not include this testing requirement. This changes the CTS by relocating a surveillance test for indication-only instrumentation to the TRM.

The purpose of the CTS 4.5.1 surveillance requirements is to ensure the associated ECCS subsystems can perform their intended safety functions. The removal of indication-only instrumentation surveillance requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The core spray and LPCI subsystem discharge line "keep filled" alarm instrumentation is not required for the low pressure ECCS subsystems to perform their specified safety functions. Control of the availability of, and necessary compensatory activities if not available, for indication-only instruments, monitoring instruments, and alarms are addressed by plant operational procedures and policies.

This change is acceptable because ITS surveillance requirements, including SR 3.5.1.1 (verification location susceptible to gas accumulation are sufficiently filled with water), are retained in ITS. The ITS 3.5.1 SRs related to the low pressure ECCS are consistent with the ISTS and continue to assure, pursuant to the requirements of 10 CFR 50.36(c)(3), that facility operation will be within safety limits and that the limiting condition for operation (LCO) associated with the low pressure ECCS will be met.

Also, this change is acceptable because the relocated core spray and LPCI keep fill instrumentation requirements will be adequately controlled in the TRM.

Changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because indication-only instrumentation requirements are being removed from the Technical Specifications.

LA04 (Type 4 Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS 4.5.1.c.4 and c.5 require a Channel Calibration of the core spray and LPCI header P instrumentation, including a verification of the setpoints of the P instrumentation are their specified

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 7 of 15 allowable values. ITS 3.5.1 does not include these testing requirements. This changes the CTS by relocating surveillance tests for indication-only instrumentation to the TRM.

The purpose of the CTS 4.5.1 surveillance requirements is to ensure the associated ECCS subsystems can perform their intended safety functions. The removal of indication-only instrumentation surveillance requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The core spray and LPCI subsystem header p instrumentation is not required for the low pressure ECCS subsystems to perform their specified safety functions. Control of the availability of, and necessary compensatory activities if not available, for indication-only instruments, monitoring instruments, and alarms are addressed by plant operational procedures and policies.

This change is acceptable because ITS surveillance requirements, including SR 3.5.1.5 (verification of low pressure ECCS pump flow rate), and SR 3.5.1.8 (verification ECCS injection spray subsystems actuate on an actual or automatic initiation signal), are retained in ITS. The ITS 3.5.1 SRs related to the low pressure ECCS are consistent with the ISTS and continue to assure, pursuant to the requirements of 10 CFR 50.36(c)(3), that facility operation will be within safety limits and that the LCO associated with the low pressure ECCS will be met.

Also, this change is acceptable because the relocated core spray and LPCI subsystem header P instrumentation requirements will be adequately controlled in the TRM. Changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because indication-only instrumentation requirements are being removed from the Technical Specifications.

LA05 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.5.1.a.1.b) footnote

• states Except that an automatic valve capable of automatic return to its ECCS position when an ECCS signal is present may be in position for another mode of operation. ITS SR 3.5.1.2 does not include this detail. CTS 4.5.1.a.2 states For the HPCI system, verifying that the HPCI pump flow controller is in the correct position. CTS 4.5.1.c.2.b) states The suction is automatically transferred from the condensate storage tank to the suppression chamber on a condensate storage tank water level - low signal and on a suppression chamber - water level high signal. ITS SR 3.5.1.6, SR 3.5.1.7, and SR 3.5.1.8 do not include these details.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS SR 3.5.1.2 retains the requirement to verify each ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position. ITS 3.5.1.6 and SR 3.5.1.7 retain the requirement for HPCI flow testing (low pressure and high pressure). SR 3.5.1.8

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 8 of 15 retains the requirement to verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal, Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA06 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.5.1.a.1.a requires, for the core spray system, the LPCI system, and the HPCI system, verifying that the system piping from the pump discharge valve to the system isolation valve is filled with water by venting at the high point vents. ITS SR 3.5.1.1 also requires verifying, for each ECCS injection/spray subsystem, piping from each pump discharge valve to the associated injection valve(s) (i.e., isolation valve) is filled with water. ITS SR 3.5.1.1 does not include the system operational description detail of the venting process.

This changes the CTS by moving system operational description details to the ITS Bases. The removal of these details, which are related to system operation and design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS SR 3.5.1.1 retains the requirement to verify, for each ECCS injection/spray subsystem, the piping from each pump discharge valve to the associated injection valve(s) is filled with water. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system operation and design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 2 - Relaxation of Applicability) CTS 3.5.1 requires the ADS function of five OPERABLE ADS valves to be OPERABLE in OPERATIONAL CONDITIONS 1, 2, and 3 except when reactor steam dome pressure is less than or equal to 100 psig as noted by ** footnote. In addition, CTS 3.5.1 Action d.2, requires, with two or more required ADS valves inoperable, to be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to 100 psig within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS LCO 3.5.1 requires the ADS function of five safety/relief valves (S/RVs) to be OPERABLE in MODES 1, and MODES 2 and 3 except the ADS valves are not required to be OPERABLE with reactor steam dome pressure 200 psig. This changes the CTS by changing the technical specification applicability for when the ADS function of the S/RVs must be OPERABLE and includes changing the action end state for two or more required inoperable ADS valves as a result of the applicability change.

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 9 of 15 The purpose of the CTS Applicability is to ensure reactor steam dome pressure is adequate for the ADS function of the S/RVs to perform their function. The purpose of the end state action when two or more required ADS valves are inoperable is to place the plant in a condition in which the LCO does not apply.

Increasing the applicability requirement for ADS does not adversely impact this purpose. The ADS is designed as a redundant function to the HPCI System by providing depressurization of the RCS during a small break LOCA if HPCI fails or is unable to maintain required water level in the RPV. ADS operation reduces the RPV pressure to within the operating pressure range of the low pressure ECCS subsystems (core spray and LPCI), so that these subsystems can provide coolant inventory makeup. This change meets the intent of the ISTS and ITS 3.5.1 Actions that the Applicability of HPCI System and ADS, which provide the same safety function during a small break LOCA, be equivalent.

Due to the HPCI System design at HCGS, reactor steam dome pressure must be

> 200 psig. The HPCI System is analyzed (per NEDC-33172P, SAFER/GESTR-LOCA Loss of Coolant Accident Analysis for Hope Creek Generating Station at Power Uprate," March 2005) to begin injection into the RPV above 200 psig. Additionally, small break loss of coolant accidents at low pressures (i.e.,

between 150 psig and 200 psig) are bounded by analyses performed at higher pressures and low pressure ECCS injection/spray subsystems are assumed to begin injection at pressures higher than 200 psig (286 psid for LPCI and 289 psid for core spray). Therefore, requiring ADS to be OPERABLE between 150 psig and 200 psig is unnecessary. NEDC-33172P (ADAMS Accession No. ML053250469; not publicly available) was reviewed by the NRC and ECCS performance was determined acceptable for the HCGS extended power uprate as documented in the NRC safety evaluation associated with License Amendment 174, dated May 14, 2008 (NRC ADAMS Accession No. ML081230540).

As a result of the change to the ADS applicability, the end state action to reduce reactor steam dome pressure to 100 psig when two or more required ADS valves are inoperable is changed to reduce reactor steam dome pressure to 200 psig. This change meets the intended purpose of placing the plant in a condition in which the LCO does not apply.

This change is acceptable because the LOCA analyses indicate that low pressure ECCS injection/spray subsystems will begin to inject at pressures greater than 200 psig. As such, there is minimal safety impact associated with the proposed change. The change is designated less restrictive because less stringent Applicability and action requirements are being applied in the ITS than were applied in the CTS.

L02 (Category 4 - Relaxation of Required Action) CTS 3.5.1 actions are as follows:

Low pressure ECCS subsystems Actions a.1 (one CS subsystem inoperable), b.1 (one LPCI subsystem inoperable), b.2 (two LPCI subsystems inoperable), and b.3 (three LPCI subsystems inoperable) require the unit be in at least HOT SHUTDOWN (MODE 3) within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN (MODE 4) within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the required action is not completed within its associated completion time.

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 10 of 15 HPCI Actions c.1 (HPCI inoperable), c.2.a (HPCI and one CS subsystem or one LPCI subsystem inoperable), c.2.b (HPCI and one CS subsystem and one LPCI subsystem inoperable) require the unit be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to 200 psig within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the required action is not completed within its associated completion time.

ADS Action d.1 (one ADS valve inoperable) requires the unit be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to 100 psig within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the required action is not completed within its associated completion time.

ITS 3.5.1 ACTION J requires the unit to be placed in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the Required Action and associated Completion Time is not met.

This changes the CTS low pressure ECCS Actions by removing the requirement and in COLD SHUTDOWN (MODE 4) within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the required action is not completed within its associated completion time, changing the end state of the CTS Low pressure ECCS Actions above to MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

This changes the CTS HPCI Actions by removing the requirement and reduce reactor steam dome pressure to 200 psig within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the required action is not completed within its associated completion time, changing the end state of the CTS HPCI Actions above to MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

This changes the CTS ADS Action by removing the requirement and reduce reactor steam dome pressure to 100 psig within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when an inoperable ADS valve cannot be restored to OPERABLE status within 14 days, changing the end state of the CTS ADS Action above to MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The purpose of ITS 3.5.1 ACTION J is to place the plant in a MODE in which overall plant risk is minimized. This change is acceptable because placing the plant in MODE 3 provides for a similar or lower risk than continuing shutdown to MODE 4 for ECCS subsystems. The change does not prevent voluntary action to continue to a lower MODE for ECCS subsystems if operating conditions should so dictate. In addition, remaining in the Applicability of the LCO is acceptable because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. ITS Required Action J.1 is modified by the addition of a Note prohibiting entry into the end state MODE within the Applicability during startup using the provisions of LCO 3.0.4.a to provide assurance that entry into the end state MODE during startup is not made without the appropriate risk assessment. The addition of ITS ACTION J is consistent with Revision 5 of the ISTS as adopted by Technical Specifications Task Force (TSTF) traveler TSTF-423-A, Revision 1, Technical Specification End States, NEDC-32988-A, dated September 16, 2014. (ADAMS Accession No. ML102730688). The TSTF was approved for licensee adoption as documented in Federal Register Notice 76 FR 9614 (ADAMS Accession No.

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 11 of 15 ML102730585). PSEG Nuclear has previously committed to assess and manage risk at HCGS in accordance with the guidance of NUMARC 93-01, Rev. 4F, Section 11 (e.g., Amendment 228 (ADAMS Accession No. ML21098A087)).

PSEG Nuclear will also follow the guidance established in TSTF-IG-05-02, Implementation Guidance for TSTF-423, Rev. 1, Technical Specifications End States, NEDC-32988-A, upon implementation of the end state requirements.

The change is designated less restrictive because a less restrictive completion time is imposed when the specified Required Action cannot be met.

L03 (Category 4 - Relaxation of Required Action) CTS Action a.1 requires, in part, with one core spray subsystem inoperable, restore the inoperable core spray subsystem to OPERABLE status within 7 days. CTS Action d.1 requires, in part, with one required ADS valve inoperable, restore the inoperable ADS valve to OPERABLE status within 14 days. ITS 3.5.1 ACTION B provides the ACTION for one core spray subsystem inoperable and ACTION H provides the ACTION for one ADS valve inoperable. However, there is no ACTION for the combination of one ADS valve and one core spray subsystem inoperable, which would require entry into CTS 3.0.3. ITS 3.5.1 ACTION I is added to require, with one ADS valve inoperable and one low pressure ECCS injection/spray subsystem inoperable (i.e., one core spray subsystem or one LPCI subsystem inoperable), restore the inoperable ADS valve or the inoperable core spray subsystem or LPCI subsystem to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This changes the CTS by allowing 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the combination of one ADS valve inoperable and one low pressure ECCS injection/spray subsystem inoperable instead of entry into LCO 3.0.3.

The purpose of ITS ACTION I is to provide appropriate remedial actions for the condition of one low pressure ECCS injection/spray subsystem inoperable concurrent with one inoperable ADS valve. In this condition, CTS Action c.2.a is provided for the combination of the HPCI System inoperable and one low pressure ECCS injection/spray subsystem inoperable and allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore one the subsystems to OPERABLE status. This action was added to the Technical Specifications in License Amendment 89. The NRC evaluated and considered the action acceptable as documented in letter from D. H Jaffe (NRC) to L.R. Eliason (PSEG), "Hope Creek Generating Station (TAC NO. M89220),"

dated November 30, 1995 (ADAMS Accession No. ML011760500). The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in proposed ITS 3.5.1 ACTION I is acceptable based on the same premise that, in this condition, adequate core cooling is ensured by the OPERABILITY of HPCI (a high pressure injection system) and the remaining low pressure ECCS injection/spray subsystems. This change is consistent with the ISTS and designated less restrictive because an action is added to CTS allowing time to restore from the condition of an inoperable core spray subsystem or LPCI subsystem concurrent with an inoperable ADS valve instead of applying LCO 3.0.3.

L04 (Category 8 - Deletion of Reporting Requirements) CTS 3.5.1 Action g states In the event an ECCS system is actuated and injects water into the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date. The current value of the usage factor for each affected safety injection nozzle shall be

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 12 of 15 provided in this Special Report whenever its value exceeds 0.70. ITS 3.5.1 does not contain this 90-day Special Report requirement in the event the ECCS is actuated and injects water into the RCS. This changes the CTS by deleting this 90-day Special Report.

The purpose of the CTS is to provide direction and details to ensure the NRC is informed in the event an ECCS system is actuated and injects water into the RCS. The removal of these details for making reports from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the LCO for each ECCS injection/spray subsystem to be OPERABLE and ACTIONS when one or more ECCS injection/spray subsystem(s) are inoperable.

This change is consistent with ISTS, which does not specify detailed reporting actions, and removes procedural reporting details necessary to comply with 10 CFR 50 requirements. Deletion of the ECCS reporting requirement is acceptable since 10 CFR 50.72(b)(2)(iv) requires a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> notification in the event of an unplanned ECCS actuation and injection into the RCS. Additionally, 10 CFR 50.73(2)(iv)(A) also requires submission of a licensee event report for any unplanned event or condition that resulted in manual or automatic actuation of ECCS. The HCGS operating license requires compliance with 10 CFR 50.72 and 50.73. These regulations are adequate to ensure the NRC is informed in the event an ECCS system is actuated and injects water into the RCS. Therefore, the CTS requirement is unnecessary. This change is designated as less restrictive because reports that would be submitted under the CTS will not be required under the ITS.

L05 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS 4.5.1.a.1.b) states Verifying that each valve, manual, power operated or automatic in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position. ITS SR 3.5.1.2 provides the same requirement.

However, ITS SR 3.5.1.2 is modified by a Note that states Not required to be met for system vent flow paths opened under administrative control. CTS 4.5.1.a.1.b) does not include this note. This changes the CTS by adding a Note to the valve alignment verification Surveillance allowing vent paths to be open under administrative control.

The purpose of the CTS Surveillance is to ensure the ECCS injection/spray subsystem valves are in the correct position for system operation. The Note to ITS SR 3.5.1.2 provides a necessary exemption during performance of SR 3.5.1.1, which verifies the ECCS injection/spray subsystem locations susceptible to gas accumulation are sufficiently filled with water. Opening vent flow paths may be needed during performance of this surveillance. The Surveillance Note provides an exception to opening vent flow paths under administrative control. The administrative control will include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 13 of 15 This change is consistent with the ISTS and considered acceptable because the venting evolution is controlled, and the administratively controlled actions ensure the vent flow paths are closed in order to maintain system OPERABILITY. This change also considers the low probability of a DBA occurring during this period.

The ITS SR continues to provide assurance that the necessary quality of the ECCS injection/spray subsystems will be maintained and the limiting condition for operation will be met pursuant to the requirements of 10 CFR 50.36(c)(3). The change is designated less restrictive because an exception is added to the valve alignment surveillance requirement that allows opening ECCS injection/spray subsystem vent flow paths under administrative control.

The addition of ITS SR 3.5.1.2 Note is consistent with Revision 5 of the ISTS as adopted by Technical Specifications Task Force (TSTF) traveler TSTF-523-A, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, dated January 15, 2014. (ADAMS Accession No. ML13255A169). The TSTF was approved for licensee adoption as documented in Federal Register Notice 78 FR 47010 (ADAMS Accession No. ML13255A403). PSEG Nuclear will follow the guidance established in TSTF-IG-14-01, Implementation Guidance for TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation, upon implementation of the managing gas accumulation requirements. The change is designated less restrictive because an exception is added to the valve alignment surveillance requirement that allows opening ECCS injection/spray subsystem vent flow paths under administrative control.

L06 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.5.1.b.3 (HPCI high pressure flow verification) and 4.5.1.c.2.a (HPCI low pressure flow verification) are modified by footnote ** allowing performance of the Surveillance to be deferred until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure" is adequate to perform the surveillance. This allowance is based on the need to establish appropriate conditions for testing. The corresponding ITS SRs 3.5.1.6 and 3.5.1.7 are modified by a similar Note that allows deferring the performance of these tests until reactor steam pressure "and flow" are adequate to perform the test. This changes the CTS by expanding the noted allowance from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reaching adequate steam pressure to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reaching adequate steam pressure and flow.

The purpose of the CTS note is to ensure the necessary unit parameters are established to perform the Surveillance test. This change is necessary because the CTS allowance to reach the required reactor steam pressure only partially addresses the issue of adequate test conditions. Requiring performance of these tests before adequate steam flow can be maintained creates the potential for an undesired reactor depressurization. This change is less restrictive because it allows additional time before the surveillances are required to be performed. This change is acceptable because the allowance permits the surveillance to be delayed until appropriate conditions are established, and this change will not result in any significant delay in the performance of the surveillance. In this situation, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to the condition where the surveillance test can be performed. The Note to the subject ITS SRs is consistent with the ISTS and

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 14 of 15 continues to provide assurance that the necessary quality of the HPCI System will be maintained and the limiting condition for operation will be met pursuant to the requirements of 10 CFR 50.36(c)(3). The change is designated less restrictive because additional criteria is added to the time delay to perform the Surveillance test.

