Text

Application to Revise Technical Specifications to Adopt TSTF-592, Revise Automatic Depressurization System (ADS) Instrumentation Requirements
	ML24263A271
Person / Time
Site:	River Bend, Grand Gulf
Issue date:	09/19/2024
From:	Couture P; Entergy Operations
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	CNRO2024-00017
	Download: ML24263A271 (1)
	v • d • e

Phil Couture Senior Manager Fleet Regulatory Assurance - Licensing 601-368-5102 Entergy Operations, Inc., 1340 Echelon Parkway, Jackson, MS 39213 CNRO2024-00017 10 CFR 50.90 September 19, 2024 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Application to Revise Technical Specifications to Adopt TSTF-592, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements" Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for Grand Gulf Nuclear Station, Unit 1 (GGNS),

and River Bend Station, Unit 1, (RBS).

Entergy requests adoption of TSTF-592, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements" (Reference 1). The Technical Specifications (TS) 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," Actions are revised to reflect the plant design and the safety significance of inoperable ADS monitoring channels.

The enclosure provides a description and assessment of the proposed changes for GGNS and RBS. Attachments to the enclosure provide, for each site respectively, 1) the existing TS pages marked to show the proposed changes, 2) provide revised (clean) TS pages, and 3) provide the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

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

There are no regulatory commitments made in this submittal.

CNRO2024-00017 Page 2 of 3 In accordance with 10 CFR 50.91, a copy of this application, with enclosures and attachments, is being provided to the designated Mississippi and Louisiana State Officials.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on September 19, 2024.

If you should you have any questions or require additional information, please contact me at (601) 368-5102.

Respectfully, Phil Couture PC/gpn Enclosure :

Description and Assessment for GGNS and RBS Enclosure, Attachments:

1. GGNS Proposed Technical Specification Changes (Mark-Up)

2. GGNS Revised Technical Specification Pages

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

4. RBS Proposed Technical Specification Changes (Mark-Up)

5. RBS Revised Technical Specification Pages

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

References:

1) NRC letter to Technical Specifications Task Force (TSTF), "Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-592, Revision 2, 'Revise Automatic Depressurization System (ADS)

Instrumentation Requirements' (EPID L-2022-PMP-0011)", dated January 31, 2024.

Digitally signed by Philip Couture DN: cn=Philip Couture, c=US, o=Entergy, ou=Regulatory Assurance, email=pcoutur@entergy.com Date: 2024.09.19 11:26:48 -05'00' Philip Couture

CNRO2024-00017 Page 3 of 3 cc:

NRC Region IV-Regional Administrator NRC Senior Resident Inspector-Grand Gulf Nuclear Station NRC Senior Resident Inspector-River Bend Station NRC Project Manager-Grand Gulf Nuclear Station NRC Project Manager-River Bend Station NRC Project Manager-Entergy Fleet State Health Officer, Mississippi Department of Health Louisiana Department of Environmental Quality

ENCLOSURE CNRO2024-00017 Description and Assessment for GGNS and RBS

CNRO2024-00017 Enclosure Page 1 of 3 DESCRIPTION AND ASSESSMENT FOR GGNS and RBS

1.0 DESCRIPTION

Entergy requests adoption of TSTF-592, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements." The Technical Specifications (TS) 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," Actions are revised to reflect the plant design and the safety significance of inoperable ADS monitoring channels.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation Entergy has reviewed the safety evaluation for TSTF-592 provided to the Technical Specifications Task Force in a letter dated January 31, 2024. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-592. Entergy has concluded that the justifications presented in TSTF-592 and the safety evaluation prepared by the NRC staff are applicable to Grand Gulf Nuclear Station, Unit 1 (GGNS) and River Bend Station, Unit 1, (RBS), and justify this amendment for the incorporation of the changes to the GGNS and RBS TS.

2.2 Optional Changes and Variations Entergy is proposing the following minor variations from the TS changes described in TSTF-592 or the applicable parts of the NRC staffs safety evaluation dated January 31, 2024:

For GGNS and RBS, the TSTF-592 proposed changes for TS 3.8.1 Action A.3, Risk Informed Completion Time (RICT), have previously been accepted within the recent TSTF-505 approvals for the sites (References 2 and 3).

Both GGNS and RBS TS Bases utilize different numbering than the Standard Technical Specifications with respect to a reference provided in TS Bases 3.3.5.1. Specifically, the bases insert for H.1, H.2, and H.3 provided in TSTF-592 contains reference to a document listed as Reference 5. The GGNS and RBS TS Bases list this document as Reference 4.

These differences are administrative and do not affect the applicability of TSTF-592 to the GGNS and RBS TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Entergy requests adoption of TSTF-592, "Revise Automatic Depressurization System (ADS)

Instrumentation Requirements." The Technical Specifications (TS) 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," Actions are revised to reflect the plant design and the safety significance of inoperable ADS monitoring channels.

