NMP1L3584, License Amendment Request to Revise Technical Specifications to Adopt TSTF-230, Revision 1, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling

License Amendment Request to Revise Technical Specifications to Adopt TSTF-230, Revision 1, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling

ML24165A223
Person / Time
Site:	Nine Mile Point
Issue date:	06/13/2024
From:	David Gudger Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NMP1L3584
Download: ML24165A223 (1)

Text

200 Exelon Way Kennett Square, PA 19348

www.constellation.com

10 CFR 50.90 NMP1L3584

June 13, 2024

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 NRC Docket No. 50-220

Subject:

License Amendment Request to Revise Technical Specifications to Adopt TSTF-230, Revision 1, "Add New Condition B to LCO 3.6.2.3, 'RHR Suppression Pool Cooling.' "

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License Amendment Request Adopt TSTF-230, Revision 1 Docket No. 50-2 20 June 13, 2024 Page 2

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

paragraph (a)(1), the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission.

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

paragraph (b), CEG is notifying the State of New York of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Officials.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this submittal, please contact Ron Reynolds at 267-533-5698.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 13 th day of June 2024.

Respectfully,

David T. Gudger Senior Manager - Licensing Constellation Energy Generation, LLC

Attachments:

1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Ups)

3. Proposed Technical Specification Bases Changes (Mark-Ups)

(For Information Only)

cc: USNRC Region I, Regional Administrator w/ attachments USNRC Project Manager, NMP "

USNRC Senior Resident Inspector, NMP "

A. L. Peterson, NYSERDA "

B. Frymire, NYSPSC "

C. Chapin, NYSPSC "

ATTACHMENT 1 Description and Assessment

1.0

SUMMARY

DESCRIPTION

2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

4.2 Precedent

4.3 No Significant Hazards Consideration

4.4 Conclusions

6.0 REFERENCES

License Amendment Request Attachment 1 Adopt TSTF-230, Revision 1 Description and Assessment Docket No. 50-220 Page 1 of 6

1.0

SUMMARY

DESCRIPTION

Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit, or early site permit," Constellation Energy Generation, LLC (CEG), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-63 for Nine Mile Point Nuclear Station, Unit 1 (NMP1).

The proposed change meets the intent of NRC-approved Technical Specification Task Force (TSTF) Traveler 230, Revision 1, "Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling" (Reference 1). This TSTF modifies improved Technical Specifications (ITS) 3.6.2.3, "Residual Heat Removal (RHR) Suppression Pool Cooling," to allow two RHR suppression pool cooling subsystems to be inoperable for eight hours. NMP1 does not have ITS; therefore, the applicable Limiting Condition for Operation (LCO) for NMP1 is Specification 3.3.7, Containment Spray System. The difference in the NMP1 TS 3.3.7 to ITS 3.6.2.3 is described as a variation to TSTF-230, Revision 1, in Section 2.1 below.

2.0 DETAILED DESCRIPTION

NMP1 TS LCO 3.3.7, Containment Spray System (CSS), currently requires each of the two independent CSS to be operable. Specification 3.3.7.e states that if both CSSs become inoperable the reactor shall be in the cold shutdown condition within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. The proposed change will revise Specification 3.3.7.e to state that if both containment spray systems become inoperable, or if one containment spray system and one subsystem in the opposite loop become inoperable, the reactor may remain in operation for a period not to exceed 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Also, a new Specification 3.3.7.f will be added that will direct operators to place the unit in Shutdown Condition-Hot within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Shutdown Conditi on-Cold in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if applicable specifications are not met. In addition, Specification 3.3.7.a will be revised for clarity. See for NMP1 TS markups.

2.1 Optional Changes and Variations

The proposed amendment meets the intent of the ITS changes described in TSTF-230, Revision 1. The changes provided in TSTF-230, Revision 1, are based on NUREG-1433, "Standard Technical Specifications General Electric BWR/4 Plants," or NUREG-1434, "Standard Technical Specifications General Electric BWR/6 Plants." NMP1 is a BWR/2 design. Based on plant design, system descriptions, and formatting of the NMP1 TS, very little is the same as the ITS described in TSTF-230, Revision 1. Therefore, CEG proposes variations or deviations from TSTF-230, Revision 1, as identified below.