L07 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.5.1.c.1 (core spray, LPCI, and HPCI) states, in part, perform a system functional test which includes simulated automatic actuation. CTS 4.5.1.d.2.a)

(ADS) states, in part, perform a system functional test which includes simulated automatic actuation. ITS SR 3.5.1.8 states, in part, verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal. ITS SR 3.5.1.9 states verify the ADS actuates on an actual or simulated automatic initiation signal. This changes the CTS by allowing satisfactory actual automatic core spray, LPCI, HPCI, and ADS system initiation to be used to fulfill the ECCS subsystems and ADS functional surveillance requirement. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the tests.

The purpose of the subject CTS surveillances is to ensure the ECCS subsystem or ADS actuates on an initiation signal. This change is acceptable because it has been determined that the current Surveillance Requirement acceptance criteria are not the only method that can be used for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual" or "simulated" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements. The change also allows a simulated signal to be used, if necessary. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L08 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.5.1.d.1 and d.2.c require, in accordance with the Surveillance Frequency Control Program (SFCP), a Channel Functional Test and Channel Calibration of the ADS primary containment instrument gas low-low pressure alarm system including a verification of the alarm setpoint of 85 +/- 2 psig on decreasing pressure. ITS SR 3.5.1.3 requires verifying ADS primary containment instrument gas receiver pressure is 85 psig at a Frequency in accordance with the SFCP.

This changes the CTS by replacing surveillance testing of an alarm system with a surveillance to periodically verify the parameter is within limits.

The purpose of the CTS 4.5.1 surveillance requirements is to ensure the associated ECCS subsystems can perform their intended safety functions. The ADS primary containment instrument gas low-low pressure alarm system is not required for the ECCS subsystems to be OPERABLE. The definition of OPERABLE - OPERABILITY in ITS Section 1.1, addresses support instrumentation, in part, as when all necessary attendant instrumentation that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) [emphasis added] are also capable of performing their related support function(s). The ADS primary containment

DISCUSSION OF CHANGES ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 15 of 15 instrument gas low-low pressure alarm system is not essential for the ADS valves to perform their specified safety function provided adequate primary containment instrument gas pressure is available to each ADS valve. The removal of the functional test of the low-low pressure alarm system from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. Control of the availability of, and necessary compensatory activities if not available, for indication-only instruments, monitoring instruments, and alarms are addressed by plant operational procedures and policies.

This change is acceptable because in addition to the new SR 3.5.1.3 (verification of primary containment instrument gas receiver pressure), other ITS surveillance requirements associated with the ADS valves are retained in ITS. The ITS 3.5.1 SRs related to the ADS valves continue to assure, pursuant to the requirements of 10 CFR 50.36(c)(3), that facility operation will be within safety limits and that the LCO associated with the ADS valves will be met. Verification that ADS primary containment instrument gas receiver pressure is 85 psig ensures adequate air pressure for reliable ADS operation. The Frequency of ITS 3.5.1.3 is in accordance with the Surveillance Frequency Control Program. HCGS controls periodic Frequencies for Surveillances in accordance with the SFCP per CTS 6.8.4.j. The initial frequency established in accordance with the SFCP will be 31 days consistent with CTS 4.5.1.d.1 (ADS primary containment instrument gas low-low pressure alarm system Channel Functional Test) frequency in accordance with the SFCP. The initial frequency of 31 days is also consistent with the Frequency established for ISTS SR 3.5.1.3 and takes into consideration administrative controls over operation of the primary containment instrument gas system and alarms for low instrument gas pressure.

Also, this change is acceptable because verification of the alarm system will be adequately controlled via plant testing procedures pursuant the requirements of 10 CFR 50, Appendix B. The requirements of 10 CFR 50, Appendix B, Section XI (Test Control), provide adequate controls for test programs to ensure testing required to demonstrate that SSCs will perform satisfactorily and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Compliance with 10 CFR 50, Appendix B is required under the unit operating license. As a result, necessary testing will continue to be performed to maintain functional capability of the ADS primary containment instrument gas low-low pressure alarm system; thus, an explicit requirement in the Technical Specifications is not necessary.

This change is designated as less restrictive because an alarm system Surveillances required in the CTS are being replaced with a periodic system parameter verification in the ITS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

ECCS - Operating 3.5.1 General Electric BWR/4 STS 3.5.1-1 Rev. 5.0 Hope Creek Amendment XXX 1

CTS 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of [seven] safety/relief valves shall be OPERABLE.

[ --------------------------------------------NOTE--------------------------------------------

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than [the Residual Heat Removal (RHR) cut in permissive pressure] in MODE 3, if capable of being manually realigned and not otherwise inoperable.

---

]

APPLICABILITY:

MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure [150] psig.

ACTIONS

---

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

LCO 3.0.4.b is not applicable to HPCI.

CONDITION REQUIRED ACTION COMPLETION TIME CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS injection/spray subsystem inoperable.

OR One LPCI pump in both LPCI subsystems inoperable.

A.1 Restore low pressure ECCS injection/spray subsystem(s) to OPERABLE status.

7 days

[OR In accordance with the Risk Informed Completion Time Program]

LCO 3.5.1 LCO 3.5.1.d DOC LA01 3.5.1 Applicability Footnote ##

Action Note shutdown cooling (SDC)

Applicability Footnote

• Footnote **

2 2

2 2

1 1

2 1

200 five LPCI Action b.1 INSERT 1 Action a.1, b.2, b.3 LPCI 30 2

2 3

1 4

DOC L01

ECCS - Operating 3.5.1 Insert Page 3.5.1-1 INSERT 1 CONDITION REQUIRED ACTION COMPLETION TIME B. One core spray subsystem inoperable.

B.1 Restore core spray subsystem to OPERABLE status.

7 days C. Two LPCI subsystems inoperable.

C.1 Restore LPCI subsystems to OPERABLE status.

7 days D. Three LPCI subsystems inoperable.

D.1 Restore LPCI subsystems to OPERABLE status.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Action a.1 Action b.2 Action b.3 3

CTS

ECCS - Operating 3.5.1 General Electric BWR/4 STS 3.5.1-2 Rev. 5.0 Hope Creek Amendment XXX 1

CTS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time of Condition A not met.

B.1

---

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C. HPCI System inoperable.

C.1 Verify by administrative means RCIC System is OPERABLE.

AND C.2 Restore HPCI System to OPERABLE status.

Immediately 14 days

[OR In accordance with the Risk Informed Completion Time Program]

D. HPCI System inoperable.

AND Condition A entered.

D.1 Restore HPCI System to OPERABLE status.

OR D.2 Restore low pressure ECCS injection/spray subsystem to OPERABLE status.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

[OR In accordance with the Risk Informed Completion Time Program]

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

[OR In accordance with the Risk Informed Completion Time Program]

Action c.1 Action c.1 Action c.2.a One low pressure ECCS injection/spray subsystem inoperable F

E Action c.2.b F

F E

E 3

1 2

3 3

3 3

3 3

2 2

INSERT 2

ECCS - Operating 3.5.1 Insert Page 3.5.1-2 INSERT 2 CONDITION REQUIRED ACTION COMPLETION TIME G. HPCI System inoperable.

AND One LPCI subsystem inoperable.

AND One core spray subsystem inoperable.

G.1 Restore HPCI System to OPERABLE status.

OR G.2 Restore LPCI subsystem to OPERABLE status.

OR G.3 Restore core spray subsystem to OPERABLE status.

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 8 hours 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Action c.2.b 3

CTS

ECCS - Operating 3.5.1 General Electric BWR/4 STS 3.5.1-3 Rev. 5.0 Hope Creek Amendment XXX 1

CTS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One ADS valve inoperable.

E.1 Restore ADS valve to OPERABLE status.

14 days

[OR In accordance with the Risk Informed Completion Time Program]

F. One ADS valve inoperable.

AND Condition A entered.

F.1 Restore ADS valve to OPERABLE status.

OR F.2 Restore low pressure ECCS injection/spray subsystem to OPERABLE status.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

[OR In accordance with the Risk Informed Completion Time Program]

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

[OR In accordance with the Risk Informed Completion Time Program]

G. Required Action and associated Completion Time of Condition C, D, E, or F not met.

G.1

---

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action d.1 DOC L03 Action a.1, b.1, b.2, b.3, c.1, c.2, c.2.b, d.1 DOC L02 A, B, C, D, E, F, G, H, or I One low pressure ECCS injection/spray subsystem inoperable I

H J

J I

I H

3 2

3 3

2 3

2 3

ECCS - Operating 3.5.1 General Electric BWR/4 STS 3.5.1-4 Rev. 5.0 Hope Creek Amendment XXX 1

CTS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. Two or more ADS valves inoperable.

H.1 Be in MODE 3.

AND H.2 Reduce reactor steam dome pressure to

[150] psig.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours I.

Two or more low pressure ECCS injection/spray subsystems inoperable for reasons other than Condition A.

OR HPCI System and one or more ADS valves inoperable.

I.1 Enter LCO 3.0.3.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

[ 31 days OR In accordance with the Surveillance Frequency Control Program ]

Action d.2 Action b.4 M01 Action c.1, d.1 DOC A07 4.5.1.a.1.a 200 K

K L

L Four Two core spray subsystems inoperable.

OR Action a.2 DOC M01 3

2 3

3 2

2 4

OR HPCI System and two or more LPCI subsystems inoperable.

OR One ADS valve inoperable and two or more low pressure ECCS injection/spray subsystems inoperable.

3 K

piping from each pump discharge valve to the associated injection valve(s) is 5

ECCS - Operating 3.5.1 General Electric BWR/4 STS 3.5.1-5 Rev. 5.0 Hope Creek Amendment XXX 1

CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.2

---

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

Not required to be met for system vent flow paths opened under administrative control.

Verify each ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

[ 31 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.5.1.3 Verify ADS [air supply header] pressure is

[90] psig.

[ 31 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.5.1.4

[ Verify the [RHR] System cross tie valve[s] [is]

closed and power is removed from the valve operator[s].

[ 31 days OR In accordance with the Surveillance Frequency Control Program ] ]

4.5.1.a.1.b DOC L05 4.5.1.a.1.c are 2

2 2

2 4.5.1.d.1 DOC L08 primary containment instrument gas receiver 85 2

2 6

ECCS - Operating 3.5.1 General Electric BWR/4 STS 3.5.1-6 Rev. 5.0 Hope Creek Amendment XXX 1

CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.5

[ Verify each LPCI inverter output voltage is

[570] V and [630] V while supplying the respective bus.

[ 31 days OR In accordance with the Surveillance Frequency Control Program ] ]

SR 3.5.1.6

---

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

Not required to be performed if performed within the previous 31 days.

Verify each recirculation pump discharge valve [and bypass valve] cycles through one complete cycle of full travel [or is de-energized in the closed position].

Once each startup prior to exceeding 25% RTP SR 3.5.1.7 Verify the following ECCS pumps develop the specified flow rate [against a system head corresponding to the specified reactor pressure].

[System Head No.

Corresponding of to a Reactor System Flow Rate Pumps Pressure of]

Core Spray

[4250] gpm [1]

[113] psig LPCI

[17,000] gpm [2]

[20] psig

[ In accordance with the INSERVICE TESTING PROGRAM OR

[92 days]

OR In accordance with the Surveillance Frequency Control Program ]

4.5.1.b.1 4.5.1.b.2 2

10,000 6,150 1

105 psi above suppression pool pressure above primary containment pressure 2

7 7

7 5

1

ECCS - Operating 3.5.1 General Electric BWR/4 STS 3.5.1-7 Rev. 5.0 Hope Creek Amendment XXX 1

CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.8

---

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

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with [reactor pressure] [1020] and

[920] psig, the HPCI pump can develop a flow rate

[4250] gpm [against a system head corresponding to reactor pressure].

[ 92 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.5.1.9

---

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

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with [reactor pressure] [165] psig, the HPCI pump can develop a flow rate [4250] gpm [against a system head corresponding to reactor pressure].

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

In accordance with the INSERVICE TESTING PROGRAM 4.5.1.b.3 Footnote **

DOC L06 4.5.1.b.3 4.5.1.c.2.a 5600 5600 2

1 2

6 7

4.5.1.c.2.a Footnote **

DOC L06 7

7 of 1000 psig of 200 HPCI turbine inlet a

HPCI turbine inlet 215 a

ECCS - Operating 3.5.1 General Electric BWR/4 STS 3.5.1-8 Rev. 5.0 Hope Creek Amendment XXX 1

CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.10

---

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

Vessel injection/spray may be excluded.

Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

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

SR 3. 5.1.11

---

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

Valve actuation may be excluded.

Verify the ADS actuates on an actual or simulated automatic initiation signal.

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

4.5.1.c.1 CS, LPCI, HPCI DOC L07 4.5.1.d.2.a) 4.5.1.d.2.a)

DOC L07 2

2 2

2 8

9 7

7

ECCS - Operating 3.5.1 General Electric BWR/4 STS 3.5.1-9 Rev. 5.0 Hope Creek Amendment XXX 1

CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.12

---

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

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify each ADS valve opens when manually actuated.

[ [18] months [on a STAGGERED TEST BASIS for each valve solenoid OR In accordance with the Surveillance Frequency Control Program ] ]

4.5.1.d.2.b)

In accordance with the INSERVICE TESTING PROGRAM 2

1 7

10 is capable of being opened.

8

JUSTIFICATION FOR DEVIATIONS ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 1 of 3

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

3. ISTS 3.5.1 is based on a standard General Electric BWR/4 ECCS design that consists of two core spray (CS) subsystems, with one 100% flow CS pump in each subsystem and two LPCI subsystems, with two 100% flow LPCI pumps in each subsystem, resulting in a total of four low pressure ECCS injection/spray subsystems. ISTS 3.5.1 is revised in the ITS to align with the Hope Creek Generating Station (HCGS) ECCS design that consists of two CS subsystems, with two 50% flow CS pumps in each subsystem, and four LPCI subsystems, with one 100% flow LPCI pump in each of the four separate and independent LPCI subsystems, resulting six low pressure ECCS injection/spray subsystems.

ISTS 3.5.1 ACTIONS are revised in the ITS, consistent with the current technical specification actions, as follows:

ACTION A is modified to one LPCI subsystem inoperable (30 days).

ACTION B adds an action for one core spray subsystem inoperable (7 days).

ACTION C adds an action for two LPCI subsystems inoperable (7 days).

ACTION D adds an action for three LPCI subsystems inoperable (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />).

ACTION E, F adopted consistent with ISTS 3.5.1 ACTIONS C and D.

ACTION G adds an action for HPCI and one LPCI subsystem and one core spray subsystem inoperable (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />).

ACTION H, I, J, K adopted consistent with ISTS 3.5.1 ACTIONS E, F, G, and H.

ACTION L (ISTS 3.5.1 ACTION I) includes the following combination of inoperabilities that have no specific actions in CTS requiring entry into LCO 3.0.3:

o Two core spray systems inoperable, o Four or more low pressure ECCS injection/spray subsystems inoperable, o HPCI System and one or more ADS valves inoperable (consistent with ISTS),

o HPCI System and two or more LPCI subsystems inoperable, and o One ADS valve inoperable and two or more low pressure ECCS injection/spray subsystems inoperable.

Subsequent Conditions and Required Actions are renumbered, as necessary, to support this deviation.

4. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. The ISTS 3.5.1 Applicability exception of 150 psig for the HPCI System and ADS is based on a standard General Electric BWR/4 ECCS design where adequate steam pressure is available to the HPCI System and ADS for the components to perform their intended safety functions.

JUSTIFICATION FOR DEVIATIONS ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 2 of 3 ADS and HPCI are not required to be OPERABLE in MODES 2 and 3 when steam dome pressure is less than the required value because the low pressure ECCS subsystems can provide sufficient flow below this pressure. The ITS 3.5.1 Applicability exception of 200 psig is consistent with Applicability allowance of the HPCI System specified in CTS. Since the ECCS function of ADS is redundant to the HPCI System, the Applicability exception at a reactor steam dome pressure value of 200 psig is also applicable to the ADS function of the SR/Vs. Additionally, the pressure specified in ITS 3.5.1 Required Action K.2 (ISTS 3.5.1 Required Action H.2) specifies 200 psig since the applicability of the ADS valves is changed to 200 psig equivalent with the HPSI System Applicability, as described in the CTS Discussion of Changes.

5. ISTS SR 3.5.1.1, associated with verifying, for each ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water, is revised in the ITS to maintain the wording in the current Technical Specifications. NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" (ADAMS Accession No. ML072910759), required licensees to submit information, in general, regarding concerns that certain safety systems could accumulate gas pockets that may inhibit system flow or damage system pumps/piping during an event which requires system operation. PSEG provided response to GL 2008-01 related to HCGS management of gas accumulation in letters dated April 10, 2008, October 13, 2008, July 30, 2009, and January 28, 2011 (ADAMS Accession Nos.

ML081130672, ML082970219, ML092230347 and ML110400201, respectively).

The responses included the results of evaluations performed on systems of concern, summary of procedural controls, and description of support features (such as the Emergency Core Cooling System "keep-fill" system). Based on the review of information provided by PSEG, the NRC found the responses acceptable and subsequently closed the GL 2008-01 request for HCGS in letter to T. Joyce (PSEG) from R.B. Ennis (NRC), dated June 2, 2011 (ADAMS Accession No. ML111380081), with no further information or action required.

SRs associated with verifying certain systems remain full of water were adopted in the ISTS following NRC approval of Technical Specification Task Force (TSTF) traveler TSTF-523-A, "Generic Letter 2008-01, Managing Gas Accumulation,"

Revision 2, dated January 15, 2014 (79 FR 2700). PSEG subsequently performed an evaluation and determined that adoption of TSTF-523 was not necessary based on established controls and support features previously determined acceptable by the NRC. Based on the considerations provided herein, ISTS SR 3.5.1.1 is not necessary to ensure associated systems are properly maintained in an OPERABLE condition and ITS SR 3.5.1.1 is revised to be consistent with current licensing basis.