CNRO2024-00017 Enclosure Page 2 of 3 Entergy has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Response: No The proposed change revises the TS Actions applicable when one or more ADS monitoring channels are inoperable to be consistent with the plant design and the safety significance of the condition. The actions taken when an ADS monitoring channel is inoperable are not an initiator of any accident previously evaluated. The proposed actions implement the appropriate actions to be taken if automatic initiation of ADS is not available (i.e., declaring the ADS valves inoperable), which ensures the equipment assumed to be available to mitigate the consequences of accidents previously evaluated is available or the plant is placed in a safe condition.

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

2.

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

Response: No The proposed change revises the TS Actions applicable when one or more ADS monitoring channels are inoperable to be consistent with the plant design and the safety significance of the condition. The proposed change does not affect the design function or operation of the ADS or the ADS initiation instrumentation. The proposed change does not create a new or different type of failure for the ADS or the ADS initiation instrumentation due to credible new failure mechanisms, malfunctions, or accident initiators not currently considered in the design and licensing bases. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

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

Response: No The proposed change revises the TS Actions applicable when one or more ADS monitoring channels are inoperable to be consistent with the plant design and the safety significance of the condition. The proposed change does not affect any controlling values of parameters established in the design or licensing basis, and does not alter any design basis or safety limit.

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

CNRO2024-00017 Enclosure Page 3 of 3 Based on the above, Entergy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

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

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

5.0 REFERENCES

1. NRC letter to Technical Specifications Task Force (TSTF), "Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-592, Revision 2, 'Revise Automatic Depressurization System (ADS) Instrumentation Requirements' (EPID L-2022-PMP-0011)",

dated January 31, 2024.

2. NRC letter to Entergy, Grand Gulf Nuclear Station, Unit 1 - Issuance of Amendment No.

234, RE: Revision to Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b (EPID L-2023-LLA-0081),

(ADAMS Accession No. ML24176A120), dated July 29, 2024.

3. NRC letter to Entergy, River Bend Station, Unit 1 - Issuance of Amendment No. 213, RE:

Revision to Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b (EPID L-2023-LLA-0037), (ADAMS Accession No. ML24081A007), dated May 16, 2024.

ENCLOSURE, ATTACHMENT 1 CNRO2024-00017 GGNS Proposed Technical Specification Changes (Mark-Up)

(5 Pages)

ECCS Instrumentation 3.3.5.1 GRAND GULF 3.3-36 Amendment No. 120, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME F.

(continued)

F.2 Place channel in trip.

96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCS or reactor core isolation cooling (RCIC) inoperable AND 8 days OR In accordance with the Risk Informed Completion Time Program G.

As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

G.1

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

Only applicable for Functions 4.c, 4.e, 4.f, 4.g, 5.c, 5.e, and 5.f.

Declare ADS valves inoperable.

AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of ADS initiation capability in both trip systems (continued)

ECCS Instrumentation 3.3.5.1 GRAND GULF 3.3-37 Amendment No. 120, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME G.

(continued)

G.2 Restore channel to OPERABLE status.

96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCS or RCIC inoperable AND 8 days OR In accordance with the Risk Informed Completion Time Program H.

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

H.1 Declare associated supported feature(s) inoperable.

Immediately INSERT H I

I G,

H

INSERT H H. As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

H.1 ------------NOTE-------------

1. Only applicable for Functions 4.e, 4.f, and 5.e.

2. Only applicable when both ADS trip systems are inoperable due to LPCS/LPCI Pump Discharge Pressure -

High channels inoperable.

Declare ADS valves inoperable.

AND H.2 ------------NOTE-------------

1. Only applicable for Functions 4.e, 4.f, and 5.e.

2. Only applicable when one ADS trip system is inoperable due to LPCS/LPCI Pump Discharge Pressure -

High channels inoperable.

Restore affected channels to OPERABLE status.

AND H.3 Restore channel to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of ADS initiation capability in both trip systems 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channels concurrent with HPCS or RCIC inoperable AND 8 days or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channels 30 days

ECCS Instrumentation 3.3.5.1 GRAND GULF 3.3-42 Amendment No. 120, 207, 218 Table 3.3.5.1-1 (page 4 of 5)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

3. HPCS System (continued)

h. Manual Initiation 1,2,3, 1

C SR 3.3.5.1.6 NA

4. Automatic Depressurzation System (ADS) Trip System A

a. Reactor Vessel Water Level +/- Low Low Low, Level 1 1,2 (d)

,3 (d) 2 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

-152.5 inches

b. Drywell Pressure +/-

High 1,2 (d)

,3 (d) 2 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 1.44 psig

c.

ADS Initiation Timer 1,2 (d)

,3 (d) 1 G

SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 115 seconds

d. Reactor Vessel Water Level - Low, Level 3 (Confirmatory) 1,2 (d)

,3 (d) 1 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 10.8 inches

e. LPCS Pump Discharge Pressure +/-

High 1,2 (d)

,3 (d) 2 G

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 125 psig and 165 psig

f.