1. The NMP1 Reactor Operating Conditions are different than the ITS. The ITS terminology of Modes is not used in the NMP1 TS. The table below compares the technical variation of ITS and NMP1 Reactor Operating Conditions.

License Amendment Request Attachment 1 Adopt TSTF-230, Revision 1 Description and Assessment Docket No. 50-220 Page 2 of 6

ITS Mode NMP1 TS Reactor Operating Condition 1 - Power Operation Power Operating Condition 2 - Startup 3 - Hot Shutdown (>200F) Shutdown Condition - Hot (>212F) 4 - Cold Shutdown (200F) Shutdown Condition - Cold (212F) 5 - Refueling Refueling Condition No Mode Major Maintenance Condition (defueled)

2. NMP1 TS do not have ITS LCO 3.6.2.3, RHR Suppression Pool Cooling, specification.

Instead, NMP1 TS uses a Containment Spray System (CSS) for suppression pool (torus) cooling. The NMP1 TS LCO for CSS is 3.3.7. The CSS function provides the same as the RHR system in that it is designed to prevent overheating and over pressurization of the containment, reduce drywell airborne fission product concentrations, and control the pressure suppression chamber water temperature following a design basis LOCA. The system is designed to provide heat removal capabilities for vessel leaks up to and including the Design Basis Accident (DBA), the double-ended break of a reactor recirculation line, without core spray system operation.

Although this is a technical variation from TSTF-230, Revision 1, the intent of the proposed change applies to the NMP1 TS and is acceptable.

3. NMP1 LCO 3.3.7, Specification e, currently states, in part, "If both containment spray systems become inoperable the reactor shall be in the cold shutdown condition within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />." TSTF-230, Revision 1, adds ITS LCO 3.6.2.3, Condition B, Two RHR suppression pool cooling subsystems inoperable, with a Required Action to restore one RHR suppression pool cooling subsystem to operable status in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. In addition, the TSTF revised Condition C to state, if Required Action and associated Completion Time is not met to be in MODE 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. NMP1s intention is to adopt TSTF-230, Revision 1, as it pertains to the NMP1 CSS design. The NMP1 CSS design includes two loops with each loop containing two suction headers, two containment spray pumps, two heat exchangers and the associated containment spray raw water pumps, a common test return line, and associated piping and control valves.

All four containment spray pumps are cross connected and any two provide sufficient capability to remove heat, reduce pressure, and restore the containment pressure suppression system temperature following a LOCA. Therefore, the current NMP1, Specification e, will be separated into two Specifications. Specification e will be revised to state, "If both containment spray systems become inoperable, or if one containment spray system and one subsystem in the opposite loop become inoperable, the reactor may remain in operation for a period not to exceed 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. A new Specification f will be created to allow for the plant to be in Shutdown Condition-Hot within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Shutdown Condition -Cold within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if Specifications a, b, c, d, or e, are not met.

Specification f follows the plant shutdown sequence outlined in TSTF-203, Revision 1, Condition C. In addition, Specification 3.3.7.a will be revised to clarify exceptions.

Although this proposed change is a technical variation from TSTF-230, Revision 1, it is following the current ITS methodology and applying it to the NMP1 CSS design while maintaining the NMP1 TS format. Therefore, this change is applicable to the NMP1 TS.

License Amendment Request Attachment 1 Adopt TSTF-230, Revision 1 Description and Assessment Docket No. 50-220 Page 3 of 6

CEG has reviewed the above variations and determined that they do not affect the applicability of TSTF-230, Revision 1, to the NMP1 TS.