6. The HCGS design residual heat removal (RHR) cross tie valves are manual valves with no power installed.

7. ISTS SRs 3.5.1.5 and 3.5.1.6 are not included in the ITS because these Surveillances do not apply to HCGS. The HCGS LPCI System design does not include LPCI inverters to supply power to the LPCI inboard injection, minimum flow valves, or recirculation pump discharge valves. In addition, the HCGS ECCS design does not include automatic closure of the recirculation pump discharge

JUSTIFICATION FOR DEVIATIONS ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 3 of 3 valves on a LPCI initiation signal because the LPCI subsystems inject directly into the RPV and do not interface with the discharge line of the recirculation pumps.

Subsequent Surveillances are renumbered, as necessary, to support this deviation.

8. ISTS SR 3.5.1.12 (ITS SR 3.5.1.10) requirement is modified to current licensing bases (i.e., Verify each ADS valve is capable of being opened) and the ISTS SR 3.5.1.12 Note is deleted since HCGS is not required to manual open ADS valves for testing. The requirement to perform in-situ functional testing of the Automatic Depressurization System safety relief valves (SRVs) during startup testing was eliminated in License Amendment 116, Deletion of Automatic Depressurization System Valve Startup Testing, dated February 10, 1999 (ADAMS Accession No. ML011770051).

Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-1 Rev. 5.0 Hope Creek Revision XXX 1

B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.1 ECCS - Operating BASES BACKGROUND The ECCS is designed, in conjunction with the primary and secondary containment, to limit the release of radioactive materials to the environment following a loss of coolant accident (LOCA). The ECCS uses two independent methods (flooding and spraying) to cool the core during a LOCA. The ECCS network consists of the High Pressure Coolant Injection (HPCI) System, the Core Spray (CS) System, the low pressure coolant injection (LPCI) mode of the Residual Heat Removal (RHR) System, and the Automatic Depressurization System (ADS). The suppression pool provides the required source of water for the ECCS.

Although no credit is taken in the safety analyses for the condensate storage tank (CST), it is capable of providing a source of water for the HPCI and CS systems.

On receipt of an initiation signal, ECCS pumps automatically start; simultaneously, the system aligns and the pumps inject water, taken either from the CST or suppression pool, into the Reactor Coolant System (RCS) as RCS pressure is overcome by the discharge pressure of the ECCS pumps. Although the system is initiated, ADS action is delayed, allowing the operator to interrupt the timed sequence if the system is not needed. The HPCI pump discharge pressure almost immediately exceeds that of the RCS, and the pump injects coolant into the vessel to cool the core. If the break is small, the HPCI System will maintain coolant inventory as well as vessel level while the RCS is still pressurized. If HPCI fails, it is backed up by ADS in combination with LPCI and CS. In this event, the ADS timed sequence would be allowed to time out and open the selected safety/relief valves (S/RVs) depressurizing the RCS, thus allowing the LPCI and CS to overcome RCS pressure and inject coolant into the vessel. If the break is large, RCS pressure initially drops rapidly and the LPCI and CS cool the core.

Water from the break returns to the suppression pool where it is used again and again. Water in the suppression pool is circulated through a heat exchanger cooled by the RHR Service Water System. Depending on the location and size of the break, portions of the ECCS may be ineffective; however, the overall design is effective in cooling the core regardless of the size or location of the piping break. Although no credit is taken in the safety analysis for the RCIC System, it performs a similar function as HPCI, but has reduced makeup capability. Nevertheless, it will maintain inventory and cool the core while the RCS is still pressurized following a reactor pressure vessel (RPV) isolation.

Safety Auxiliaries Cooling 1

is not an ECCS 1

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-2 Rev. 5.0 Hope Creek Revision XXX 1

BASES BACKGROUND (continued)

All ECCS subsystems are designed to ensure that no single active component failure will prevent automatic initiation and successful operation of the minimum required ECCS equipment.

The CS System (Ref. 1) is composed of two independent subsystems.

Each subsystem consists of a motor driven pump, a spray sparger above the core, and piping and valves to transfer water from the suppression pool to the sparger. The CS System is designed to provide cooling to the reactor core when reactor pressure is low. Upon receipt of an initiation signal, the CS pumps in both subsystems are automatically started when AC power is available. When the RPV pressure drops sufficiently, CS System flow to the RPV begins. A full flow test line is provided to route water from and to the suppression pool to allow testing of the CS System without spraying water in the RPV.

LPCI is an independent operating mode of the RHR System. There are two LPCI subsystems (Ref. 2), each consisting of two motor driven pumps and piping and valves to transfer water from the suppression pool to the RPV via the corresponding recirculation loop. The two LPCI subsystems can be interconnected via the RHR System cross tie valve; however, the cross tie valve is maintained closed with its power removed to prevent loss of both LPCI subsystems during a LOCA. The LPCI subsystems are designed to provide core cooling at low RPV pressure.

Upon receipt of an initiation signal, all four LPCI pumps are automatically started (B pump immediately when AC power is available, and A, C, and D pumps approximately 10 seconds after AC power is available).

RHR System valves in the LPCI flow path are automatically positioned to ensure the proper flow path for water from the suppression pool to inject into the recirculation loops. When the RPV pressure drops sufficiently, the LPCI flow to the RPV, via the corresponding recirculation loop, begins. The water then enters the reactor through the jet pumps. Full flow test lines are provided for the four LPCI pumps to route water from the suppression pool, to allow testing of the LPCI pumps without injecting water into the RPV. These test lines also provide suppression pool cooling capability, as described in LCO 3.6.2.3, "RHR Suppression Pool Cooling."

The HPCI System (Ref. 3) consists of a steam driven turbine pump unit, piping, and valves to provide steam to the turbine, as well as piping and valves to transfer water from the suction source to the core via the feedwater system line, where the coolant is distributed within the RPV through the feedwater sparger. Suction piping for the system is provided from the CST and the suppression pool. Pump suction for HPCI is normally aligned to the CST source to minimize injection of suppression pool water into the RPV. However, if the CST water supply is low, or if the suppression pool level is high, an automatic transfer to the two s

four one 1

RPV valves, manual valves used for alternate decay heat removal, are RHR crosstie valves allow the C (D)

RHR pump to be used as a means for Alternate Decay Heat Removal via its respective RHR loop heat exchanger if the normal shutdown cooling RHR Pump A (B) for the loop is inoperable. Open RHR System cross tie valves affect LPCI subsystem OPERABILITY.

the discharge valves to the core spray and feedwater lines 1

1 1

directly

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-3 Rev. 5.0 Hope Creek Revision XXX 1

BASES BACKGROUND (continued) suppression pool water source ensures a water supply for continuous operation of the HPCI System. The steam supply to the HPCI turbine is piped from a main steam line upstream of the associated inboard main steam isolation valve.

The HPCI System is designed to provide core cooling for a wide range of reactor pressures (162 psid to 1135 psid, vessel to pump suction). Upon receipt of an initiation signal, the HPCI turbine stop valve and turbine control valve open simultaneously and the turbine accelerates to a specified speed. As the HPCI flow increases, the turbine governor valve is automatically adjusted to maintain design flow. Exhaust steam from the HPCI turbine is discharged to the suppression pool. A full flow test line is provided to route water from and to the CST to allow testing of the HPCI System during normal operation without injecting water into the RPV.

The ECCS pumps are provided with minimum flow bypass lines, which discharge to the suppression pool. The valves in these lines automatically open to prevent pump damage due to overheating when other discharge line valves are closed. To ensure rapid delivery of water to the RPV and to minimize water hammer effects, all ECCS pump discharge lines are filled with water. The LPCI and CS System discharge lines are kept full of water using a "keep fill" system (jockey pump system). The HPCI System is normally aligned to the CST. The height of water in the CST is sufficient to maintain the piping full of water up to the first isolation valve. The relative height of the feedwater line connection for HPCI is such that the water in the feedwater lines keeps the remaining portion of the HPCI discharge line full of water. Therefore, HPCI does not require a "keep fill" system.

The ADS (Ref. 4) consists of 7 of the 11 S/RVs. It is designed to provide depressurization of the RCS during a small break LOCA if HPCI fails or is unable to maintain required water level in the RPV. ADS operation reduces the RPV pressure to within the operating pressure range of the low pressure ECCS subsystems (CS and LPCI), so that these subsystems can provide coolant inventory makeup. Each of the S/RVs used for automatic depressurization is equipped with one air accumulator and associated inlet check valves. The accumulator provides the pneumatic power to actuate the valves.

APPLICABLE The ECCS performance is evaluated for the entire spectrum of break SAFETY sizes for a postulated LOCA. The accidents for which ECCS operation is ANALYSES required are presented in References 5, 6, and 7. The required analyses and assumptions are defined in Reference 8. The results of these analyses are also described in Reference 9.

5 14 1

200 psig to 1141 psig 1

The HPCI pump assembly is located below the minimum water levels of the CST and suppression pool to ensure positive suction head to the HPCI pump. The HPCI pump check valve at the pump discharge is also located below the water levels in the CST and the suppression pool to ensure piping upstream of the valve is maintained full of water.

The HPCI jockey pump prevents water hammer from occurring during HPCI System startup and minimizes injection time by maintaining the HPCI discharge lines full of water. The jockey pump maintains pressure downstream of the HPCI main pump discharge check valve to keep it closed.

1

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-4 Rev. 5.0 Hope Creek Revision XXX 1

BASES APPLICABLE SAFETY ANALYSES (continued)

This LCO helps to ensure that the following acceptance criteria for the ECCS, established by 10 CFR 50.46 (Ref. 10), will be met following a LOCA, assuming the worst case single active component failure in the ECCS:

a.

Maximum fuel element cladding temperature is 2200°F,

b.

Maximum cladding oxidation is 0.17 times the total cladding thickness before oxidation,

c.

Maximum hydrogen generation from a zirconium water reaction is 0.01 times the hypothetical amount that would be generated if all of the metal in the cladding surrounding the fuel, excluding the cladding surrounding the plenum volume, were to react,

d.

The core is maintained in a coolable geometry, and

e.

Adequate long term cooling capability is maintained.

The limiting single failures are discussed in Reference 11. For a large discharge pipe break LOCA, failure of the LPCI valve on the unbroken recirculation loop is considered the most severe failure. For a small break LOCA, HPCI failure is the most severe failure. One ADS valve failure is analyzed as a limiting single failure for events requiring ADS operation.

The remaining OPERABLE ECCS subsystems provide the capability to adequately cool the core and prevent excessive fuel damage.

The ECCS satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Each ECCS injection/spray subsystem and seven ADS valves are required to be OPERABLE. The ECCS injection/spray subsystems are defined as the two CS subsystems, the two LPCI subsystems, and one HPCI System. The low pressure ECCS injection/spray subsystems are defined as the two CS subsystems and the two LPCI subsystems.

Management of gas voids is important to ECCS injection/spray subsystem OPERABILITY.

With less than the required number of ECCS subsystems OPERABLE, the potential exists that during a limiting design basis LOCA concurrent with the worst case single failure, the limits specified in Reference 10 could be exceeded. All ECCS subsystems must therefore be OPERABLE to satisfy the single failure criterion required by Reference 10.

five four four failure of the class 1E 125 VDC electrical power distribution subsystem A both and 1

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-5 Rev. 5.0 Hope Creek Revision XXX 1

BASES LCO (continued)

[ As noted, LPCI subsystems may be considered OPERABLE during alignment and operation for decay heat removal when below the actual RHR cut in permissive pressure in MODE 3, if capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable. Alignment and operation for decay heat removal includes when the required RHR pump is not operating or when the system is realigned from or to the RHR shutdown cooling mode. This allowance is necessary since the RHR System may be required to operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. At these low pressures and decay heat levels, a reduced complement of ECCS subsystems should provide the required core cooling, thereby allowing operation of RHR shutdown cooling when necessary. ]

APPLICABILITY All ECCS subsystems are required to be OPERABLE during MODES 1, 2, and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure is 150 psig, ADS and HPCI are not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. Requirements for MODES 4 and 5 are specified in LCO 3.5.2, "RPV Water Inventory Control."

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCI subsystem 2. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCI subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 If any one low pressure ECCS injection/spray subsystem is inoperable, or if one LPCI pump in both LPCI subsystems is inoperable, the inoperable subsystem(s) must be restored to OPERABLE status within 7 days [or in accordance with the Risk Informed Completion Time Program]. In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced, because a single failure in one of the remaining OPERABLE subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is based on a reliability study (Ref. 12) that evaluated the impact on ECCS 200 psig B.1 INSERT 1 4

shutdown cooling (SDC) 2 5

CS 1

2 an industry

ECCS - Operating B 3.5.1 Insert Page B 3.5.1-5 INSERT 1 A.1 If one LPCI subsystem is inoperable, the subsystem must be restored to OPERABLE status within 30 days due to the overall reduction in defense in depth of the ECCS to fulfill its safety function to respond to an accident condition. In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced, because a single failure of a 125 V battery (e.g.,

Battery Bank A), concurrent with a LOCA in another ECCS line, may result in the ECCS not being able to perform its intended safety function.

The 30 day Completion Time is based on the availability of five remaining OPERABLE low pressure ECCS injection/spray subsystems to mitigate a design basis LOCA and the low probability of a DBA.

1

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-6 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued) availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times).

B.1

---

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

Adoption of a MODE 3 end state requires the licensee to make the following commitments:

1.

[LICENSEE] will follow the guidance established in Section 11 of NUMARC 93-01, "Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Nuclear Management and Resource Council, Revision [4F].

2.

[LICENSEE] will follow the guidance established in TSTF-IG-05-02, Implementation Guidance for TSTF-423, Revision 2, "Technical Specifications End States, NEDC-32988-A," November 2009.

If the inoperable low pressure ECCS subsystem cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 13) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 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 3, 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.

C.1 INSERT 2 plant specific 1

1

ECCS - Operating B 3.5.1 Insert Page B 3.5.1-6 INSERT 2 C.1 If two LPCI subsystems are inoperable, at least one of the two inoperable LPCI subsystems must be restored to OPERABLE status within 7 days.

In this Condition, the remaining four OPERABLE low pressure ECCS injection/subsystems (two LPCI subsystems and two CS subsystems) provide adequate core cooling during a LOCA for most spectrum of break sizes. However, overall ECCS reliability is reduced, because a single failure in one of the remaining OPERABLE subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is based on an industry reliability study (Ref. 12) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service.

The results were used to calculate the plant specific availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times) approved in Reference 13.

1

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-7 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued)

The allowed Completion Time is 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 and C.2 If the HPCI System is inoperable and the RCIC System is verified to be OPERABLE, the HPCI System must be restored to OPERABLE status within 14 days [or in accordance with the Risk Informed Completion Time Program]. In this Condition, adequate core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection/spray subsystems in conjunction with ADS. Also, the RCIC System will automatically provide makeup water at most reactor operating pressures. Verification of RCIC OPERABILITY immediately is therefore required when HPCI is inoperable. This may be performed as an administrative check by examining logs or other information to determine if RCIC is out of service for maintenance or other reasons. It does not mean to perform the Surveillances needed to demonstrate the OPERABILITY of the RCIC System. If the OPERABILITY of the RCIC System cannot be verified, however, Condition G must be immediately entered. If a single active component fails concurrent with a design basis LOCA, there is a potential, depending on the specific failure, that the minimum required ECCS equipment will not be available. A 14 day Completion Time is based on a reliability study cited in Reference 12 and has been found to be acceptable through operating experience.

D.1 and D.2 If any one low pressure ECCS injection/spray subsystem, or one LPCI pump in both LPCI subsystems, is inoperable in addition to an inoperable HPCI System, the inoperable low pressure ECCS injection/spray subsystem or the HPCI System must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program]. In this Condition, adequate core cooling is ensured by the OPERABILITY of the ADS and the remaining low pressure ECCS subsystems. However, the overall ECCS reliability is significantly reduced because a single failure in one of the remaining OPERABLE subsystems concurrent with a design basis LOCA may result in the ECCS not being able to perform its intended safety function. Since both a high pressure system (HPCI) and a low pressure subsystem are inoperable, a more restrictive Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is required to restore either INSERT 3 E

E F

F INSERT 4 1

2 2

1 reduced ECCS capability

ECCS - Operating B 3.5.1 Insert Page B 3.5.1-7a INSERT 3 D.1 If three LPCI subsystems are inoperable, at least one of the three inoperable LPCI subsystems must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, the remaining three OPERABLE low pressure ECCS injection/subsystems (one LPCI subsystem and two CS subsystems) provide adequate core cooling during a LOCA for most spectrum of break sizes. However, overall ECCS reliability is significantly reduced, because a single failure in one of the remaining OPERABLE subsystems, concurrent with a LOCA, will result in the ECCS not being able to perform its intended safety function. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on an industry reliability study (Ref. 12) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the plant specific availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e.,

Completion Times) approved in Reference 13.

1

ECCS - Operating B 3.5.1 Insert Page B 3.5.1-7b INSERT 4 G.1, G.2, and G.3 If one CS subsystem and one LPCI subsystem are inoperable in addition to the HPCI System inoperable, the overall ECCS reliability to address a design basis LOCA is reduced. The limited availability of ECCS subsystems requires a more restrictive Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore either the HPCI System, CS subsystem, or the LPCI subsystem to OPERABLE status due to the overall reduction in defense in depth of the ECCS to fulfill its safety function to respond to an accident condition. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time takes into account the additional redundancy afforded by the four independent loop design of the LPCI System to still provide a low pressure injection source into the reactor to maintain core cooling and the low likelihood of a LOCA. This Completion Time is based the Completion Time for one inoperable AC electrical power distribution subsystem of Specification 3.8.9, Distribution Systems - Operating, allowed to restore multiple inoperable safety related systems as described in Reference 15, which concludes that a sufficient number of ECCS subsystems remain available to adequately mitigate a design basis LOCA.

1

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-8 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued) the HPCI System or the low pressure ECCS injection/spray subsystem to OPERABLE status. This Completion Time is based on a reliability study cited in Reference 12 and has been found to be acceptable through operating experience.

E.1 The LCO requires seven ADS valves to be OPERABLE in order to provide the ADS function. Reference 14 contains the results of an analysis that evaluated the effect of one ADS valve being out of service.