LPCI Pump A Discharge Pressure

+/- High 1,2 (d)

,3 (d) 2 G

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 115 psig and 135 psig (continued)

(d)

With reactor steam dome pressure > 150 psig.

H H

ECCS Instrumentation 3.3.5.1 GRAND GULF 3.3-43 Amendment No. 120, 207, 218 Table 3.3.5.1-1 (page 5 of 5)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

4.

ADS Trip system A (continued)

g.

ADS Bypass Timer (High Drywell Pressure) 1,2(d),3(d) 2 G

SR 3.3.5.1.1 SR 3.3.5.1.4 SR 3.3.5.1.6 9.4 minutes

h. Manual Initiation

5.

ADS Trip System B 1,2(d),3(d) 2/system G

SR 3.3.5.1.6 NA

a. Reactor Vessel Water Level +/- Low Low Low, Level 1 1,2(d),3(d) 2 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

-152.5 inches

b. Drywell Pressure +/-

High 1,2(d),3(d) 2 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 1.44 psig

c.

ADS Initiation Timer 1,2(d),3(d) 1 G

SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 115 seconds

d. Reactor Vessel Water LeveL +/-

Low, Level 3 (Confirmatory) 1,2(d),3(d) 1 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 10.8 inches

e. LPCI Pumps B & C Discharge Pressure +/- High 1,2(d),3(d) 2 per pump G

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 115 psig and 135 psig

f.

ADS Bypass Timer (High Drywell Pressure) 1,2(d),3(d) 2 G

SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 9.4 minutes

g. Manual Initiation 1,2(d),3(d) 2/system G

SR 3.3.5.1.6 NA (d)

With reactor steam dome pressure > 150 psig.

H H

H

ENCLOSURE, ATTACHMENT 2 CNRO2024-00017 GGNS Revised Technical Specification Pages (6 pages)

ECCS Instrumentation 3.3.5.1 GRAND GULF 3.3-36 Amendment No. 120, 234, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME F.

(continued)

F.2 Place channel in trip.

96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCS or reactor core isolation cooling (RCIC) inoperable AND 8 days OR In accordance with the Risk Informed Completion Time Program G.

As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

G.1 Declare ADS valves inoperable.

AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of ADS initiation capability in both trip systems (continued)

ECCS Instrumentation 3.3.5.1 GRAND GULF 3.3-37 Amendment No. 120, 234, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME G.

(continued)

G.2 Restore channel to OPERABLE status.

96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCS or RCIC inoperable AND 8 days OR In accordance with the Risk Informed Completion Time Program H.

As required by Required Action A.1 and referenced in Table 3.3.5-1-1 H.1

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

1.

Only applicable for Functions 4.e, 4.f, and 5.e.

2. Only applicable when both ADS trip systems are inoperable due to LPCS/LPCI Pump Discharge Pressure +/-

High channels inoperable.

Declare ADS valves inoperable.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of ADS initiation capability in both trip systems

ECCS Instrumentation 3.3.5.1 GRAND GULF 3.3-37a Amendment No. 120, 234, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME AND H.2

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

1.

Only applicable for Functions 4.e, 4.f, and 5.e.

2.

Only applicable when one ADS trip system is inoperable due to LPCS/LPCI Pump Discharge Pressure -

High channels inoperable.

Restore affected channels to OPERABLE status.

AND H.3 Restore channel to OPERABLE status.

96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channels concurrent with HPCS or RCIC inoperable AND 8 days or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channels 30 days

ECCS Instrumentation 3.3.5.1 GRAND GULF 3.3-37b Amendment No. 120, 234, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME I.

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

I.1 Declare associated supported feature(s) inoperable.

Immediately

ECCS Instrumentation 3.3.5.1 GRAND GULF 3.3-42 Amendment No. 120, 207, 218, Table 3.3.5.1-1 (page 4 of 5)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

3. HPCS System (continued)

h. Manual Initiation 1,2,3, 1

C SR 3.3.5.1.6 NA

4. Automatic Depressurzation System (ADS) Trip System A

a. Reactor Vessel Water Level +/- Low Low Low, Level 1 1,2 (d),3 (d) 2 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

-152.5 inches

b.

Drywell Pressure +/-

High 1,2 (d),3 (d) 2 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 1.44 psig

c.

ADS Initiation Timer 1,2 (d),3 (d) 1 G

SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 115 seconds

d. Reactor Vessel Water Level - Low, Level 3 (Confirmatory) 1,2 (d),3 (d) 1 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 10.8 inches

e. LPCS Pump Discharge Pressure +/-

High 1,2 (d),3 (d) 2 H

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 125 psig and 165 psig

f.