3.0 TECHNICAL EVALUATION

Two redundant CSS loops are provided to remove heat, reduce pressure, and restore the containment pressure suppression system temperature following a LOCA. Each loop is capable of removing all the decay heat and, in addition, the energy from any credible metal-water reaction at a rate that will prevent containment pressures and temperatures from exceeding their design values. The primary loop (Loop 11) provides water to the primary or inner drywell sparger and to the torus sparger. The secondary loop (Loop 12) provides water to the secondary or outer drywell sparger and to the torus sparger. The torus sparger is common to both loops. Each of the two loops are cross connected through the test return lines such that each of the loops can provide flow to both the primary and secondary spargers. Each loop includes two redundant trains and consists of two suction headers, two containment spray pumps, two heat exchangers and the associated containment spray raw water pumps, a common test return line, and associated piping and control valves. All pumps in a loop are powered from the same emergency power bus. Each loop is electrically independent from the other loop. System initiation is by two reactor protection system signals: low-low water level in the reactor and high drywell pressure. The containment spray raw water pumps must be manually initiated following automatic initiation of the containment spray pumps.

Currently, NMP1 TS 3.3.7.e requires the unit to be in Shutdown Condition-Cold within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> in the event both CSS become inoperable. The proposed change would allow 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore one CSS to operable status before initiating a unit shutdown. The proposed 8-hour limit is considered appropriate since an immediate plant shutdown, which is currently required, has the potential to result in a unit scram and discharge of steam to the Torus. With both CSS inoperable, there would be no available means to remove heat from the Torus. The 8-hour limit provides time to restore one of the CSS prior to requiring the unit to shut down yet is short enough that it does not significantly increase the time that the systems would be unavailable in the event of an accident. In addition, a new Specification (Specification f) was created to adopt the shutdown Required Actions currently in ITS LCO 3.6.2.3, Condition B, and as revised in TSTF-230, Revision 1 (see Section 2.1, Variation 3, for justification).

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements/Criteria

• Criterion 38, Containment Heat Removal

• 10 CFR 50.36, Technical Specifications CEG has determined that the proposed amendment is consistent with the regulatory requirements and criteria described in the above cited documents.

4.2 Precedent

An example of a plant-specific NRC approval of the changes in TSTF-230, Revision 1, is Clinton Power Station, Unit 1, Amendment No. 247, dated November 10, 2022 (Reference 2).

License Amendment Request Attachment 1 Adopt TSTF-230, Revision 1 Description and Assessment Docket No. 50-220 Page 4 of 6

4.3 No Significant Hazards Consideration Determination

Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit, or early site permit, " Constellation Energy Generation, LLC (CEG), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-63 for Nine Mile Point Nuclear Station, Unit 1 (NMP1). The proposed change meets the intent of NRC-approved Technical Specification Task Force (TSTF) Traveler 230, Revision 1, "Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling." This TSTF modifies improved Standard Technical Specifications (ITS) 3.6.2.3, "Residual Heat Removal (RHR) Suppression Pool Cooling," to allow two RHR suppression pool cooling subsystems to be inoperable for eight hours. NMP1 does not have ITS; therefore, the applicable LCO for NMP1 is Specification 3.3.7, Containment Spray System.

According to 10 CFR 50.92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or consequences of any accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

Constellation Energy Generation, LLC (CEG), has evaluated the proposed changes to the TS using the criteria in 10 CFR 50.92 and has determined that the proposed change s do not involve a significant hazards consideration.

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes relax the Specifications of LCO 3.3.7 by allowing 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore one Containment Spray System (CSS) to operable status when both systems have been determined to be inoperable. The Specifications and associated Completion Times are not initiating conditions for any accident previously evaluated. The proposed 8-hour Completion Time provides time to restore required system(s) to operable status is short enough that operating an additional 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is not a significant risk. The Required Actions in the proposed changes have been developed to provide assurance that appropriate remedial actions are taken in response to the degraded condition, considering the operability status of the CSS and the capability of minimizing the risk associated with continued operation. As a result, neither the probability nor the consequences of any accident previously evaluated are significantly increased.

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

License Amendment Request Attachment 1 Adopt TSTF-230, Revision 1 Description and Assessment Docket No. 50-220 Page 5 of 6

2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes do not change the design, configuration, or method of operation of the plant. The proposed changes do not involve a physical alteration of the plant (no new or different kind of equipment will be installed).

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

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No.

The relaxed Specification does not involve a significant reduction in a margin of safety.