Per this analysis, operation of only six ADS valves will provide the required depressurization. However, overall reliability of the ADS is reduced, because a single failure in the OPERABLE ADS valves could result in a reduction in depressurization capability. Therefore, operation is only allowed for a limited time. The 14 day Completion Time is based on a reliability study cited in Reference 12 and has been found to be acceptable through operating experience. [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.]

F.1 and F.2 If any one low pressure ECCS injection/spray subsystem, or one LPCI pump in both LPCI subsystems, is inoperable in addition to one inoperable ADS valve, adequate core cooling is ensured by the OPERABILITY of HPCI and the remaining low pressure ECCS injection/spray subsystem. However, overall ECCS reliability is reduced because a single active component failure concurrent with a design basis LOCA could result in the minimum required ECCS equipment not being available. Since both a high pressure system (ADS) and a low pressure subsystem are inoperable, a more restrictive Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is required to restore either the low pressure ECCS subsystem or the ADS valve to OPERABLE status. This Completion Time is based on a reliability study cited in Reference 12 and has been found to be acceptable through operating experience. [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.]

I I

H five four 11 1

2 1

14 1

14 2

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-9 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued)

G.1

---

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

Adoption of a MODE 3 end state requires the licensee to make the following commitments:

1.

[LICENSEE] will follow the guidance established in Section 11 of NUMARC 93-01, "Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Nuclear Management and Resource Council, Revision [4F].

2.

[LICENSEE] will follow the guidance established in TSTF-IG-05-02, Implementation Guidance for TSTF-423, Revision 2, "Technical Specifications End States, NEDC-32988-A," November 2009.

If any Required Action and associated Completion Time of Condition C, D, E, or F is not met, the plant must be brought to a MODE in which the overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 13) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action G.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 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 3, 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 Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

J A, B, C, D, E, F, G, H, or I J

6 1

1 1

1 16

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-10 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued)

H.1 and H.2 If two or more ADS valves are inoperable, there is a reduction in the depressurization capability. The plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reactor steam dome pressure reduced to 150 psig 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 plant conditions from full power conditions in an orderly manner and without challenging plant systems.

I.1 When multiple ECCS subsystems are inoperable, as stated in Condition H, the plant is in a condition outside of the accident analyses.

Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS The ECCS injection/spray subsystem flow path piping and components have the potential to develop voids and pockets of entrained gases.

Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS injection/spray subsystems and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of ECCS injection/spray subsystem locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The ECCS injection/spray subsystem is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or K

K L

L 200 1

4 1

1 7

was have been determined to include the piping from each ECCS pump discharge valve to the associated injection valve(s) 7 This is verified by venting the piping of each ECCS injection/spray subsystem at the system high point vents.

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-11 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued) discharge of a pump), the Surveillance is not met. If the accumulated gas is eliminated or brought within the acceptance criteria limits during performance of the Surveillance, the Surveillance is met and past system OPERABILITY is evaluated under the Corrective Action Program. If it is determined by subsequent evaluation that the ECCS injection/spray subsystems are not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS injection/spray subsystem locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

[ The 31 day Frequency is based on the gradual nature of void buildup in the ECCS injection/spray subsystem piping, the procedural controls governing system operation, and operating experience.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

---

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.

---

]

3 2

7 7

7

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-12 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.1.2 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. For the HPCI System, this SR also includes the steam flow path for the turbine and the flow controller position.

[ The 31 day Frequency of this SR was derived from the INSERVICE TESTING PROGRAM requirements for performing valve testing at least once every 92 days. The Frequency of 31 days is further justified because the valves are operated under procedural control and because improper valve position would only affect a single subsystem. This Frequency has been shown to be acceptable through operating experience.

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.

---

]

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

2 3

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-13 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.1.3 Verification that ADS air supply header pressure is [90] psig ensures adequate air pressure for reliable ADS operation. The accumulator on each ADS valve provides pneumatic pressure for valve actuation. The design pneumatic supply pressure requirements for the accumulator are such that, following a failure of the pneumatic supply to the accumulator, at least two valve actuations can occur with the drywell at 70% of design pressure (Ref. 11). The ECCS safety analysis assumes only one actuation to achieve the depressurization required for operation of the low pressure ECCS. This minimum required pressure of [90] psig is provided by the ADS instrument air supply. [ The 31 day Frequency takes into consideration administrative controls over operation of the air system and alarms for low air pressure.

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.

---

]

SR 3.5.1.4 Verification that the RHR System cross tie valve is closed and power to its operator is disconnected ensures that each LPCI subsystem remains independent and a failure of the flow path in one subsystem will not affect the flow path of the other LPCI subsystem. Acceptable methods of removing power to the operator include de-energizing breaker control power or racking out or removing the breaker. If the RHR System cross tie valve is open or power has not been removed from the valve operator, both LPCI subsystems must be considered inoperable. [ The 31 day Frequency has been found acceptable, considering that these valves are under strict administrative controls that will ensure the valves continue to remain closed with either control or motive power removed.

OR primary containment instrument gas receiver 2

85 1

2 85 3

primary containment instrument gas 2

1 1

RHR crosstie valves allow the C (D)

RHR pump to be used as a means for Alternate Decay Heat Removal via its respective RHR loop heat exchanger if the normal shutdown cooling RHR Pump A (B) for the loop is inoperable. Open RHR System cross tie valves affect LPCI subsystem OPERABILITY.

valves, manual valves used for alternate decay heat removal, are

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-14 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

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.

---

]

SR 3.5.1.5 Verification that each LPCI inverter output has a voltage of [570] V and

[630] V while supplying its respective bus demonstrates that the AC electrical power is available to ensure proper operation of the associated LPCI inboard injection and minimum flow valves and the recirculation pump discharge valve. Each inverter must be OPERABLE for the associated LPCI subsystem to be OPERABLE. [ The 31 day Frequency has been found acceptable based on engineering judgment and operating experience.

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.

---

]

SR 3.5.1.6 Cycling the recirculation pump discharge [and bypass] valves through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will close when required. Upon initiation of an automatic LPCI subsystem injection signal, these valves are required to be closed to ensure full LPCI subsystem flow injection in the reactor via the recirculation jet pumps. De-energizing the valve in the closed position will also ensure the proper flow path for the LPCI subsystem. Acceptable methods of de-energizing the valve include de-energizing breaker control power, racking out the breaker or removing the breaker.

3 8

3 8

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-15 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

The specified Frequency is once during reactor startup before THERMAL POWER is > 25% RTP. However, this SR is modified by a Note that states the Surveillance is only required to be performed if the last performance was more than 31 days ago. Therefore, implementation of this Note requires this test to be performed during reactor startup before exceeding 25% RTP. Verification during reactor startup prior to reaching

> 25% RTP is an exception to the normal INSERVICE TESTING PROGRAM generic valve cycling Frequency, but is considered acceptable due to the demonstrated reliability of these valves. If the valve is inoperable and in the open position, the associated LPCI subsystem must be declared inoperable.

SR 3.5.1.7, SR 3.5.1.8, and SR 3.5.1.9 The performance requirements of the low pressure ECCS pumps are determined through application of the 10 CFR 50, Appendix K criteria (Ref. 8). This periodic Surveillance is performed (in accordance with the ASME Code requirements for the ECCS pumps) to verify that the ECCS pumps will develop the flow rates required by the respective analyses.

The low pressure ECCS pump flow rates ensure that adequate core cooling is provided to satisfy the acceptance criteria of Reference 10.

The pump flow rates are verified against a system head equivalent to the RPV pressure expected during a LOCA. The total system pump outlet pressure is adequate to overcome the elevation head pressure between the pump suction and the vessel discharge, the piping friction losses, and RPV pressure present during a LOCA. These values may be established during preoperational testing.

The flow tests for the HPCI System are performed at two different pressure ranges such that system capability to provide rated flow is tested at both the higher and lower operating ranges of the system.

Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the HPCI System diverts steam flow. Reactor steam pressure must be [920] psig to perform SR 3.5.1.8 and [150] psig to perform SR 3.5.1.9. Adequate steam flow is represented by [at least 1.25 turbine bypass valves open, or total steam flow 106 lb/hr]. Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these tests. Reactor startup is allowed prior to performing the low pressure Surveillance test because the reactor pressure is low and the time allowed to satisfactorily perform the Surveillance test is short. The reactor pressure is allowed to be increased to normal operating pressure since it is assumed that the low pressure test has been satisfactorily completed and there is no indication or reason to believe that HPCI is inoperable.

8 5

6 7

8 200 6

7 8

2 one

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-16 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

Therefore, SR 3.5.1.8 and SR 3.5.1.9 are modified by Notes that state the Surveillances are not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the reactor steam pressure and flow are adequate to perform the test.

---

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 [92 days] or the reference to the Surveillance Frequency Control Program should be used.

[ The Frequency for SR 3.5.1.7 is [92 days] [in accordance with the INSERVICE TESTING PROGRAM]. The Frequency for SR 3.5.1.8 is in accordance with the Inservice Testing Program requirements. The 18 month Frequency for SR 3.5.1.9 is based on the need to perform the Surveillance under the conditions that apply just prior to or during a startup from a plant outage. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

OR The Surveillance Frequencies for [SR 3.5.1.7,] SR 3.5.1.8, and SR 3.5.1.9 are 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.

---

]

SR 3.5.1.10 The ECCS subsystems are required to actuate automatically to perform their design functions. This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCI, CS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup and actuation of all SR 3.5.1.5 and SR 3.5.1.6 y

is 6

7 8

9 8

2 9

8 3

8 8

7

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-17 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued) automatic valves to their required positions. This SR also ensures that the HPCI System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool. The SR excludes automatic valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to valves that are locked, sealed, or otherwise secured in the actuated position since the affected valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured.

Placing an automatic valve in a locked, sealed, or otherwise secured position requires an assessment of the OPERABILITY of the system or any supported systems, including whether it is necessary for the valve to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve to the non-actuated position requires verification that the SR has been met within its required Frequency. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlaps this Surveillance to provide complete testing of the assumed safety function.

[ The 18 month Frequency is based on the need to perform the Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

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.

---

]

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

2 3

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-18 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.1.11 The ADS designated S/RVs are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e.,

solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components. SR 3.5.1.12 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

[ The 18 month Frequency is based on the need to perform the Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

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.

---

]

This SR is modified by a Note that excludes valve actuation. This prevents an RPV pressure blowdown.

SR 3.5.1.12 A manual actuation of each ADS valve is performed to verify that the valve and solenoid are functioning properly and that no blockage exists in the S/RV discharge lines. This is demonstrated by the response of the turbine control or bypass valve or by a change in the measured flow or by any other method suitable to verify steam flow. Adequate reactor steam dome pressure must be available to perform this test to avoid damaging the valve. Also, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure The ADS designated S/RVs are required to be capable of being opened. The requirement is determined through application of periodic verification of the individual ADS S/RV components in determining an ADS valve is capable of being opened. This testing includes testing of the solenoid valves, air operator, and pilot assembly; leak testing of the ADS instrument gas/accumulator; and main disk exercising of all SRVs in accordance with the INSERVICE TESTING PROGRAM.

8 9

10 2

3 10 10 10

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-19 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued) when the ADS valves divert steam flow upon opening. Sufficient time is therefore allowed after the required pressure and flow are achieved to perform this SR. Adequate pressure at which this SR is to be performed is [920 psig] (the pressure recommended by the valve manufacturer).

Adequate steam flow is represented by [at least 1.25 turbine bypass valves open, or total steam flow 106 lb/hr]. Reactor startup is allowed prior to performing this SR because valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME requirements, prior to valve installation. Therefore, this SR is modified by a Note that states the Surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test. The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for manual actuation after the required pressure is reached is sufficient to achieve stable conditions and provides adequate time to complete the Surveillance. SR 3.5.1.11 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

[ The Frequency of 18 months on a STAGGERED TEST BASIS ensures that both solenoids for each ADS valve are alternately tested. The Frequency is based on the need to perform the Surveillance under the conditions that apply just prior to or during a startup from a plant outage.

Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

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.

---

]

REFERENCES

1.

FSAR, Section [6.3.2.2.3].

2.

FSAR, Section [6.3.2.2.4].

3.

FSAR, Section [6.3.2.2.1].

U U

U 3

1 2

10

ECCS - Operating 3.5.1 General Electric BWR/4 STS B 3.5.1-20 Rev. 5.0 Hope Creek Revision XXX 1

BASES REFERENCES (continued)

4.

FSAR, Section [6.3.2.2.2].

5.

FSAR, Section [15.2.8].

6.

FSAR, Section [15.6.4].

7.

FSAR, Section [15.6.5].

8.

10 CFR 50, Appendix K.

9.

FSAR, Section [6.3.3].

10.

10 CFR 50.46.

11.

FSAR, Section [7.3.1.2.2].

12.

Memorandum from R.L. Baer (NRC) to V. Stello, Jr. (NRC),

"Recommended Interim Revisions to LCOs for ECCS Components,"

December 1, 1975.

13.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

14.

FSAR, Section [6.3.3.3].

U U

U U

U 6.3.3.3 6.3.3.7 15.6.5 15.C NEDC-33172, "SAFER/GESTR-LOCA Loss-of-Coolant Accident Analysis for Hope Creek Generating Station at Power Uprate, March 2005.

1 2

16

13. NUREG-1202, "Technical Specifications Hope Creek Generating Station," July 1986 (NRC ADAMS Accession No. ML20205D512).

14. Letter from D. H Jaffe (NRC) to L.R. Eliason (PSEG), "HOPE CREEK GENERATING STATION (TAC NO. M89220)," November 30, 1995 (NRC ADAMS Accession No. ML011760500).

15. Letter from J.S. Kim (NRC) to E. Carr (PSEG), "Hope Creek Generating Station Issuance of Amendment No. 226 RE: Revise Emergency Core Cooling System Technical Specification for High Pressure Coolant Injection System Inoperability (EPID L-2020-LLA-0131)," March 10, 2021 (NRC ADAMS Accession No. ML21047A313)

JUSTIFICATION FOR DEVIATIONS ITS 3.5.1 BASES, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 1 of 2

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

3. The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

4. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. The ISTS 3.5.1 Applicability exception of 150 psig for the HPCI System and ADS is based on a standard General Electric BWR/4 ECCS design where adequate steam pressure is available to the HPCI System and ADS for the components to perform their intended safety functions. The ITS 3.5.1 Applicability exception of 200 psig is consistent with Applicability allowance of the HPCI System specified in CTS. Additionally, the pressure specified in ITS 3.5.1 Required Action K.2 (ISTS 3.5.1 Required Action H.2) specifies 200 psig since the applicability of the ADS valves is changed to 200 psig equivalent with the HPCI System Applicability, as described in the CTS Discussion of Changes. ISTS Bases are revised in the ITS to reflect the change to Specification Applicability and associated Required Action.

5. Editorial correction is made to NUREG 1433 (Revision 5) ISTS 3.5.1 Bases.

6. Hope Creek is adopting TSTF-423-A, Technical Specification End States, consistent with ISTS 3.5.3 ACTION B. The addition of ITS ACTION J is consistent with Revision 5 of the ISTS as adopted by Technical Specifications Task Force (TSTF) traveler TSTF-423-A, Revision 1, Technical Specification End States, NEDC-32988-A, dated September 16, 2014. (ADAMS Accession No. ML102730688). The TSTF was approved for licensee adoption as documented in Federal Register Notice 76 FR 9614 (ADAMS Accession No. ML102730585). PSEG Nuclear has previously committed to assess and manage risk at Hope Creek Generating Station (HCGS) in accordance with the guidance of NUMARC 93-01, Rev. 4F, Section 11 (e.g., Amendment 228 (ADAMS Accession No. ML21098A087)).

PSEG Nuclear will also follow the guidance established in TSTF-IG-05-02, Implementation Guidance for TSTF-423, Rev. 1, Technical Specifications End States, NEDC-32988-A, upon implementation of the end state requirements.

7. ISTS SR 3.5.1.1, associated with verifying, for each ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water, is revised in the ITS to maintain the wording in the current Technical Specifications. PSEG provided response to NRC Generic Letter (GL) 2008-01 related to HCGS management of gas accumulation in letters dated April 10, 2008, October 13, 2008, July 30, 2009, and January 28, 2011 (ADAMS Accession Nos.

ML081130672, ML082970219, ML092230347 and ML110400201, respectively).

The responses included the results of evaluations performed on systems of concern,

JUSTIFICATION FOR DEVIATIONS ITS 3.5.1 BASES, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 2 of 2 summary of procedural controls, and description of support features (such as the Emergency Core Cooling System "keep-fill" system). Based on the review of information provided by PSEG, the NRC found the responses acceptable and subsequently closed the GL 2008-01 request for HCGS in letter to T. Joyce (PSEG) from R.B. Ennis (NRC), dated June 2, 2011 (ADAMS Accession No. ML111380081),

with no further information or action required. Therefore, adoption of ISTS SR 3.5.1.1 is not necessary to ensure associated systems are properly maintained in an OPERABLE condition and ITS SR 3.5.1.1 is revised to be consistent with current licensing basis. Changes to the ISTS Bases are made to support the changes to the Specification.

8. ISTS SRs 3.5.1.5 and 3.5.1.6 are not included in the ITS because these Surveillances do not apply to HCGS. The HCGS LPCI System design does not include LPCI inverters to supply power to the LPCI inboard injection, minimum flow valves, or recirculation pump discharge valves. In addition, the HCGS ECCS design does not include automatic closure of the recirculation pump discharge valves on a LPCI initiation signal because the LPCI subsystems inject directly into the reactor core shroud and do not interface with the discharge line of the recirculation pumps.

Subsequent Surveillances are renumbered, as necessary, to support this deviation.

9. The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. These Notes are not meant to be retained in the final version of the plant specific submittal. The low pressure ECCS injection/spray pump flow rate testing (ITS SR 3.5.1.5) and the HPCI pump high pressure flow rate testing (ITS SR 3.5.1.6) are within the scope of the plants Inservice Testing Program consistent with the current licensing basis. The Frequency of the HPCI pump low pressure flow rate testing (ITS SR 3.5.1.7) is specified in accordance with the Surveillance Frequency Control Program consistent with the current licensing basis.