LPCI Pump A Discharge Pressure

+/- High 1,2 (d),3 (d) 2 H

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 115 psig and 135 psig (continued)

(d)

With reactor steam dome pressure > 150 psig.

ECCS Instrumentation 3.3.5.1 GRAND GULF 3.3-43 Amendment No. 120, 207, 218, Table 3.3.5.1-1 (page 5 of 5)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

4.

ADS Trip system A (continued)

g. ADS Bypass Timer (High Drywell Pressure) 1,2(d),3(d) 2 G

SR 3.3.5.1.1 SR 3.3.5.1.4 SR 3.3.5.1.6 9.4 minutes

h. Manual Initiation

5.

ADS Trip System B 1,2(d),3(d) 2/system H

SR 3.3.5.1.6 NA

a. Reactor Vessel Water Level +/- Low Low Low, Level 1 1,2(d),3(d) 2 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

-152.5 inches

b.

Drywell Pressure +/-

High 1,2(d),3(d) 2 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 1.44 psig

c.

ADS Initiation Timer 1,2(d),3(d) 1 G

SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 115 seconds

d. Reactor Vessel Water LeveL +/-

Low, Level 3 (Confirmatory) 1,2(d),3(d) 1 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 10.8 inches

e. LPCI Pumps B & C Discharge Pressure +/- High 1,2(d),3(d) 2 per pump H

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 115 psig and 135 psig

f.

ADS Bypass Timer (High Drywell Pressure) 1,2(d),3(d) 2 G

SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 9.4 minutes

g. Manual Initiation 1,2(d),3(d) 2/system H

SR 3.3.5.1.6 NA (d)

With reactor steam dome pressure > 150 psig.

ENCLOSURE, ATTACHMENT 3 CNRO2024-00017 GGNS Proposed Technical Specification Bases Changes (Mark-Up)

- For Information Only (10 pages)

ECCS Instrumentation B 3.3.5.1 BASES GRAND GULF B 3.3-104 LBDCR 18011 BACKGROUND Automatic Depressurization System (continued)

Each ADS trip system (trip system A and trip system B) includes a time delay between satisfying the initiation logic and the actuation of the ADS valves. The time delay chosen is long enough that the HPCS has time to operate to recover to a level above Level 1, yet not so long that the LPCI and LPCS systems are unable to adequately cool the fuel if the HPCS fails to maintain level. An alarm in the control room is annunciated when either of the timers is running. Resetting the ADS initiation signals resets the ADS Initiation Timers.

The ADS also monitors the discharge pressures of the three LPCI pumps and the LPCS pump. Each ADS trip system includes two discharge pressure permissive transmitters from each of the two low pressure ECCS pumps in the associated Division (i.e., Division 1 ECCS inputs to ADS trip system A and Division 2 ECCS inputs to ADS trip system B).

The signals are used as a permissive for ADS actuation, indicating that there is a source of core coolant available once the ADS has depressurized the vessel. Any one of the four low pressure pumps provides sufficient core coolant flow to permit automatic depressurization.

The ADS logic in each trip system is arranged in two strings. One string has a contact from each of the following variables: Reactor Vessel Water Level - Low Low Low, Level 1; Drywell Pressure - High or ADS Bypass Timer; Reactor Vessel Water Level - Low, Level 3; ADS Initiation Timer; and two low pressure ECCS Discharge Pressure -High contacts. The other string has a contact from each of the following variables: Reactor Vessel Water Level - Low Low Low, Level 1; Drywell Pressure - High or ADS Bypass Timer; and two low pressure ECCS Discharge Pressure -

High contacts. To initiate an ADS trip system, the following applicable contacts must close in the associated string: Reactor Vessel Water Level

- Low Low Low, Level 1; Drywell Pressure - High or ADS Bypass Timer; Reactor Vessel Water Level - Low, Level 3; ADS Initiation Timer; and one of the two low pressure ECCS Discharge Pressure - High contacts.

(continued)

Pump Pump Pump

ECCS Instrumentation B 3.3.5.1 BASES GRAND GULF B 3.3-124 LBDCR 23012 ACTIONS B.1, B.2, and B.3 (continued)

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action B.1, the Completion Time only begins upon discovery that a redundant feature in both Divisions (e.g., any Division 1 ECCS and Division 2 ECCS) cannot be automatically initiated due to inoperable, untripped channels within the same variable as described in the paragraph above. For Required Action B.2, the Completion Time only begins upon discovery that the HPCS System cannot be automatically initiated due to two inoperable, untripped channels for the associated Function in the same trip system.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months has been shown to be acceptable (Ref. 4) to permit restoration of any inoperable channel to OPERABLE status.

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action B.3. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue.

Alternately, if it is not desired to place the channel in trip (e.g., as in the case where placing the inoperable channel in trip would result in an initiation), Condition H must be entered and its Required Action taken.