The proposed changes have been evaluated to minimize the risk of continued operation with both CSS inoperable. The operability status of the CSS, a reasonable time for repair or replacement of required features, and the low probability of a design basis accident occurring during the repair period have been considered in the evaluation.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

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

4.4 Conclusions

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

5.0 ENVIRONMENTAL EVALUATION

CEG has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation." However, the proposed changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.

License Amendment Request Attachment 1 Adopt TSTF-230, Revision 1 Description and Assessment Docket No. 50-220 Page 6 of 6

6.0 REFERENCES

6.1 TSTF-230, Revision 1, "Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling" (ADAMS Accession No. ML040570110) 6.2 Clinton Power Station, Unit 1 - "Issuance of Amendment No. 247 RE: Adoption of TSTF-230, Revision 1," dated November 10, 2022 (ADAMS Accession No. ML22263A473)

ATTACHMENT 2

License Amendment Request

Nine Mile Point Nuclear Station, Unit 1 Docket No. 50-220

Adopt TSTF -230, Revision 1, "Add New Condition B to LCO 3.6.2.3, 'RHR Suppression Pool Cooling.'"

Proposed Technical Specification Changes (Mark-Ups)

TS Pages

159 160 161

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 4.3.7 CONTAINMENT SPRAY SYSTEM 3.3.7 CONTAINMENT SPRAY SYSTEM Applicability:

Applicability:

Applies to the testing of the containment spray Applies to the operating status of the containment system.

spray system.

Objective:

Objective:

To verify the operability of the containment spray To assure the capability of the containment spray system.

system to limit containment pressure and temperature in the event of a loss-of-coolant accident. Specification:

Specification: The containment spray system surveillance shall be performed as indicated below:

a. During all reactor operating conditions whenever reactor coolant temperature is greater than a. Containment Spray Pumps 215F and fuel is in the reactor vessel and primary containment integrity is required; each of (1) In accordance with the Surveillance the two containment spray systems and the Frequency Control Program, automatic associated raw water cooling systems shall be startup of the containment spray pump shall operable except as specified in 3.3.7.b. be demonstrated.

b. If a redundant component of a containment spray (2) In accordance with the Surveillance system becomes inoperable, Specification Frequency Control Program, pump 3.3.7.a shall be considered fulfilled, provided that operability shall be checked.

the component is returned to an operable condition within 15 days or in accordance with b. Nozzles the Risk Informed Completion Time Program and that the additional surveillance required is Following maintenance that could result in nozzle performed. blockage, a test shall be performed on the spray nozzles.

AMENDMENT NO. 142, 170, 208, 222, 250 159

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT

c. If a redundant component in each of the containment c. Raw Water Cooling Pumps spray systems or their associated raw water systems become inoperable, both systems shall be In accordance with the Surveillance Frequency considered operable provided that the component is Control Program, manual startup and operability returned to an operable condition within 7 days or in of the raw water cooling pumps shall be accordance with the Risk Informed Completion Time demonstrated.

Program and that the additional surveillance required is performed. d. Surveillance with Inoperable Components

d. If a containment spray system or its associated raw When a component or system becomes water system becomes inoperable and all the inoperable its redundant component or system components are operable in the other systems, the shall be verified to be operable immediately and in reactor may remain in operation for a period not to accordance with the Surveillance Frequency exceed 7 days or in accordance with the Risk Control Program thereafter.

Informed Completion Time Program.

e. If Specifications "a" or "b" are not met, shutdown shall begin within one hour and the reactor coolant shall be below 215F within ten hours.

If both containment spray systems become inoperable the reactor shall be in the cold shutdown condition within ten hours and no work shall be performed on the reactor which could result in lowering the reactor water level to more than six feet, three inches (-10 inches indicator scale) below minimum normal water level (Elevation 302'9").

AMENDMENT NO. 142, 222, 250 160

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT

f. The containment spray system shall be considered f. Lake Water Temperature operable by verifying that lake water temperature does not exceed 83F. Record in accordance with the Surveillance Frequency Control Program and at least once

g. If specification "f" cannot be met commence per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when latest recorded water shutdown within one hour and be in hot temperature is greater than or equal to 75F and shutdown within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and cold shutdown at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> when the latest within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. recorded water temperature is greater than or equal to 79F.