10. Bases changes are made to reflect the changes to the Specification. The ISTS SR 3.5.1.12 (ITS SR 3.5.1.10) bases is modified to include testing providing periodic verification of the individual ADS SRV components in determining an ADS valve is capable of being opened. As outlined in License Amendment 116, dated February 10, 1999 (ADAMS Accession No. ML011770051), this includes testing of the ADS logic, solenoid valves, air operator, and pilot assembly; leak testing of the ADS instrument gas/accumulator; setpoint testing of 50% of the pilot stages each refueling; main disk exercising of all SRVs at least each 5 years and when the entire valve assembly is shipped to the certified test facility.

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.1, EMERGENCY CORE COOLING SYSTEMS (ECCS) - OPERATING Hope Creek Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 2 ITS 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control

Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)

EMERGENCY CORE COOLING SYSTEMS (ECCS) AND RPV WATER INVENTORY CONTROL 3/4 5.2 RPV WATER INVENTORY CONTROL LIMITING CONDITION FOR OPERATION 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> AND At least one of the following low pressure ECCS subsystems shall be OPERABLE:

a.

Core spray system subsystem with a subsystem comprised of:

1.

Two OPERABLE core spray pumps, and

2.

An OPERABLE flow path capable of taking suction from at least one of the following water sources and transferring the water through the spray sparger to the reactor vessel:

a)

From the suppression chamber, or b)

When the suppression chamber water level is less than the limit or is drained, from the condensate storage tank containing at least 135,000 available gallons of water.

b.

Low pressure coolant injection (LPCI) system subsystem with a subsystem comprised of:

1.

One OPERABLE LPCI pump, and

2.

An OPERABLE flow path capable of taking suction from the suppression chamber and transferring the water to the reactor vessel. **

APPLICABILITY:

OPERATIONAL CONDITION 4 and 5.

ACTION:

a.

With none of the above low pressure ECCS subsystems OPERABLE, immediately suspend CORE ALTERATIONS and restore a subsystem to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Otherwise, immediately initiate action to establish a method of water injection capable of operating without offsite electrical power.

b.

Deleted.

Deleted.

A LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

HOPE CREEK 3/4 5-6 Amendment 213 LCO 3.5.2 3.5.2

, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Reactor Pressure Vessel (RPV) injection/spray LA01 MODES A02 Applicability ACTION A ACTION B Required injection/spray inoperable required ECCS injection/spray A01 ITS 3.5.2 ITS L01 LA02

Required Action D.1 Note EMERGENCY CORE COOLING SYSTEMS (ECCS) AND RPV WATER INVENTORY CONTROL LIMITING CONDITION FOR OPERATION (continued)

ACTION:

c.

With DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, within 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s:

1.

Verify secondary containment boundary is capable of being established in less than the DRAIN TIME, AND

2.

Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME, AND

3.

Verify one Filtration, Recirculation and Ventilation (FRVS) ventilation unit is capable of being placed in operation in less than the DRAIN TIME.

Otherwise, immediately initiate action to restore DRAIN TIME to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

d.

With DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and > 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, immediately:

1. Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />s*** AND,

2. Initiate action to establish secondary containment boundary, AND

3. Initiate action to isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room, AND

4. Initiate action to verify one FRVS ventilation unit is capable of being placed in operation.

Otherwise, immediately initiate action to restore DRAIN TIME to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

e.

With DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, immediately initiate action to restore DRAIN TIME to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

• • • Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

HOPE CREEK 3/4 5-6a Amendment 227 A01 ITS 3.5.2 ITS

, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM ACTION C Required Action C.1 Required Action C.2 Required Action C.3 ACTION E ACTION D Required Action D.1 Required Action D.2 Required Action D.3 ACTION E Required Action D.4 A03

EMERGENCY CORE COOLING SYSTEMS (ECCS) AND RPV WATER INVENTORY CONTROL SURVEILLANCE REQUIREMENTS 4.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in accordance with the Surveillance Frequency Control Program.

4.5.2.2 Verify, for a required low pressure coolant injection (LPCI) subsystem, the suppression chamber indicated water level is > 5.0 inches in accordance with the Surveillance Frequency Control Program.

4.5.2.3 Verify, for a required Core Spray (CS) subsystem, the Suppression chamber indicated water level is > 5.0 inches or condensate storage tank contains at least 135,000 available gallons of water in accordance with the Surveillance Frequency Control Program.

4.5.2.4 Verify, for the required ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve in accordance with the Surveillance Frequency Control Program.

4.5.2.5 Deleted 4.5.2.6 Operate the required ECCS injection/spray subsystem for 10 minutes, in accordance with the Surveillance Frequency Control Program. # ###

4.5.2.7 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal, in accordance with the Surveillance Frequency Control Program.

4.5.2.8 Verify the required ECCS injection/spray subsystem can be manually operated, in accordance with the Surveillance Frequency Control Program. ##

1. Operation may be through the test return line.

1. 1. Vessel injection/spray may be excluded.

1. 1. 1. Credit may be taken for normal system operation to satisfy this SR.

HOPE CREEK 3/4 5-7 Amendment No. 227 SR 3.5.2.1 SR 3.5.2.2 SR 3.5.2.3 SR 3.5.2.4 SR 3.5.2.5 SR 3.5.2.6 SR 3.5.2.7 SR 3.5.2.5 Note 1 SR 3.5.2.7 Note SR 3.5.2.5 Note 2 A01 ITS 3.5.2 ITS

, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM pool pool water volume is

DISCUSSION OF CHANGES ITS 3.5.2, REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL Hope Creek Page 1 of 4 ADMINISTRATIVE CHANGES A01 In the conversion of the Hope Creek Generating Station (HCGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 5.0, "Standard Technical Specifications-General Electric BWR/4 Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.5.2 Applicability states OPERATIONAL CONDITION 4 and 5. ITS 3.5.2 Applicability states MODES 4 and 5. This changes the CTS by incorporating the ITS MODE definition, and by clearly stating the Reactor Pressure Vessel (RPV)

Water Inventory Control is required to be OPERABLE in MODES 4 and 5.

The purpose of CTS 3.5.2 Applicability is to establish the Operational Condition (i.e., ITS MODE) in which the LCO is required. This change is acceptable because the Applicability of MODE is not changed. This change is designated as an administrative change and is acceptable because it does not result in a technical change to the CTS.

A03 CTS Action d. Condition is applicable With DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. ITS 3.5.2 ACTION D Condition is applicable with DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

This changes the CTS by deleting and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from the CTS Action d.

Condition.

The purpose of ITS 3.5.2 ACTION D is with the DRAIN TIME less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, mitigating actions are implemented in case an unexpected draining event should occur. If the DRAIN TIME is less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, Required Action E.1 is also applicable and Required Actions D.1, D.2, D.3, and D.4 are still applicable when DRAIN TIME is less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. For CTS, if DRAIN TIME is less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Action d. Condition is not met and Actions d.1, d.2, d.3, and d.4 are no longer required until the DRAIN TIME is restored to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. ITS ACTION D does not retain the CTS and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> requirement. The removal of the and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ensures the appropriate interpretation of the current requirements under ITS.

This ensures that If the DRAIN TIME is less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, Required Action E.1 is entered and Required Actions D.1, D.2, D.3, and D.4 are still applicable.

This change is acceptable because it ensures with DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, the actions entered remain applicable when DRAIN TIME is less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This change is designated as more restrictive this change is only an enhanced presentation of existing requirements and does not alter the intent of the current requirements.

MORE RESTRICTIVE CHANGES None

DISCUSSION OF CHANGES ITS 3.5.2, REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL Hope Creek Page 2 of 4 RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.5.2 LCO requires that one of the low pressure ECCS subsystems be OPERABLE, and provides details for the core spray subsystem (CTS LCO 3.5.2.a) and the low pressure coolant injection (LPCI) subsystem (LCO 3.5.2.b) to be considered OPERABLE. This changes the CTS by moving these details regarding low pressure ECCS core spray and LPCI subsystem OPERABILITY from Technical Specifications to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS LCO retains the requirement that one low pressure ECCS injection/spray subsystem be OPERABLE. One low pressure ECCS injection/spray subsystem is required to be OPERABLE and capable of being manually aligned and started from the control room to provide defense-in-depth should an unexpected draining event occur. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.5.2.b.2 Footnote ** states A LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable. This note is not included in the ITS LCO 3.5.2. This changes the CTS by moving these details regarding LPCI subsystem OPERABILITY from Technical Specifications to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. TSTF-582, Revision 0, dated October 9, 2020 (ADAMS Accession No. ML20219A333), revised Technical Specification (TS) 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control." Limiting Condition for Operation (LCO) 3.5.2 was modified by a Note which permits an Emergency Core Cooling System (ECCS) subsystem to be considered operable while providing decay heat removal if it can be manually realigned to the ECCS configuration. However, the changes in TSTF-582 revised TS 3.5.2 to permit an ECCS subsystem to be considered operable if it can be manually aligned and started, eliminating the need for the LCO Note. Therefore, the LCO Note is

DISCUSSION OF CHANGES ITS 3.5.2, REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL Hope Creek Page 3 of 4 proposed to be deleted by TSTF-587, Revision 0, dated August 13, 2020 (ADAMS Accession No. ML20223A000). TSTF-587 states that the reason for the proposed change is following the changes made by TSTF-582, the LCO Note is no longer required because an ECCS injection/spray subsystem is operable if it can be manually aligned or started from the control room, even when it is being used as a residual heat removal (RHR) subsystem. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.5.2, Action a requires With none of the above low pressure ECCS subsystems OPERABLE, immediately suspend CORE ALTERATIONS and restore a subsystem to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS 3.5.2 ACTIONS do not require suspension of CORE ALTERATIONS for the same condition. This changes the CTS by deleting the requirement to suspend CORE ALTERATIONS when all low pressure ECCS subsystems are inoperable during refueling.

The purpose of the CTS Action requirement is to ensure appropriate remedial actions are taken when all low pressure ECCS are inoperable in MODE 4 or 5.

The RPV Water Inventory Control Specification was added to the HCGS Technical Specifications as a result of adopting Technical Specification Task Force (TSTF) Traveler TSTF-542-A, Reactor Pressure Vessel Water Inventory Control, Revision 2, in License Amendment 213 (ADAMS Accession No. ML18260A203). This TSTF was a BWR industry initiative to revise the BWR ISTS to allow the deletion of the term, operation with the potential for draining the reactor vessel (OPDRV). TSTF 542-A modified ISTS 3.5.2, ECCS -

Shutdown, which did not include an action to suspend CORE ALTERATIONS when no low pressure ECCS was OPERABLE, as justified in a number of BWR ITS Conversion submittals; e.g., Fermi 2 (ADAMS Accession No. ML20217Q504), Susquehanna Steam Electric Station, Units 1 and 2 (ADAMS Accession No. ML20116N004), and Brunswick Steam Electric Plant Units 1 and 2 (ADAMS Accession No. ML20134G093).

The proposed change is consistent with the ISTS prior to incorporation of TSTF-542 and the ECCS - Shutdown Actions for plants that converted to the ITS prior to the development of TSTF-542 A. The acceptability for the change to the previous ISTS ECCS - Shutdown Actions when all low pressure ECCS are inoperable also applies to HCGS. This change is acceptable because ITS refueling LCOs provide requirements to ensure safe operation during CORE ALTERATIONS including required water level above the RPV flange during certain activities and the position of the mode switch. The ECCS function enforced by ITS LCO 3.5.2 is intended to provide protection in the event of a loss of vessel inventory during shutdown and refueling conditions. However, a loss of vessel water inventory is not initiated by CORE ALTERATIONS and the

DISCUSSION OF CHANGES ITS 3.5.2, REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL Hope Creek Page 4 of 4 response to a loss of vessel water inventory is not hampered by CORE ALTERATION operations. Therefore, this change has no impact on safety. The ITS 3.5.2 ACTIONS, in conjunction with the LCO and ACTION requirements specified in the ITS Section 3.9, Refueling Operations, Specifications, ensure appropriate remedial actions are taken when all low pressure ECCS are inoperable in MODE 4 or 5. This change is designated as less restrictive because a Required Action in the CTS will not be required in the ITS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

RPV Water Inventory Control 3.5.2 General Electric BWR/4 STS 3.5.2-1 Rev. 5.0 Hope Creek Amendment XXX 1

3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

AND One low pressure ECCS injection/spray subsystem shall be OPERABLE.

APPLICABILITY:

MODES 4 and 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS injection/spray subsystem inoperable.

A.1 Restore required ECCS injection/spray subsystem to OPERABLE status.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. Required Action and associated Completion Time of Condition A not met.

B.1 Initiate action to establish a method of water injection capable of operating without offsite electrical power.

Immediately C. DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

C.1 Verify [secondary]

containment boundary is capable of being established in less than the DRAIN TIME.

AND 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 3.5.2 3.5.2.a, 3.5.2.b Applicability Action a Action a Action c Action c.1 CTS 2

RPV Water Inventory Control 3.5.2 General Electric BWR/4 STS 3.5.2-2 Rev. 5.0 Hope Creek Amendment XXX 1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.2 Verify each [secondary]

containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas treatment (SGT) subsystem is capable of being placed in operation in less than the DRAIN TIME.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4 hours D. DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

D.1

---

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

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

AND D.2 Initiate action to establish

[secondary] containment boundary.

AND Immediately Immediately Action c.2 Action c.3 Filtration Recirculation and Ventilation System (FRVS) ventilation unit Action d Action d.1 Footnote ***

Action d.2 3

2 Action d.1 CTS

RPV Water Inventory Control 3.5.2 General Electric BWR/4 STS 3.5.2-3 Rev. 5.0 Hope Creek Amendment XXX 1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.3 Initiate action to isolate each [secondary]

containment penetration flow path or verify it can be

[automatically or] manually isolated from the control room.

AND D.4 Initiate action to verify one SGT subsystem is capable of being placed in operation.

Immediately Immediately E. Required Action and associated Completion Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

E.1 Initiate action to restore DRAIN TIME to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance with the Surveillance Frequency Control Program ]

Action d.3 Action d.4 Action c (last action)

Action d (last action) 4.5.2.1 2

2 FRVS ventilation unit 3

2 2

CTS Action e.

RPV Water Inventory Control 3.5.2 General Electric BWR/4 STS 3.5.2-4 Rev. 5.0 Hope Creek Amendment XXX 1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for a required LPCI subsystem, the suppression pool water level is [12 ft 2 inches].

[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance with the Surveillance Frequency Control Program ]

SR 3.5.2.3 Verify, for a required core spray (CS) subsystem, the:

a. Suppression pool water level is

[12 ft 2 inches] or

b. Condensate storage tank water level is [12 ft].

[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance with the Surveillance Frequency Control Program ]

SR 3.5.2.4 Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

[ 31 days OR In accordance with the Surveillance Frequency Control Program ]

4.5.2.2 4.5.2.3 4.5.2.4 5.0 5.0 volume is 135,000 gallons 2

2 2

2 2

2 CTS 4

piping from the pump discharge valve to the associated injection valve is 5

RPV Water Inventory Control 3.5.2 General Electric BWR/4 STS 3.5.2-5 Rev. 5.0 Hope Creek Amendment XXX 1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5

---

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

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray subsystem for 10 minutes.

[ 92 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

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

SR 3.5.2.7

---

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

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

4.5.2.6 4.5.2.6 Footnote #

4.5.2.6 Footnote ##

4.5.2.7 4.5.2.8 2

2 2

2 2

2 CTS

JUSTIFICATION FOR DEVIATIONS ITS 3.5.2, REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL Hope Creek Page 1 of 2

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

3. ISTS 3.5.2 Required Actions C.3 and D.4 are modified in the ITS from one Standby Gas Treatment (SGT) subsystem to one Filtration Recirculation and Ventilation System (FRVS) ventilation unit. This deviation reflects the Hope Creek Generating Station (HCGS) design. As discussed in Section 2.2.6.11 of the NRC safety evaluation issued with HCGS License Amendment 213 (NRC ADAMS Accession No. ML18260A203), FRVS provides the equivalent level of secondary containment protection as the SGT System. One FRVS ventilation unit is capable of maintaining the secondary containment at a negative pressure with respect to the environment and filter gaseous releases in MODES 4 and 5.

4. Revised the text in ITS SR 3.5.2.3 to conform to TSTF-GG-05-01, Revision 1, Writers Guide for Plant-Specific Improved Technical Specifications, Section 3.2.2.

Section 3.2.2.a, Specific Use, requires an acronym to be identified upon the first reference and used alone on all subsequent references. With no subsequent references, identification of the acronym is not necessary.

5. ISTS SR 3.5.2.4, associated with verifying, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water, is revised in the ITS to maintain the wording in the current Technical Specifications. NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" (ADAMS Accession No. ML072910759), required licensees to submit information, in general, regarding concerns that certain safety systems could accumulate gas pockets that may inhibit system flow or damage system pumps/piping during an event which requires system operation. PSEG provided response to GL 2008-01 related to HCGS management of gas accumulation in letters dated April 10, 2008, October 13, 2008, July 30, 2009, and January 28, 2011 (ADAMS Accession Nos.

ML081130672, ML082970219, ML092230347 and ML110400201, respectively).

The responses included the results of evaluations performed on systems of concern, summary of procedural controls, and description of support features (such as the Emergency Core Cooling System "keep-fill" system). Based on the review of information provided by PSEG, the NRC found the responses acceptable and subsequently closed the GL 2008-01 request for HCGS in letter to T. Joyce (PSEG) from R.B. Ennis (NRC), dated June 2, 2011 (ADAMS Accession No. ML111380081),

with no further information or action required.

SRs associated with verifying certain systems remain full of water were adopted in the ISTS following NRC approval of Technical Specification Task Force (TSTF) traveler TSTF-523-A, "Generic Letter 2008-01, Managing Gas Accumulation,"

Revision 2, dated January 15, 2014 (79 FR 2700). PSEG subsequently performed an evaluation and determined that adoption of TSTF-523 was not necessary based on established controls and support features previously determined acceptable by

JUSTIFICATION FOR DEVIATIONS ITS 3.5.2, REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL Hope Creek Page 2 of 2 the NRC. Based on the considerations provided herein, ISTS SR 3.5.2.4 is not necessary to ensure associated systems are properly maintained in an OPERABLE condition and ITS SR 3.5.2.4 is revised to be consistent with current licensing basis.

Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-1 Rev. 5.0 Hope Creek Revision XXX 1

B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF.

If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not SAFETY required to mitigate any events or accidents evaluated in the safety ANALYSES analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material to the environment should an unexpected draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not considered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is considered in which an initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (an event that creates a drain path through multiple vessel penetrations located below top of active fuel, such as loss of normal power, or a single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety.

Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO The RPV water level must be controlled in MODES 4 and 5 to ensure that if an unexpected draining event should occur, the reactor coolant water level remains above the top of the active irradiated fuel as required by Safety Limit 2.1.1.3.

The Limiting Condition for Operation (LCO) requires the DRAIN TIME of RPV water inventory to the TAF to be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A DRAIN TIME of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is considered reasonable to identify and initiate action to

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-2 Rev. 5.0 Hope Creek Revision XXX 1

BASES LCO (continued) mitigate unexpected draining of reactor coolant. An event that could cause loss of RPV water inventory and result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

One low pressure ECCS injection/spray subsystem is required to be OPERABLE and capable of being manually aligned and started from the control room to provide defense-in-depth should an unexpected draining event occur. OPERABILITY of the ECCS injection/spray subsystem includes any necessary valves, instrumentation, or controls needed to manually align and start the subsystem from the control room. A low pressure ECCS injection/spray subsystem consists of either one core spray (CS) subsystem or one low pressure coolant injection (LPCI) subsystem. Each CS subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or condensate storage tank (CST) to the RPV. Each LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV. In MODES 4 and 5, the RHR System cross tie valve is not required to be closed. Management of gas voids is important to ECCS injection/spray subsystem OPERABILITY.

APPLICABILITY RPV water inventory control is required in MODES 4 and 5.

Requirements on water inventory control in other MODES are contained in LCOs in Section 3.3, "Instrumentation," and other LCOs in Section 3.5, "ECCS, RPV Water Inventory Control, and RCIC System." RPV water inventory control is required to protect Safety Limit 2.1.1.3 which is applicable whenever irradiated fuel is in the reactor vessel.

ACTIONS A.1 and B.1 If the required low pressure ECCS injection/spray subsystem is inoperable, it must be restored to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. In this Condition, the LCO controls on DRAIN TIME minimize the possibility that an unexpected draining event could necessitate the use of the ECCS injection/spray subsystem, however the defense-in-depth provided by the ECCS injection/spray subsystem is lost. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time for restoring the required low pressure ECCS injection/spray subsystem to OPERABLE status is based on engineering judgment that considers the LCO controls on DRAIN TIME and the low probability of an unexpected draining event that would result in loss of RPV water inventory.

1 two 1

s 1

2

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-3 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued)

If the inoperable ECCS injection/spray subsystem is not restored to OPERABLE status within the required Completion Time, action must be initiated immediately to establish a method of water injection capable of operating without offsite electrical power. The method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur. The method of water injection may be manually initiated and may consist of one or more systems or subsystems, and must be able to access water inventory capable of maintaining the RPV water level above the TAF for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

If recirculation of injected water would occur, it may be credited in determining the necessary water volume.

C.1, C.2, and C.3 With the DRAIN TIME less than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> but greater than or equal to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, compensatory measures should be taken to ensure the ability to implement mitigating actions should an unexpected draining event occur.

Should a draining event lower the reactor coolant level to below the TAF, there is potential for damage to the reactor fuel cladding and release of radioactive material. Additional actions are taken to ensure that radioactive material will be contained, diluted, and processed prior to being released to the environment.

The [secondary] containment provides a controlled volume in which fission products can be contained, diluted, and processed prior to release to the environment. Required Action C.1 requires verification of the capability to establish the [secondary] containment boundary in less than the DRAIN TIME. The required verification confirms actions to establish the [secondary] containment boundary are preplanned and necessary materials are available. The [secondary] containment boundary is considered established when one standby gas treatment (SGT) subsystem is capable of maintaining a negative pressure in the

[secondary] containment with respect to the environment.

Verification that the [secondary] containment boundary can be established must be performed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The required verification is an administrative activity and does not require manipulation or testing of equipment.

4 Filtration Recirculation and Ventilation System (FRVS) ventilation unit 3

3 3

3 3

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-4 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued)

[Secondary] containment penetration flow paths form a part of the

[secondary] containment boundary. Required Action C.2 requires verification of the capability to isolate each [secondary] containment penetration flow path in less than the DRAIN TIME. The required verification confirms actions to isolate the [secondary] containment penetration flow paths are preplanned and necessary materials are available. Power operated valves are not required to receive automatic isolation signals if they can be closed manually within the required time.

Verification that the [secondary] containment penetration flow paths can be isolated must be performed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The required verification is an administrative activity and does not require manipulation or testing of equipment.

One SGT subsystem is capable of maintaining the [secondary]

containment at a negative pressure with respect to the environment and filter gaseous releases. Required Action C.3 requires verification of the capability to place one SGT subsystem in operation in less than the DRAIN TIME. The required verification confirms actions to place a SGT subsystem in operation are preplanned and necessary materials are available. Verification that a SGT subsystem can be placed in operation must be performed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The required verification is an administrative activity and does not require manipulation or testing of equipment.

---

REVIEWER'S NOTE ----------------------------------

The bracketed information applies to multiple unit sites with a shared secondary containment and recognizes that an OPERABLE secondary containment, secondary containment penetrations, and SGT subsystems satisfy Required Actions C.1, C.2, and C.3.

[Required Actions C.1, C.2, and C.3 are considered to be met when

[secondary] containment, [secondary] containment penetrations, and the SGT System are OPERABLE in accordance with LCO 3.6.4.1, LCO 3.6.4.2, and LCO 3.6.4.3.]

FRVS ventilation unit FRVS ventilation unit 4

4 5

5 FRVS ventilation unit 4

3 3

3 3

3 One FRVS ventilation unit 4

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-5 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued)

D.1, D.2, D.3, and D.4

---

REVIEWER'S NOTE ----------------------------------

The bracketed information applies to multiple unit sites with a shared secondary containment and recognizes that an OPERABLE secondary containment, secondary containment penetrations, and SGT subsystems satisfy Required Actions D.2, D.3, and D.4.

With the DRAIN TIME less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, mitigating actions are implemented in case an unexpected draining event should occur. Note that if the DRAIN TIME is less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, Required Action E.1 is also applicable.

Required Action D.1 requires immediate action to establish an additional method of water injection augmenting the ECCS injection/spray subsystem required by the LCO. The additional method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur. The Note to Required Action D.1 states that either the ECCS injection/spray subsystem or the additional method of water injection must be capable of operating without offsite electrical power. The additional method of water injection may be manually initiated and may consist of one or more systems or subsystems. The additional method of water injection must be able to access water inventory capable of being injected to maintain the RPV water level above the TAF for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The additional method of water injection and the ECCS injection/spray subsystem may share all or part of the same water sources. If recirculation of injected water would occur, it may be credited in determining the required water volume.

Should a draining event lower the reactor coolant level to below the TAF, there is potential for damage to the reactor fuel cladding and release of radioactive material. Additional actions are taken to ensure that radioactive material will be contained, diluted, and processed prior to being released to the environment.

The [secondary] containment provides a control volume in which fission products can be contained, diluted, and processed prior to release to the environment. Required Action D.2 requires that actions be immediately initiated to establish the [secondary] containment boundary. With the

[secondary] containment boundary established, one SGT subsystem is capable of maintaining a negative pressure in the [secondary]

containment with respect to the environment.

5 FRVS ventilation unit 4

3 3

3 3

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-6 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued)

The [secondary] containment penetrations form a part of the [secondary]

containment boundary. Required Action D.3 requires that actions be immediately initiated to verify that each [secondary] containment penetration flow path is isolated or to verify that it can be [automatically or] manually isolated from the control room.

One SGT subsystem is capable of maintaining the [secondary]

containment at a negative pressure with respect to the environment and filter gaseous releases. Required Action D.4 requires that actions be immediately initiated to verify that at least one SGT subsystem is capable of being placed in operation. The required verification is an administrative activity and does not require manipulation or testing of equipment.

[Required Actions D.2, D.3, and D.4 are considered to be met when

[secondary] containment, [secondary] containment penetrations, and the SGT System are OPERABLE in accordance with LCO 3.6.4.1, LCO 3.6.4.2, and LCO 3.6.4.3.]

E.1 If the Required Actions and associated Completion Times of Conditions C or D are not met or if the DRAIN TIME is less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, actions must be initiated immediately to restore the DRAIN TIME to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. In this condition, there may be insufficient time to respond to an unexpected draining event to prevent the RPV water inventory from reaching the TAF.

Note that Required Actions D.1, D.2, D.3, and D.4 are also applicable when DRAIN TIME is less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

SURVEILLANCE SR 3.5.2.1 REQUIREMENTS This Surveillance verifies that the DRAIN TIME of RPV water inventory to the TAF is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The period of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is considered reasonable to identify and initiate action to mitigate draining of reactor coolant. Loss of RPV water inventory that would result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

5 FRVS ventilation unit 4

3 3

3 3

FRVS ventilation unit 4

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-7 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

The definition of DRAIN TIME states that realistic cross-sectional areas and drain rates are used in the calculation. A realistic drain rate may be determined using a single, step-wise, or integrated calculation considering the changing RPV water level during a draining event. For a control rod RPV penetration flow path with the control rod drive mechanism removed and not replaced with a blank flange, the realistic cross-sectional area is based on the control rod blade seated in the control rod guide tube. If the control rod blade will be raised from the penetration to adjust or verify seating of the blade, the exposed cross-sectional area of the RPV penetration flow path is used.

The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths. A blank flange or other bolted device must be connected with a sufficient number of bolts to prevent draining. Normal or expected leakage from closed systems or past isolation devices is permitted. Determination that a system is intact and closed or isolated must consider the status of branch lines.

The Residual Heat Removal (RHR) Shutdown Cooling System is only considered an intact closed system when misalignment issues (Reference 6) have been precluded by functional valve interlocks or by isolation devices, such that redirection of RPV water out of an RHR subsystem is precluded. Further, RHR Shutdown Cooling System is only considered an intact closed system if its controls have not been transferred to remote shutdown, which disables the interlocks and isolation signals.

The exclusion of a single penetration flow path, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME should consider the effects of temporary alterations in support of maintenance (rigging, scaffolding, temporary shielding, piping plugs, freeze seals, etc.). If reasonable controls are implemented to prevent such temporary alterations from causing a draining event from a closed system, or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered.

Reasonable controls include, but are not limited to, controls consistent with the guidance in NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision

[4F], NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," or commitments to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants."

3

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-8 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

Surveillance Requirement 3.0.1 requires SRs to be met between performances. Therefore, any changes in plant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined.

[ The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is sufficient in view of indications of RPV water level available to the operator.

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.

---

]

SR 3.5.2.2 and SR 3.5.2.3 The minimum water level of [12 ft 2 inches] required for the suppression pool is periodically verified to ensure that the suppression pool will provide adequate net positive suction head (NPSH) for the CS subsystem or LPCI subsystem pump, recirculation volume, and vortex prevention.

With the suppression pool water level less than the required limit, the required ECCS injection/spray subsystem is inoperable unless aligned to an OPERABLE CST.

The required CS System is OPERABLE only if it can take suction from the CST, and the CST water level is sufficient to provide the required NPSH for the CS pump. Therefore, a verification that either the suppression pool water level is [12 ft 2 inches] or that a required CS subsystem is aligned to take suction from the CST and the CST contains

[150,000] gallons of water, equivalent to [12] ft, ensures that the CS subsystem can supply at least [50,000] gallons of makeup water to the RPV. The CS suction is uncovered at the [100,000] gallon level.

135,000 available gallons of water, ensures that the CS subsystem can supply the required makeup water to the RPV.

1 3

5 5.0 3

5.0 3

1 3

subsystem

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-9 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

[ The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency of these SRs was developed considering operating experience related to suppression pool water level and CST water level variations. Furthermore, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal suppression pool or CST water level condition.

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.

---

]

SR 3.5.2.4 The ECCS injection/spray subsystem flow path piping and components have the potential to develop voids and pockets of entrained gases.

Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS injection/spray subsystems and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of ECCS injection/spray subsystem locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The ECCS injection/spray subsystem is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible 3

5 2

was have been determined to include the piping from the required ECCS pump discharge valve to the associated injection valve 2

This is verified by venting the piping of the required ECCS injection/spray subsystem at the system high point vents.

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-10 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued) locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If the accumulated gas is eliminated or brought within the acceptance criteria limits during performance of the Surveillance, the Surveillance is met and past system OPERABILITY is evaluated under the Corrective Action Program. If it is determined by subsequent evaluation that the ECCS injection/spray subsystems are not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS injection/spray subsystem locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

[ The 31 day Frequency is based on operating experience, on the procedural controls governing system operation, and on the gradual nature of void buildup in the ECCS piping.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

---

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.

---

]

3 5

2 2

2 2

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-11 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.5 Verifying that the required ECCS injection/spray subsystem can be manually aligned, and the pump started and operated for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This SR is modified by two Notes. Note 1 states that testing the ECCS injection/spray subsystem may be done through the test return line to avoid overfilling the refueling cavity. Note 2 states that credit for meeting the SR may be taken for normal system operation that satisfies the SR, such as using the RHR mode of LPCI for 10 minutes.

The minimum operating time of 10 minutes was based on engineering judgement. [The performance frequency of 92 days is consistent with similar at-power testing required by SR 3.5.1.7.

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.

---

]

SR 3.5.2.6 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

[ The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the

[18] month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

3 5

3

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-12 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

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.

---

]

SR 3.5.2.7 This Surveillance verifies that a required CS subsystem or LPCI subsystem can be manually aligned and started from the control room, including any necessary valve alignment, instrumentation, or controls, to transfer water from the suppression pool or CST to the RPV.

[ The [18] month Frequency is based on the need to perform the Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

Operating experience has shown that these components usually pass the SR when performed at the [18] month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

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.

---

]

3 5

3 5

3

RPV Water Inventory Control B 3.5.2 General Electric BWR/4 STS B 3.5.2-13 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES

1.

Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup,"

November 1984.

2.

Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3.

Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(F)," August 1992.

4.

NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.

5.

Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.

6.

General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6,"

February 1983.

JUSTIFICATION FOR DEVIATIONS ITS 3.5.2 BASES, REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL Hope Creek Page 1 of 1

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2. ISTS SR 3.5.2.4, associated with verifying, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water, is revised in the ITS to maintain the wording in the current Technical Specifications. NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" (ADAMS Accession No. ML072910759), required licensees to submit information, in general, regarding concerns that certain safety systems could accumulate gas pockets that may inhibit system flow or damage system pumps/piping during an event which requires system operation. PSEG provided response to GL 2008-01 related to HCGS management of gas accumulation in letters dated April 10, 2008, October 13, 2008, July 30, 2009, and January 28, 2011 (ADAMS Accession Nos.

ML081130672, ML082970219, ML092230347 and ML110400201, respectively).

The responses included the results of evaluations performed on systems of concern, summary of procedural controls, and description of support features (such as the Emergency Core Cooling System "keep-fill" system). Based on the review of information provided by PSEG, the NRC found the responses acceptable and subsequently closed the GL 2008-01 request for HCGS in letter to T. Joyce (PSEG) from R.B. Ennis (NRC), dated June 2, 2011 (ADAMS Accession No. ML111380081),

with no further information or action required. Therefore, adoption of ISTS SR 3.5.2.4 is not necessary to ensure associated systems are properly maintained in an OPERABLE condition and ITS SR 3.5.2.4 is revised to be consistent with current licensing basis. Changes to the ISTS Bases are made to support the changes to the Specification.

3. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

4. ISTS 3.5.2 Required Actions C.3 and D.4 are modified in the ITS from one Standby Gas Treatment (SGT) subsystem to one Filtration Recirculation and Ventilation System (FRVS) ventilation unit. Conforming changes are made in the ITS Bases to reflect the changes to the Specification.

5. The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.2, REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL Hope Creek Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 3 ITS 3.5.3, RCIC System

Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)

PLANT SYSTEMS 3/4.7.4 REACTOR CORE ISOLATION COOLING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.4 The reactor core isolation cooling (RCIC) system shall be OPERABLE with an OPERABLE flow path capable of automatically taking suction from the suppression pool and transferring the water to the reactor pressure vessel.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3 with reactor steam dome pressure greater than 150 psig.

ACTION:

Note: LCO 3.0.4.b is not applicable to RCIC.

With the RCIC system inoperable, operation may continue provided the HPCI system is OPERABLE; restore the RCIC system to OPERABLE status within 14 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to less than or equal to 150 psig within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.7.4 The RCIC system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by:

1.

Verifying by venting at the high point vents that the system piping from the pump discharge valve to the system isolation valve is filled with water.

2.

Verifying that each valve, manual, power operated or automatic in the flow path that is not locked, sealed or otherwise secured in position, is in its correct position.

3.

Verifying that the pump flow controller is in the correct position.

b.

When tested pursuant to the INSERVICE TESTING PROGRAM by verifying that the RCIC pump develops a flow of greater than or equal to 600 gpm in the test flow path with a system head corresponding to reactor vessel operating pressure when steam is being supplied to the turbine at 1000 + 20, - 80 psig.*

The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure is adequate to perform the test.

HOPE CREEK 3/4 7-11 Amendment No. 205 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND (RCIC) 3.5.3 RCIC System A01 ITS 3.5.3 ITS LCO 3.5.3 LA01 MODES MODE ACTIONS NOTE A03 Verify by administrative means High Pressure Coolant Injection MODE 3 Immediately L02 Req. Action A.1 Req. Action A.2 ACTION B Add Required Action B.1 NOTE L02 LCO 3.5.3 SR 3.5.3.1 SR 3.5.3.2 SR 3.5.3.3 L03 Add SR 3.5.3.2 NOTE LA02 LA02 SR 3.5.3.3 NOTE Not required to be until and flow are and In accordance with LA02 can rate against the RCIC System A02 A04 L04 RCIC System 200 L01 1020 psig and 920 psig of 1000 psig injection

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (continued)

c.