(continued)

I

ECCS Instrumentation B 3.3.5.1 BASES GRAND GULF B 3.3-126 LBDCR 23012 ACTIONS C.1 and C.2 (continued)

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action C.1, the Completion Time only begins upon discovery that the same feature in both Divisions (e.g., any Division 1 ECCS and Division 2 ECCS) cannot be automatically initiated due to inoperable channels within the same variable as described in the paragraph above. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months has been shown to be acceptable (Ref. 4) to permit restoration of any inoperable channel to OPERABLE status.

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition H must be entered and its Required Action taken.

The Required Actions do not allow placing the channel in trip since this action would either cause the initiation or would not necessarily result in a safe state for the channel in all events.

D.1, D.2.1, and D.2.2 Required Action D.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same Function result in a complete loss of automatic component initiation capability for the HPCS System. Automatic component initiation capability is lost if two Function 3.d channels or two Function 3.e channels are inoperable and untripped. In this situation (loss of automatic suction swap), the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowance of Required Actions D.2.1 and D.2.2 is not appropriate and the HPCS System must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after discovery of loss of HPCS initiation capability. As noted, the Required Action is only applicable if the HPCS pump suction is not aligned to the suppression pool, since, if aligned, the Function is already performed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action D.1, the Completion Time only begins upon discovery that the HPCS System cannot be automatically aligned to the suppression pool due to two inoperable, (continued)

I

ECCS Instrumentation B 3.3.5.1 BASES GRAND GULF B 3.3-127 LBDCR 23012 ACTIONS D.1, D.2.1, and D.2.2 (continued) untripped channels in the same Function. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months has been shown to be acceptable (Ref. 4) to permit restoration of any inoperable channel to OPERABLE status.

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action D.2.1 or the suction source must be aligned to the suppression pool within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per Required Action D.2.2. Placing the inoperable channel in trip performs the intended function of the channel (shifting the suction source to the suppression pool). Performance of either of these two Required Actions will allow operation to continue. If Required Action D.2.1 or Required Action D.2.2 is performed, measures should be taken to ensure that the HPCS System piping remains filled with water. Alternately, if it is not desired to perform Required Actions D.2.1 and D.2.2, Condition H must be entered and its Required Action taken.

E.1 and E.2 Required Action E.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the LPCS and LPCI Pump Discharge Flow-Low (Bypass) Functions result in redundant automatic initiation capability being lost for the feature(s). For Required Action E.1, the features would be those that are initiated by Functions 1.e, 1.f, and 2.e (e.g., low pressure ECCS). Redundant automatic initiation capability is lost if three of the four channels associated with Functions 1.e, 1.f, and 2.e are inoperable. Since each inoperable channel would have Required Action E.1 applied separately (refer to ACTIONS Note), each inoperable channel would only require the affected low pressure ECCS pump to be declared inoperable. However, since channels for more than one low pressure ECCS pump are inoperable, and the Completion Times started concurrently for the channels of the low pressure ECCS pumps, this results in the affected low pressure ECCS pumps being concurrently declared inoperable.

(continued)

I

ECCS Instrumentation B 3.3.5.1 BASES GRAND GULF B 3.3-129 LBDCR 23012 ACTIONS E.1 and E.2 (continued) of service time, Condition H must be entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

F.1 and F.2 Required Action F.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within similar ADS trip system Functions result in automatic initiation capability being lost for the ADS. Automatic initiation capability is lost if either (a) one or more Function 4.a channel(s) and one or more Function 5.a channel(s) are inoperable and untripped, (b) one Function 4.b channel(s) and one Function 5.b channel are inoperable and untripped, or (c) one Function 4.d channel and one Function 5.d channel are inoperable and untripped.

In this situation (loss of automatic initiation capability), the 96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or 8 day allowance, as applicable, of Required Action F.2 is not appropriate, and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after discovery of loss of ADS initiation capability in both trip systems.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action F.1, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable, untripped channels within similar ADS trip system Functions as described in the paragraph above. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

(continued)

I

ECCS Instrumentation B 3.3.5.1 BASES GRAND GULF B 3.3-130 LBDCR 23012 ACTIONS F.1 and F.2 (continued)

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 8 days has been shown to be acceptable (Ref. 4) to permit restoration of any inoperable channel to OPERABLE status if both HPCS and RCIC are OPERABLE. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If either HPCS or RCIC is inoperable, the time is shortened to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months .

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If the status of HPCS or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months , the 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months begins upon discovery of HPCS or RCIC inoperability. However, total time for an inoperable, untripped channel cannot exceed 8 days. If the status of HPCS or RCIC changes such that the Completion Time changes from 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable, untripped channel. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action F.2. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue. Alternately, if it is not desired to place the channel in trip (e.g., as in the case where placing the inoperable channel in trip would result in an initiation), Condition H must be entered and its Required Action taken.