AMENDMENT NO. 142, 190, 222 161

ATTACHMENT 3

License Amendment Request

Nine Mile Point Nuclear Station, Unit 1 Docket No. 50-220

Adopt TSTF -230, Revision 1, "Add New Condition B to LCO 3.6.2.3, 'RHR Suppression Pool Cooling.'"

Proposed Technical Specification Bases Changes (Mark-Ups)

(for Information Only)

TS Bases Pages

162 163 (provided for completeness)

BASES FOR 3.3.7 AND 4.3.7 CONTAINMENT SPRAY SYSTEM

For reactor coolant temperatures less than 215F not enough steam is generated during a loss-of-coolant accident to pressurize the containment. For reactor coolant temperatures up to 312F, the resultant loss-of-coolant accident pressure would not exceed the design pressure of 35 psig.

Operation of only one containment spray pump is sufficient to provide the required containment spray cooling flow.(1) The specified flow of 3600 gpm at 87.7 psid primary, 89 psid secondary (approximately 95 percent to the drywell and the balance to the suppression chamber) is sufficient to remove post accident core energy released (FSAR Section VII). Requiring both pumps systems operable (400 percent redundancy) will assure the availability of the containment spray system.(1)

Allowable outages are specified to account for components that become inoperable in both systems and for more than one component in a system. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

The containment spray raw water cooling system is considered operable when the flow rate is not less than 300 0 gpm and the pressure on the raw water side of the containment spray heat exchangers is 10 psig greater than that on the torus water side (not less than 141 psig).

The higher pressure on the raw water side will assure that any leakage is into the containment spray system.

Electrical power for all system components is normally available from the reserve transformer. Upon loss of this service the pumping requirement will be supplied from the diesel generator. At least one diesel generator shall always be available to provide backup electrical power for one containment spray system.

Automatic initiation of the containment spray system assures that the containment will not be overpressurized. This automatic feature would only be required if all core spray systems malfunctioned and significant metal-water reaction occurred. For the normal operation condition of 85F suppression chamber water, containment spray actuation would not be necessary for about 15 minutes.

(1)With two of the containment spray intertie valves open, operation of two containment spray pumps is required to assure the proper flow distribution to the containment spray headers to reduce containment pressure during the first fifteen minutes of the LOCA. Requiring two containment spray pumps to operate reduces the 400 percent redundance of the containment spray system, but there are still si x combinations (two out of four pumps) that will assure two pump operation.

AMENDMENT NO. 142, Revision 53 (A250) 162 BASES FOR 3.3.7 AND 4.3.7 CONTAINMENT SPRAY SYSTEM

In conjunction with containment spray pump operation during each operating cycle, the raw water pumps and associated cooling system performance will be observed. The containment spray system shall be capable of automatic initiation from simultaneous low-low reactor water level and high containment pressure. The associated raw water cooling system shall be capable of manual actuation. Operation of the containment spray system involves spraying water into the atmosphere of the containment. Therefore, periodic system tests are not practical. Instead separate testing of automatic containment spray pump startup will be performed during each operating cycle. During pump operation, water will be recycled to the suppression chamber. Also, tests to verify that the drywell and torus spray nozzles are free from obstructions will be performed following maintenance that could result in nozzle blockage. As an alternative, a visual inspection (e.g.,

boroscope) of the nozzles or piping could be utilized in lieu of an air test if a visual inspection is determined to provide an equivalent or more effective post-maintenance test. A visual inspection may be more effective if the potential for material intrusion is localized and the affected area is accessible. Maintenance that could result in nozzle blockage would be those maintenance activities on any loop of the containment spray system where the Foreign Material Exclusion program controls were deemed ineffective. For activities such as valve repair/replacement, a visual inspection would be the preferred post-maintenance test since small debris in a localized area is the most likely concern. An air test may be appropriate following an event where a large amount of debris potentially entered the system or water was actually discharged through the spray nozzles. Design features are discussed in Volume I, Section VII-B.2.0 (page VII-19)*. The valves in the containment spray system are normally open and are not required to operate when the system is called upon to operate.

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

AMENDMENT NO. 142, Revision 33 (A208), 41 (A222) 163