In accordance with the Surveillance Frequency Control Program by:

1.

Performing a system functional test which includes simulated automatic actuation and restart# and verifying that each automatic valve in the flow path actuates to its correct position. Actual injection of coolant into the reactor vessel may be excluded.

2.

Verifying that the system will develop a flow of greater than or equal to 600 gpm in the test flow path when steam is supplied to the turbine at a pressure of 150 + 15, - 0 psig.*

3.

Verifying that the suction for the RCIC system is automatically transferred from the condensate storage tank to the suppression pool on a condensate storage tank water level-low signal.

The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure is adequate to perform the tests.

Automatic restart on a low water level signal which is subsequent to a high water level trip.

HOPE CREEK 3/4 7-12 Amendment No. 187 A01 ITS 3.5.3 ITS LA01 SR 3.5.3.5 SR 3.5.3.4 LA03 SR 3.5.3.5 NOTE Verify the RCIC System actuates on an actual or L05 initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

A05 150 psig and 165 psig against a system head corresponding to a reactor pressure of 150 psig RCIC pump can rate L01 LA02 LA03

DISCUSSION OF CHANGES ITS 3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Hope Creek Page 1 of 7 ADMINISTRATIVE CHANGES A01 In the conversion of the Hope Creek Generating Station (HCGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 5.0, "Standard Technical Specifications-General Electric BWR/4 Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.7.4 Applicability states OPERATIONAL CONDITIONS 1, 2, and 3 with reactor steam dome pressure greater than 150 psig. ITS 3.5.3 Applicability states MODE 1, MODES 2 and 3 with reactor steam dome pressure > 200 psig.

This changes the CTS by incorporating the ITS MODE definition, and by clearly stating the RCIC System is required to be OPERABLE in MODE 1, and MODES 2 and 3 with reactor steam dome pressure > 200 psig. See Discussion of Change (DOC) L01 for the change in reactor steam dome pressure in the Applicability.

The purpose of CTS 3.7.4 Applicability is to establish the Operational Condition (i.e., ITS MODE) in which the LCO is required. This change is acceptable because the Applicability of MODE is not changed. This change is designated as an administrative change and is acceptable because it does not result in a technical change to the CTS.

A03 CTS 3.7.4 Action states, in part, With the RCIC system inoperable, operation may continue provided the HPCI system is OPERABLE. ITS 3.5.3 ACTION A states, in part, with the RCIC System inoperable, immediately verify by administrative means the High Pressure Coolant Injection System is OPERABLE. This changes CTS by clarifying the time to verify the HPCI System is OPERABLE.

The purpose of CTS 3.7.4 Action is to immediately verify the HPCI System is OPERABLE, since an OPERABLE HPCI is required to allow the 14 day completion time to restore the RCIC System to OPERABLE status. If the OPERABILITY of the HPCI System cannot be verified, the unit must be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This change clarifies the intent of the existing action and is acceptable because ITS Section 1.3 defines the Immediately Completion Time as the Required Action be pursued without delay and in a controlled manner. This change is acceptable because the intent of the action is not changed. This change is designated as administrative because it does not result in technical changes to the CTS.

A04 CTS 4.7.4.b (RCIC high pressure flow verification) is modified by footnote

• that states, "The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure is adequate to perform the test." ITS SR 3.5.3.3 does not include this statement in the Surveillance Note. The statement "the provisions of Specification 4.0.4 are not applicable" is not required in the ITS because the current Surveillance Note is specifically designed to allow entry into a Mode of the LCO Applicability before

DISCUSSION OF CHANGES ITS 3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Hope Creek Page 2 of 7 the Surveillance is required if the Surveillance can only be performed in the applicable MODE. Therefore, the additional information related to CTS 4.0.4 (ITS SR 3.0.3) is unnecessary. This change is designated as an administrative change because it does not result in a technical change to the CTS.

A05 CTS 4.7.4.c.1 requires verifying that each automatic valve in the flow path actuates to its correct position. ITS SR 3.5.3.5 requires verifying that the RCIC System actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

This changes the CTS by adding the exception for valves that are locked, sealed, or otherwise secured in the actuated position to the surveillance requirement.

The purpose of CTS 4.7.4.c.1 is to verify the RCIC System actuates on an automatic initiation signal. CTS 4.7.4.c.1 implies that the position of valves is not in the correct (i.e., actuated) position. However, system valves that are locked, sealed, or otherwise secured in the actuated position are in the actuated position and will not change. This change is acceptable because ITS SR 3.5.3.5 retains the requirement to verify the RCIC System actuates on an automatic initiation signal. This change provides additional clarification to the existing requirement and is designated as an administrative change because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.7.4 requires the RCIC system be OPERABLE with an OPERABLE flow path capable of automatically taking suction from the suppression pool and transferring the water to the reactor pressure vessel. CTS Surveillance 4.7.4.c.3 requires verifying that the suction for the RCIC system is automatically transferred from the condensate storage tank to the suppression pool on a condensate storage tank water level-low signal. ITS LCO 3.5.3 requires the RCIC to OPERABLE and ITS SR 3.5.3.5 requires verifying that the RCIC System actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position. ITS Specification 3.5.3 does not include these system design and operational description details. This changes the CTS by moving these system design and operational description details to the ITS Bases.

The removal of these details, which are related to system design and operational description, from the Technical Specifications is acceptable because this type of

DISCUSSION OF CHANGES ITS 3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Hope Creek Page 3 of 7 information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS LCO 3.5.3 continues to require the RCIC System to be OPERABLE and ITS SR 3.5.3.5 retains the requirement to verify proper automatic system actuation. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system operation and design is being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.7.4.a.1 requires verifying that the system piping from the pump discharge valve to the system isolation valve is filled with water by venting at the high point vents. ITS SR 3.5.3.1 also requires verifying the RCIC System piping from the pump discharge valve to the injection (i.e., isolation) valve is filled with water. ITS SR 3.5.3.1 does not include this system operational description detail.

CTS 4.7.4.a.3 requires verifying that the pump flow controller is in the correct position (i.e., correct position of the RCIC steam governor valve). ITS SR 3.5.3.2 requires each RCIC System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position. ITS SR 3.5.3.2 does not include this system operational description detail.

CTS 4.7.4.b and 4.7.4.c.2 require verifying flow in the test flow path." ITS SR 3.5.3.3 and ITS SR 3.5.3.4 require verifying the RCIC pump can develop a required flow rate against a system head corresponding to a specified reactor pressure. ITS SR 3.5.3.3 or SR 3.5.3.4 do not include this system operational description detail.

This changes the CTS by moving these system operational description details to the ITS Bases. The removal of these details, which are related to system operation and design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS SR 3.5.3.1 retains the requirement to verify the RCIC System piping from the pump discharge valve to the injection valve is filled with water. ITS SR 3.5.3.2 retains the requirement to verify each RCIC System manual, power operated, and automatic valve in the flow path is in the correct position, which includes verifying the flow controller position. ITS SR 3.5.3.3 and ITS SR 3.5.3.4 retain the requirement for RCIC pump high pressure flow verification and RCIC pump low pressure flow verification, respectively. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system operation and design is being removed from the Technical Specifications.

DISCUSSION OF CHANGES ITS 3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Hope Creek Page 4 of 7 LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.7.4.c.1 requires performing a system functional test which includes simulated automatic actuation and restart with reference to footnote #.

Footnote # states Automatic restart on a low water level signal which is subsequent to a high water level trip. ITS SR 3.5.3.5 requires verifying that the RCIC System actuates on an actual or simulated automatic initiation signal. ITS SR 3.5.3.5 does not include this detail that RCIC will automatically restart on an reactor pressure vessel (RPV) low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip. This changes the CTS by moving these system operational description details to the ITS Bases.

The removal of these details, which are related to system operation and design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS SR 3.5.3.5 retains the requirement to verify proper automatic system actuation. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system operation and design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 2 - Relaxation of Applicability) CTS 3.7.4 requires the RCIC System to be OPERABLE in OPERATIONAL CONDITIONS 1, 2, and 3 with reactor steam dome pressure greater than 150 psig. In addition, CTS 4.7.4.c.2 (RCIC low pressure flow verification) is modified by footnote

• that states, The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure is adequate to perform the tests.

ITS LCO 3.5.3 requires the RCIC System to be OPERABLE in MODES 1, and MODES 2 and 3 when reactor steam dome pressure is > 200 psig and CTS 4.7.4.c.2 footnote

• note is not included in ITS SR 3.5.3.4 because it is no longer necessary. This changes the CTS by changing the technical specification applicability for when the RCIC System must be OPERABLE and includes deleting an unnecessary note as a result of the applicability change.

The purpose of the CTS Applicability is to ensure reactor steam dome pressure is adequate for the RCIC System to perform its function. Increasing the applicability requirement for the RCIC System does not adversely impact this purpose. The RCIC System is designed to operate following RPV isolation accompanied by a loss of coolant flow from the feedwater system to provide adequate core cooling and control of RPV water level without relying on the Automatic Depressurization System and the low pressure Emergency Core Cooling System (ECCS). Under these conditions, the HPCI and RCIC systems perform similar functions. The function of the RCIC System is to respond to transient events by providing makeup coolant to the reactor. In the event the RCIC System is unable to recover or maintain RPV water level or is unavailable during a design basis accident or transient, the HPCI System and the ADS in

DISCUSSION OF CHANGES ITS 3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Hope Creek Page 5 of 7 conjunction low pressure ECCS are fully capable of mitigating the accident or transient.

The proposed change to the ITS Applicability is necessary to be consistent with the HPCI System Specification applicability requirements, which requires the HPCI System to be OPERABLE in MODES 1, 2, and 3 except then when reactor steam dome pressure is 200 psig. This change meets the intent of the ISTS and the CTS 3.7.4 and ITS 3.5.1 Actions that the Applicability of HPCI and RCIC systems be equivalent. The HPCI System is analyzed (per NEDC-33172P, SAFER/GESTR-LOCA Loss of Coolant Accident Analysis for Hope Creek Generating Station at Power Uprate," March 2005) to begin injection into the RPV above 200 psig. Additionally, small break loss of coolant accidents at low pressures (i.e., between 150 psig and 200 psig) are bounded by analyses performed at higher pressures and low pressure ECCS injection/spray subsystems are assumed to begin injection at pressures higher than 200 psig (286 psid for LPCI and 289 psid for core spray). Therefore, requiring the RCIC System to be OPERABLE between 150 psig and 200 psig serves no safety significant purpose. NEDC-33172P (ADAMS Accession No. ML053250469; not publicly available) was reviewed by the NRC and ECCS performance was determined acceptable for the HCGS extended power uprate as documented in the NRC safety evaluation associated with License Amendment 174, dated May 14, 2008 (NRC ADAMS Accession No. ML081230540).

Additionally, since the RCIC System Applicability is increased from > 150 psig to

> 200 psig, there is no need to provide a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance to perform the RCIC low pressure flow verification (i.e., between 150 psig and 165 psig) as modified by footnote

• to CTS 4.7.4.c.2. Adequate steam pressure and flow to perform the test can be attained prior to when the RCIC System is required to be OPERABLE (i.e., MODE 2 or 3 with reactor steam dome pressure > 200 psig). Therefore, it is unnecessary to include this note in ITS SR 3.5.3.4.

This change is acceptable because the LOCA analyses indicate that low pressure ECCS injection/spray subsystems will begin to inject at pressures greater than 200 psig and the low pressure ECCS is fully capable of restoring and maintaining RPV water level during any accident or transient initiated below 200 psig. As such, there is minimal safety impact associated with the proposed change. The change is designated less restrictive because less stringent Applicability requirements are being applied in the ITS than were applied in the CTS.

L02 (Category 4 - Relaxation of Required Action) CTS 3.7.4 Action requires the plant to be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to 150 psig within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when an inoperable RCIC System cannot be restored to OPERABLE status within 14 days. ITS 3.5.3 ACTION B requires the unit to be placed in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the Required Action and associated Completion Time is not met.

This changes the CTS by changing the end state of the CTS 3.5.3 Action to MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The purpose of the CTS Action is to place the plant in a MODE in which overall plant risk is minimized. This change is acceptable because placing the plant in

DISCUSSION OF CHANGES ITS 3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Hope Creek Page 6 of 7 MODE 3 provides for a similar or lower risk than reducing reactor steam dome pressure to 200 psig, although voluntary reduction of reactor steam dome pressure to 200 psig is acceptable. In addition, remaining in the Applicability of the LCO is acceptable because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. ITS Required Action B.1 is modified by the addition of a Note prohibiting entry into the end state MODE within the Applicability during startup using the provisions of LCO 3.0.4.a to provide assurance that entry into the end state MODE during startup is not made without the appropriate risk assessment. The addition of ITS ACTION B is consistent with Revision 5 of the ISTS as adopted by Technical Specifications Task Force (TSTF) traveler TSTF-423-A, Revision 1, Technical Specification End States, NEDC-32988-A, dated September 16, 2014. (ADAMS Accession No. ML102730688). The TSTF was approved for licensee adoption as documented in Federal Register Notice 76 FR 9614 (ADAMS Accession No. ML102730585). PSEG Nuclear has previously committed to assess and manage risk at HCGS in accordance with the guidance of NUMARC 93-01, Rev. 4F, Section 11 (e.g., Amendment 228 (ADAMS Accession No. ML21098A087)).

PSEG Nuclear will also follow the guidance established in TSTF-IG-05-02, Implementation Guidance for TSTF-423, Rev. 1, Technical Specifications End States, NEDC-32988-A, upon implementation of the end state requirements.

The change is designated less restrictive because a less restrictive action is imposed when the specified Required Action cannot be met.

L03 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS 4.7.4.a.2 states Verify each valve, manual, power operated or automatic in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position. ITS 3.5.3.2 states Verify each RCIC System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position. Additionally, ITS SR 3.5.3.2 is modified by a Note that states Not required to be met for system vent flow paths opened under administrative control. CTS 4.7.4.a.2 does not include this note. This changes the CTS by adding a Note to the valve alignment verification Surveillance allowing vent paths to be open under administrative control.

The purpose of the CTS Surveillance is to ensure the RCIC System valves are in the correct position for system operation. The Note to ITS SR 3.5.3.2 provides a necessary exemption during performance of SR 3.5.3.1, which verifies the RCIC System piping from the pump discharge valve to the injection valve is filled with water. Opening vent flow paths may be needed during performance of this surveillance. The Surveillance Note provides an exception to opening vent flow paths under administrative control. The administrative control will include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

This change is consistent with the ISTS and considered acceptable because the venting evolution is controlled and the administratively controlled actions ensure the vent flow paths are closed in order to maintain system OPERABILITY. This change also considers the low probability of a DBA occurring during this period.

The ITS SR continues to provide assurance that the necessary quality of the

DISCUSSION OF CHANGES ITS 3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Hope Creek Page 7 of 7 RCIC System will be maintained and the limiting condition for operation will be met pursuant to the requirements of 10 CFR 50.36(c)(3). The change is designated less restrictive because an exception is added to the valve alignment surveillance requirement that allows opening RCIC System vent flow paths under administrative control.

L04 (Category 7 - Relaxation of Surveillance Frequency Change) CTS 4.7.4 b (RCIC high pressure flow verification) is modified by footnote

• allowing performance of the Surveillance to be deferred until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure" is adequate to perform the surveillance. ITS SR 3.5.3.3 is modified by a similar Note that allows deferring the performance of these tests until reactor steam pressure "and flow" are adequate to perform the test. This changes the CTS by modifying the time to perform the RCIC flow verification test unit pressure and flow are adequate to perform the test.

The purpose of the current Note is to establish appropriate conditions for testing.

This change is necessary because the CTS allowance to reach the required reactor steam pressure only partially addresses the issue of adequate test conditions. Requiring performance of these tests before adequate steam flow can be maintained creates the potential for an undesired reactor depressurization.

This change is less restrictive because it allows additional time before the surveillances are required to be performed. This change is acceptable because the allowance permits the surveillance to be delayed until appropriate conditions are established, and this change will not result in any significant delay in the performance of the surveillance.

L05 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS 4.7.4.c.1 states, in part, perform a RCIC system functional test which includes simulated automatic actuation. ITS SR 3.5.3.5 states, in part, verify the RCIC System actuates on an actual or simulated automatic initiation signal. This changes the CTS by allowing satisfactory actual automatic RCIC system initiation to be used to fulfill the RCIC system functional surveillance requirement. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the tests.

The purpose of CTS 4.7.4.c.1 is to ensure the RCIC system actuates on a simulated automatic initiation signal. This change is acceptable because it has been determined that the current Surveillance Requirement acceptance criteria are not the only method that can be used for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual" or "simulated" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements. The change also allows a simulated signal to be used, if necessary. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

RCIC System 3.5.3 General Electric BWR/4 STS 3.5.3-1 Rev. 5.0 CTS Hope Creek Amendment XXX 1

3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 with reactor steam dome pressure > [150] psig.

ACTIONS

---

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

LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System inoperable.

A.1 Verify by administrative means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System to OPERABLE status.

Immediately 14 days

[OR In accordance with the Risk Informed Completion Time Program]

B. Required Action and associated Completion Time not met.

B.1

---

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 3.7.4 Applicability DOC L01 Action Note Action (part 1)

Action (part 3)

Action (part 2)

DOC L02 2

3.7.4 2

200 3

RCIC System 3.5.3 General Electric BWR/4 STS 3.5.3-2 Rev. 5.0 CTS Hope Creek Amendment XXX 1

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System locations susceptible to gas accumulation are sufficiently filled with water.

[ 31 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.5.3.2

---

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

Not required to be met for system vent flow paths opened under administrative control.

Verify each RCIC System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

[ 31 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.5.3.3

---

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

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with [reactor pressure] [1020] psig and

[920] psig, the RCIC pump can develop a flow rate

[400] gpm [against a system head corresponding to reactor pressure].