G.1 and G.2 Required Action G.1 is intended to ensure that appropriate actions are taken if multiple, inoperable channels within similar ADS trip system Functions result in automatic initiation capability being lost for the ADS.

Automatic initiation capability is lost if either (a) one Function 4.c channel and one Function 5.c channel are inoperable, (b) one or more Function 4.e channels and one or more Function 5.e channels are inoperable, (c) one or more Function 4.f channels and one or more Function 5.e channels are inoperable, or (d) one or more Function 4.g channels and one or more Function 5.f channels are inoperable.

(continued)

I b

ECCS Instrumentation B 3.3.5.1 BASES GRAND GULF B 3.3-131 LBDCR 23012 ACTIONS G.1 and G.2 (continued)

In this situation (loss of automatic initiation capability), the 96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or 8 day allowance, as applicable, of Required Action G.2 is not appropriate, and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after discovery of loss of ADS initiation capability in both trip systems. The Note to Required Action G.1 states that Required Action G.1 is only applicable for Functions 4.c, 4.e, 4.f, 4.g, 5.c, 5.e, and 5.f. Required Action G.1 is not applicable to Functions 4.h and 5.g (which also require entry into this Condition if a channel in these Functions is inoperable),

since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of manual initiation capability for 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or 8 days (as allowed by Required Action G.2) is allowed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action G.1, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable channels within similar ADS trip system Functions, as described in the paragraph above. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 8 days has been shown to be acceptable (Ref. 4) to permit restoration of any inoperable channel to OPERABLE status if both HPCS and RCIC are OPERABLE (Required Action G.2). Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If either HPCS or RCIC is inoperable, the time is reduced to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months . Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If the status of HPCS or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months , the 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months begins upon discovery of HPCS or RCIC inoperability. However, total time for an inoperable channel cannot exceed 8 days. If the status of HPCS or RCIC changes such that the Completion Time changes from 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable channel. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition H must be entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events.

(continued)

I INSERT H.1., H.2, and H.3

H.1, H.2, and H.3 Required Action H.1 requires that the ADS valves be declared inoperable when a combination of Functions 4.e, 4.f, and 5.e channels are inoperable such that neither ADS Trip System A or B has two OPERABLE Pump Discharge Pressure - High channels associated with one low pressure ECCS pump.

In this situation (loss of automatic initiation capability), the 96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or 8 day allowance, as applicable, of Required Action H.2 is not appropriate, and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after discovery of loss of ADS initiation capability in both trip systems. The Notes to Required Action H.1 state that Required Action H.1 is only applicable for Functions 4.e, 4.f, and 5.e, and that it is only applicable when both ADS trip systems are inoperable due to LPCS/LPCI Pump Discharge Pressure - High channels being inoperable. Required Action H.1 is not applicable to Functions 4.h and 5.g (which also require entry into this Condition if a channel in these Functions is inoperable), since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of these functions for 30 days (as allowed by Required Action H.3) is allowed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action H.1, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable channels within similar ADS trip system Functions, as described in the paragraph above. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration of channels. If the inoperable channels cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.

Required Action H.2 is intended to ensure that appropriate actions are taken if there are not two OPERABLE Pump Discharge Pressure

- High channels associated with one low pressure ECCS pump within one ADS trip system, which results in automatic initiation capability being lost for that ADS trip system. Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, a Completion Time of 8 days has been shown to be acceptable (Ref. 4) to permit restoration of two inoperable Pump Discharge Pressure - High channels associated with one low pressure ECCS Pump to OPERABLE status if both HPCS and RCIC are OPERABLE (Required Action H.2).

INSERT H.1, H.2, H.3

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If either HPCS or RCIC is inoperable, the Completion Time is reduced to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months .

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If the status of HCPS or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months , the 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months begins upon discovery of HPCS or RCIC inoperability. However, the total time to restore the required inoperable channels to OPERABLE status cannot exceed 8 days. If the status of HPCS or RCIC changes such that the Completion Time changes from 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable channel. If the minimum required inoperable channels cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.

The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events. The Notes to Required Action H.2 state that Required Action H.2 is only applicable for Functions 4.e, 4.f, and 5.e, and that it is only applicable when one ADS trip system is inoperable due to LPCS/LPCI Pump Discharge Pressure - High functions are inoperable. Required Action H.2 is not applicable to Functions 4.h and 5.g (which also require entry into this Condition if a channel in these Functions is inoperable), since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of these functions for 30 days (as allowed by Required Action H.3) is allowed.

Required Action H.3 is intended to ensure that appropriate actions are taken if inoperable channels within one ADS trip system do not result in loss of automatic initiation capability to respond to a design basis event, but require restoration per Table 3.3.5.1-1. This applies to Functions 4.e, 4.f, 4.h, 5.e, and 5.g. The 30 day Completion Time of Required Action H.3 is acceptable, based on operating experience, considering the multiple channels available for meeting the low pressure ECCS pump discharge pressure permissive, and the availability of automatic ADS initiation. If the inoperable channel cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.

INSERT H.1, H.2, H.3 continued

ECCS Instrumentation B 3.3.5.1 BASES GRAND GULF B 3.3-132 Revision No. 0 ACTIONS H.1 With any Required Action and associated Completion Time not met, the associated feature(s) may be incapable of performing the intended function and the supported feature(s) associated with the inoperable untripped channels must be declared inoperable immediately.

SURVEILLANCE As noted at the beginning of the SRs, the SRs for each ECCS REQUIREMENTS instrumentation Function are found in the SRs column of Table 3.3.5.1-1.

The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months as follows: (a) for Functions 3.c, 3.f, 3.g, and 3.h; and (b) for Functions other than 3.c, 3.f, 3.g, and 3.h provided the associated Function or the redundant Function maintains ECCS initiation capability. Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken. This Note is based on the reliability analysis (Ref. 4) assumption of the average time required to perform channel Surveillance. That analysis demonstrated that the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months testing allowance does not significantly reduce the probability that the ECCS will initiate when necessary.

(continued)

I (LPCS, LPCI, HPCS, or ADS)

ENCLOSURE, ATTACHMENT 4 CNRO2024-00017 RBS Proposed Technical Specification Changes (Mark-Up)

(5 pages)

ECCS Instrumentation 3.3.5.1 RIVER BEND 3.3-36a Amendment No. 213 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

G.1

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

Only applicable for Functions 4.c, 4.e, 4.f, 4.g, 5.c, 5.e, and 5.f.

Declare ADS valves inoperable.

AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of ADS initiation capability in both trip systems (continued)

ECCS Instrumentation 3.3.5.1 ACTIONS RIVER BEND 3.3-37 Amendment No. 81, 213 CONDITION REQUIRED ACTION COMPLETION TIME G.

(continued)

G.2 Restore channel to OPERABLE status.

NOTE---------

The Risk Informed Completion Time Program is not applicable when a loss of function occurs.

96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCS or RCIC inoperable AND

NOTE---------

The Risk Informed Completion Time Program is not applicable when a loss of function occurs.

8 days or in accordance with the Risk Informed Completion Time Program H.

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

H.1 Declare associated supported feature(s) inoperable.

Immediately INSERT H I

G, H

I

INSERT H H. As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

H.1 ------------NOTE-------------

1. Only applicable for Functions 4.e, 4.f, and 5.e.

2. Only applicable when both ADS trip systems are inoperable due to LPCS/LPCI Pump Discharge Pressure -

High channels inoperable.

Declare ADS valves inoperable.

AND H.2 ------------NOTE-------------

1. Only applicable for Functions 4.e, 4.f, and 5.e.

2. Only applicable when one ADS trip system is inoperable due to LPCS/LPCI Pump Discharge Pressure -

High channels inoperable.

Restore affected channels to OPERABLE status.

AND H.3 Restore channel to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of ADS initiation capability in both trip systems 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channels concurrent with HPCS or RCIC inoperable AND 8 days or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channels 30 days

H H

H

H H

ENCLOSURE, ATTACHMENT 5 CNRO2024-00017 RBS Revised Technical Specification Pages (6 pages)

ECCS Instrumentation 3.3.5.1 RIVER BEND 3.3-36a Amendment No. 213, ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

G.1 Declare ADS valves inoperable.

AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of ADS initiation capability in both trip systems (continued)

ECCS Instrumentation 3.3.5.1 RIVER BEND 3.3-37 Amendment No. 81, 213 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G.

(continued)

G.2 Restore channel to OPERABLE status.

NOTE---------

The Risk Informed Completion Time Program is not applicable when a loss of function occurs.

96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCS or RCIC inoperable AND

NOTE---------

The Risk Informed Completion Time Program is not applicable when a loss of function occurs.

8 days or in accordance with the Risk Informed Completion Time Program (continued)

ECCS Instrumentation 3.3.5.1 RIVER BEND 3.3-37a Amendment No.

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H.

As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

H.1 ----------------NOTE---------------

1. Only applicable for Functions 4.e, 4.f, and 5.e.

2. Only applicable when both ADS trip systems are inoperable due to LPCS/LPCI Pump Discharge Pressure -

High channels inoperable.

Declare ADS valves inoperable.

AND H.2 ----------------NOTE---------------

1. Only applicable for Functions 4.e, 4.f, and 5.e.

2. Only applicable when one ADS trip system is inoperable due to LPCS/LPCI Pump Discharge Pressure -

High channels inoperable.

Restore affected channels to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of ADS initiation capability in both trip systems 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCS or RCIC inoperable (continued)

ECCS Instrumentation 3.3.5.1 RIVER BEND 3.3-37b Amendment No.

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H.

(continued)

AND H.3 Restore channel to OPERABLE status.

AND 8 days or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channels 30 days I.

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

I.1 Declare associated supported features(s) inoperable.