[ 92 days OR In accordance with the Surveillance Frequency Control Program ]

2 2

2 2

2 DOC L03 4.7.4.a.2 4.7.4.b Footnote

• DOC L04 4.7.4.a.1 600 INSERVICE TESTING PROGRAM of 1000 psig turbine inlet a

4 piping from the pump discharge valve to the injection valve is

RCIC System 3.5.3 General Electric BWR/4 STS 3.5.3-3 Rev. 5.0 CTS Hope Creek Amendment XXX 1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.3.4

---

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

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with [reactor pressure] [165] psig, the RCIC pump can develop a flow rate [400] gpm [against a system head corresponding to reactor pressure].

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

SR 3.5.3.5

---

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

Vessel injection may be excluded.

Verify the RCIC System actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

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

4.7.4.c.2 DOC L01 4.7.4.c.1 DOC L05 2

2 2

2 600 3

3 of 150 psig turbine inlet and 150 psig a

JUSTIFICATION FOR DEVIATIONS ITS 3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Hope Creek Page 1 of 2

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

3. The reactor steam dome pressure in the Applicability for ITS 3.5.3 is revised to 200 psig to be consistent with Applicability of the HPCI System specified in ITS 3.5.1. This change meets the intent of the ISTS and the CTS and ITS ACTION requirements that the Applicability of HPCI and RCIC systems be equivalent.

Additionally, since the RCIC System Applicability is increased from > 150 psig to

> 200 psig, there is no need to provide a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance to perform the RCIC low pressure flow verification (i.e., between 150 psig and 165 psig). Adequate steam pressure and flow to perform the test can be attained prior to when the RCIC System is required to be OPERABLE (i.e., MODE 2 or 3 with reactor steam dome pressure > 200 psig). Therefore, it is unnecessary to include this note in ITS SR 3.5.3.4. Since the reactor steam dome pressure is increased in the Applicability, no longer representing the minimum pressure to perform the RCIC pump low pressure flow test, the minimum pressure of the low pressure test is added to ITS SR 3.5.3.4.

4. ISTS SR 3.5.3.1, associated with verifying RCIC System locations susceptible to gas accumulation are sufficiently filled with water, is revised in the ITS to maintain the wording in the current Technical Specifications. NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" (ADAMS Accession No. ML072910759), required licensees to submit information, in general, regarding concerns that certain safety systems could accumulate gas pockets that may inhibit system flow or damage system pumps/piping during an event which requires system operation. PSEG provided response to GL 2008-01 related to Hope Creek Generating Station (HCGS) management of gas accumulation in letters dated April 10, 2008, October 13, 2008, July 30, 2009, and January 28, 2011 (ADAMS Accession Nos. ML081130672, ML082970219, ML092230347 and ML110400201, respectively). The responses included the results of evaluations performed on systems of concern, summary of procedural controls, and description of support features (such as the Emergency Core Cooling System "keep-fill" system). Based on the review of information provided by PSEG, the NRC found the responses acceptable and subsequently closed the GL 2008-01 request for HCGS in letter to T. Joyce (PSEG) from R.B. Ennis (NRC), dated June 2, 2011 (ADAMS Accession No. ML111380081), with no further information or action required.

SRs associated with verifying certain systems remain full of water were adopted in the ISTS following NRC approval of Technical Specification Task Force (TSTF) traveler TSTF-523-A, "Generic Letter 2008-01, Managing Gas Accumulation,"

Revision 2, dated January 15, 2014 (79 FR 2700). PSEG subsequently performed an evaluation and determined that adoption of TSTF-523 was not necessary based on established controls and support features previously determined acceptable by the NRC. Based on the considerations provided herein, ISTS SR 3.5.3.1 is not

JUSTIFICATION FOR DEVIATIONS ITS 3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Hope Creek Page 2 of 2 necessary to ensure associated systems are properly maintained in an OPERABLE condition and ITS SR 3.5.3.1 is revised to be consistent with current licensing basis.

Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

RCIC System B 3.5.3 General Electric BWR/4 STS B 3.5.3-1 Rev. 5.0 Hope Creek Revision XXX 1

B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.3 RCIC System BASES BACKGROUND The RCIC System is not part of the ECCS; however, the RCIC System is included with the ECCS section because of their similar functions.

The RCIC System is designed to operate either automatically or manually following reactor pressure vessel (RPV) isolation accompanied by a loss of coolant flow from the feedwater system to provide adequate core cooling and control of the RPV water level. Under these conditions, the High Pressure Coolant Injection (HPCI) and RCIC systems perform similar functions. The RCIC System design requirements ensure that the criteria of Reference 1 are satisfied.

The RCIC System (Ref. 2) consists of a steam driven turbine pump unit, piping, and valves to provide steam to the turbine, as well as piping and valves to transfer water from the suction source to the core via the feedwater system line, where the coolant is distributed within the RPV through the feedwater sparger. Suction piping is provided from the condensate storage tank (CST) and the suppression pool. Pump suction is normally aligned to the CST to minimize injection of suppression pool water into the RPV. However, if the CST water supply is low, or the suppression pool level is high, an automatic transfer to the suppression pool water source ensures a water supply for continuous operation of the RCIC System. The steam supply to the turbine is piped from a main steam line upstream of the associated inboard main steam line isolation valve.

The RCIC System is designed to provide core cooling for a wide range of reactor pressures [165 psig to 1155 psig]. Upon receipt of an initiation signal, the RCIC turbine accelerates to a specified speed. As the RCIC flow increases, the turbine control valve is automatically adjusted to maintain design flow. Exhaust steam from the RCIC turbine is discharged to the suppression pool. A full flow test line is provided to route water from and to the CST to allow testing of the RCIC System during normal operation without injecting water into the RPV.

The RCIC pump is provided with a minimum flow bypass line, which discharges to the suppression pool. The valve in this line automatically open to prevent pump damage due to overheating when other discharge line valves are closed. To ensure rapid delivery of water to the RPV and to minimize water hammer effects, the RCIC System discharge piping is kept full of water. The RCIC System is normally aligned to the CST. The height of water in the CST is sufficient to maintain the piping full of water 2

1156

(

)

1 minimum flow valves automatically open to prevent overheating the RCIC pump recirculation The RCIC pump and turbine are located below the water level of the CST and suppression pool.

1 1

without relying on the Automatic Depressurization System (ADS) and the low pressure ECCS 1

RCIC System B 3.5.3 General Electric BWR/4 STS B 3.5.3-2 Rev. 5.0 Hope Creek Revision XXX 1

BASES BACKGROUND (continued) up to the first isolation valve. The relative height of the feedwater line connection for RCIC is such that the water in the feedwater lines keeps the remaining portion of the RCIC discharge line full of water. Therefore, RCIC does not require a "keep fill" system.

APPLICABLE The function of the RCIC System is to respond to transient events by SAFETY providing makeup coolant to the reactor. The RCIC System is not an ANALYSES Engineered Safety Feature System and no credit is taken in the safety analyses for RCIC System operation. The RCIC System satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO The OPERABILITY of the RCIC System provides adequate core cooling such that actuation of any of the low pressure ECCS subsystems is not required in the event of RPV isolation accompanied by a loss of feedwater flow. The RCIC System has sufficient capacity for maintaining RPV inventory during an isolation event. Management of gas voids is important to RCIC System OPERABILITY.

APPLICABILITY The RCIC System is required to be OPERABLE during MODE 1, and MODES 2 and 3 with reactor steam dome pressure > 150 psig, since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized. In MODES 2 and 3 with reactor steam dome pressure 150 psig, the low pressure ECCS injection/spray subsystems can provide sufficient flow to the RPV. In MODES 4 and 5, RCIC is not required to be OPERABLE since RPV water inventory control is required by LCO 3.5.2, "RPV Water Level Inventory Control."

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC System. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC System and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 and A.2 If the RCIC System is inoperable during MODE 1, or MODE 2 or 3 with reactor steam dome pressure > [150] psig, and the HPCI System is verified to be OPERABLE, the RCIC System must be restored to OPERABLE status within 14 days [or in accordance with the Risk Informed Completion Time Program]. In this Condition, loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at high reactor pressure since the HPCI System is the only high 2

2 200 200 200 1

1 The RCIC jockey pump maintains RCIC discharge piping full of water to help prevent water hammer from occurring during RCIC System startup.

1 5

5 5

1 1

credited in the safety analyses for transients that result in loss of normal feedwater to the RPV. In the event the RCIC System is unable to recover or maintain RPV water level or is unavailable during a design basis accident or transient, the HPCI System and the ADS in conjunction low pressure ECCS are fully capable of mitigating the accident or transient 3

1

RCIC System B 3.5.3 General Electric BWR/4 STS B 3.5.3-3 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued) pressure system assumed to function during a loss of coolant accident (LOCA). OPERABILITY of HPCI is therefore verified immediately when the RCIC System is inoperable. This may be performed as an administrative check, by examining logs or other information, to determine if HPCI is out of service for maintenance or other reasons. It does not mean it is necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the HPCI System. If the OPERABILITY of the HPCI System cannot be verified, however, Condition B must be immediately entered. For transients and certain abnormal events with no LOCA, RCIC (as opposed to HPCI) is the preferred source of makeup coolant because of its relatively small capacity, which allows easier control of the RPV water level. Therefore, a limited time is allowed to restore the inoperable RCIC to OPERABLE status.

The 14 day Completion Time is based on a reliability study (Ref. 3) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (AOTs). Because of similar functions of HPCI and RCIC, the AOTs (i.e.,

Completion Times) determined for HPCI are also applied to RCIC.

B.1

---

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

Adoption of a MODE 3 end state requires the licensee to make the following commitments:

1.

[LICENSEE] will follow the guidance established in Section 11 of NUMARC 93-01, "Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Nuclear Management and Resource Council, Revision [4F].

2.

[LICENSEE] will follow the guidance established in TSTF-IG-05-02, Implementation Guidance for TSTF-423, Revision 2, "Technical Specifications End States, NEDC-32988-A," November 2009.

If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

4

RCIC System B 3.5.3 General Electric BWR/4 STS B 3.5.3-4 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued)

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 4) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 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 3, 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 Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.5.3.1 REQUIREMENTS The RCIC System flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RCIC System and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RCIC System locations susceptible to gas accumulation is based on a self-assessment of the piping configuration to identify where gases may accumulate and remain even after the system is filled and vented, and to identify vulnerable potential degassing flow paths. The review is supplemented by verification that installed high-point vents are actually at the system high points, including field verification to ensure pipe shapes and construction tolerances have not inadvertently created additional high points. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

was have been determined to include the piping from the RCIC System pump discharge valve to the injection valve 6

6 6

RCIC System B 3.5.3 General Electric BWR/4 STS B 3.5.3-5 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

The RCIC System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump),

the Surveillance is not met. If the accumulated gas is eliminated or brought within the acceptance criteria limits during performance of the Surveillance, the Surveillance is met and past system OPERABILITY is evaluated under the Corrective Action Program. If it is determined by subsequent evaluation that the RCIC System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RCIC System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

[ The 31 day Frequency is based on the gradual nature of void buildup in the RCIC piping, the procedural controls governing system operation, and operating experience.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

2 6

6 This is verified by venting the RCIC System piping at the system high point vents.

6 6

RCIC System B 3.5.3 General Electric BWR/4 STS B 3.5.3-6 Rev. 5.0 Hope Creek Revision XXX 1

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.

---

]

SR 3.5.3.2 Verifying the correct alignment for manual, power operated, and automatic valves in the RCIC flow path provides assurance that the proper flow path will exist for RCIC operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. For the RCIC System, this SR also includes the steam flow path for the turbine and the flow controller position.

[ The 31 day Frequency of this SR was derived from the INSERVICE TESTING PROGRAM requirements for performing valve testing at least once every 92 days. The Frequency of 31 days is further justified because the valves are operated under procedural control and because improper valve position would affect only the RCIC System. This Frequency has been shown to be acceptable through operating experience.

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.

---

]

3 2

3

RCIC System B 3.5.3 General Electric BWR/4 STS B 3.5.3-7 Rev. 5.0 Hope Creek Revision XXX 1

low pressure RCIC pump flow test is performed during the reactor startup prior to exceeding 200 psig. Reactor BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

SR 3.5.3.3 and SR 3.5.3.4 The RCIC pump flow rates ensure that the system can maintain reactor coolant inventory during pressurized conditions with the RPV isolated.

The flow tests for the RCIC System are performed at two different pressure ranges such that system capability to provide rated flow is tested both at the higher and lower operating ranges of the system.

Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the RCIC System diverts steam flow. Reactor steam pressure must be [920] psig to perform SR 3.5.3.3 and [150] psig to perform SR 3.5.3.4. Adequate steam flow is represented by [at least 1.25 turbine bypass valves open, or total steam flow 106 lb/hr]. Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these SRs. Reactor startup is allowed prior to performing the low pressure Surveillance because the reactor pressure is low and the time allowed to satisfactorily perform the Surveillance is short. The reactor pressure is allowed to be increased to normal operating pressure since it is assumed that the low pressure Surveillance has been satisfactorily completed and there is no indication or reason to believe that RCIC is inoperable. Therefore, these SRs are modified by Notes that state the Surveillances are not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the reactor steam pressure and flow are adequate to perform the test.

[ A 92 day Frequency for SR 3.5.3.3 is consistent with the INSERVICE TESTING PROGRAM requirements. The 18 month Frequency for SR 3.5.3.4 is based on the need to perform the Surveillance under conditions that apply just prior to or during a startup from a plant outage.

Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

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

2 2

The SR 3.5.3.3 Surveillance Frequency is controlled under the INSERVICE TESTING PROGRAM, SR 3.5.3.4 1

1 high 5

5 SR 3.5.3.3 is modified by a Note that states 5

is 1

SR 3.5.3.3 1

2 one

RCIC System B 3.5.3 General Electric BWR/4 STS B 3.5.3-8 Rev. 5.0 Hope Creek Revision XXX 1

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.

---

]

SR 3.5.3.5 The RCIC System is required to actuate automatically in order to verify its design function satisfactorily. This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of the RCIC System will cause the system to operate as designed, including actuation of the system throughout its emergency operating sequence; that is, automatic pump startup and actuation of all automatic valves to their required positions. This test also ensures the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool. The SR excludes automatic valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to valves that are locked, sealed, or otherwise secured in the actuated position since the affected valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured.

Placing an automatic valve in a locked, sealed, or otherwise secured position requires an assessment of the OPERABILITY of the system or any supported systems, including whether it is necessary for the valve to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve to the non-actuated position requires verification that the SR has been met within its required Frequency. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.3 overlaps this Surveillance to provide complete testing of the assumed safety function.

[ The 18 month Frequency is based on the need to perform the Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

OR 2

3

RCIC System B 3.5.3 General Electric BWR/4 STS B 3.5.3-9 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

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.

---

]

This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES

1.

10 CFR 50, Appendix A, GDC 33.

2.

FSAR, Section [5.5.6].

3.

Memorandum from R.L. Baer (NRC) to V. Stello, Jr. (NRC),

"Recommended Interim Revisions to LCOs for ECCS Components,"

December 1, 1975.

4.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

2 7.4.1.1 U

3 1

JUSTIFICATION FOR DEVIATIONS ITS 3.5.3 BASES, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Hope Creek Page 1 of 2

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

3. The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

4. Hope Creek is adopting TSTF-423-A, Technical Specification End States, consistent with ISTS 3.5.3 ACTION B. The addition of ITS ACTION B is consistent with Revision 5 of the ISTS as adopted by Technical Specifications Task Force (TSTF) traveler TSTF-423-A, Revision 1, Technical Specification End States, NEDC-32988-A, dated September 16, 2014. (ADAMS Accession No. ML102730688). The TSTF was approved for licensee adoption as documented in Federal Register Notice 76 FR 9614 (ADAMS Accession No. ML102730585). PSEG Nuclear has previously committed to assess and manage risk at HCGS in accordance with the guidance of NUMARC 93-01, Rev. 4F, Section 11 (e.g., Amendment 228 (ADAMS Accession No. ML21098A087)).

PSEG Nuclear will also follow the guidance established in TSTF-IG-05-02, Implementation Guidance for TSTF-423, Rev. 1, Technical Specifications End States, NEDC-32988-A, upon implementation of the end state requirements.

5. The reactor steam dome pressure in the Applicability for ITS 3.5.3 is revised to 200 psig to be consistent with Applicability of the HPCI System specified in ITS 3.5.1. As a result, adequate steam pressure and flow to perform the test can be attained prior to when the RCIC System is required to be OPERABLE (i.e.,

MODE 2 or 3 with reactor steam dome pressure > 200 psig). Therefore, it is unnecessary to include this note in ITS SR 3.5.3.4. The ITS Bases is revised to reflect the changes to the Specification.

6. ISTS SR 3.5.3.1, associated with verifying RCIC System locations susceptible to gas accumulation are sufficiently filled with water, is revised in the ITS to maintain the wording in the current Technical Specifications. PSEG provided response to NRC Generic Letter (GL) 2008-01 related to Hope Creek Generating Station (HCGS) management of gas accumulation in letters dated April 10, 2008, October 13, 2008, July 30, 2009, and January 28, 2011 (ADAMS Accession Nos.

ML081130672, ML082970219, ML092230347 and ML110400201, respectively).

The responses included the results of evaluations performed on systems of concern, summary of procedural controls, and description of support features (such as the Emergency Core Cooling System "keep-fill" system). Based on the review of information provided by PSEG, the NRC found the responses acceptable and subsequently closed the GL 2008-01 request for HCGS in letter to T. Joyce (PSEG) from R.B. Ennis (NRC), dated June 2, 2011 (ADAMS Accession No. ML111380081), with no further information or action required.

Therefore, adoption of ISTS SR 3.5.3.1 is not necessary to ensure associated systems are properly maintained in an OPERABLE condition and ITS SR 3.5.3.1

JUSTIFICATION FOR DEVIATIONS ITS 3.5.3 BASES, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Hope Creek Page 2 of 2 is revised to be consistent with current licensing basis. Changes to the ISTS Bases are made to support the changes to the Specification.

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM Hope Creek Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.