Immediately

ECCS Instrumentation 3.3.5.1 RIVER BEND 3.3-42 Amendment No. 81, 193, Table 3.3.5.1-1 (page 4 of 5)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

4.

Automatic Depressurization System (ADS) Trip System A

a.

Reactor Vessel Water Level Low Low Low, Level 1 1,2(b),3(b) 2 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

-147 inches

b.

Drywell Pressure High 1,2(b),3(b) 2 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 1.88 psid

c.

ADS Initiation Timer 1,2(b),3(b) 1 G

SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 117 seconds

d.

Reactor Vessel Water Level Low, Level 3 (Confirmatory) 1,2(b),3(b) 1 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 8.7 inches

e.

LPCS Pump Discharge Pressure High 1,2(b),3(b) 2 H

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 130 psig

f.

LPCI Pump A Discharge Pressure High 1,2(b),3(b) 2 H

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 120 psig

g.

ADS Bypass Timer (High Drywell Pressure) 1,2(b),3(b) 2 G

SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 5.5 minutes

h.

Manual Initiation 1,2(b),3(b) 2 per system H

SR 3.3.5.1.6 NA (continued)

(b) With reactor steam dome pressure > 100 psig.

ECCS Instrumentation 3.3.5.1 RIVER BEND 3.3-43 Amendment No. 81, 193, Table 3.3.5.1-1 (page 5 of 5)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

5.

ADS Trip System B

a.

Reactor Vessel Water Level Low Low Low, Level 1 1,2(b),3(b) 2 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

-147 Inches

b.

Drywell Pressure High 1,2(b),3(b) 2 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 1.88 psid

c.

ADS Initiation Timer 1,2(b),3(b) 1 G

SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 117 seconds

d.

Reactor Vessel Water Level Low, Level 3 (Confirmatory) 1,2(b),3(b) 1 F

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 8.7 Inches

e.

LPCI Pumps B & C Discharge Pressure High 1,2(b),3(b) 2 per pump H

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 120 psig

f.

ADS Bypass Timer (High Drywell Pressure) 1,2(b),3(b) 2 G

SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 5.5 minutes

g.

Manual Initiation 1,2(b),3(b) 2 per system H

SR 3.3.5.1.6 NA (b) With reactor steam dome pressure > 100 psig.

ENCLOSURE, ATTACHMENT 6 CNRO2024-00017 RBS Proposed Technical Specification Bases Changes (Mark-Up)

- For Information Only (11 pages)

Pump Pump Pump

I

I b

I INSERT H.1., H.2, and H.3

H.1, H.2, and H.3 Required Action H.1 requires that the ADS valves be declared inoperable when a combination of Functions 4.e, 4.f, and 5.e channels are inoperable such that neither ADS Trip System A or B has two OPERABLE Pump Discharge Pressure - High channels associated with one low pressure ECCS pump.

In this situation (loss of automatic initiation capability), the 96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or 8 day allowance, as applicable, of Required Action H.2 is not appropriate, and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after discovery of loss of ADS initiation capability in both trip systems. The Notes to Required Action H.1 state that Required Action H.1 is only applicable for Functions 4.e, 4.f, and 5.e, and that it is only applicable when both ADS trip systems are inoperable due to LPCS/LPCI Pump Discharge Pressure - High channels being inoperable. Required Action H.1 is not applicable to Functions 4.h and 5.g (which also require entry into this Condition if a channel in these Functions is inoperable), since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of these functions for 30 days (as allowed by Required Action H.3) is allowed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action H.1, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable channels within similar ADS trip system Functions, as described in the paragraph above. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration of channels. If the inoperable channels cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.

Required Action H.2 is intended to ensure that appropriate actions are taken if there are not two OPERABLE Pump Discharge Pressure

- High channels associated with one low pressure ECCS pump within one ADS trip system, which results in automatic initiation capability being lost for that ADS trip system. Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, a Completion Time of 8 days has been shown to be acceptable (Ref. 4) to permit restoration of two inoperable Pump Discharge Pressure - High channels associated with one low pressure ECCS Pump to OPERABLE status if both HPCS and RCIC are OPERABLE (Required Action H.2).

INSERT H.1, H.2, H.3

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If either HPCS or RCIC is inoperable, the Completion Time is reduced to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months .

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If the status of HCPS or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months , the 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months begins upon discovery of HPCS or RCIC inoperability. However, the total time to restore the required inoperable channels to OPERABLE status cannot exceed 8 days. If the status of HPCS or RCIC changes such that the Completion Time changes from 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable channel. If the minimum required inoperable channels cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.

The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events. The Notes to Required Action H.2 state that Required Action H.2 is only applicable for Functions 4.e, 4.f, and 5.e, and that it is only applicable when one ADS trip system is inoperable due to LPCS/LPCI Pump Discharge Pressure - High functions are inoperable. Required Action H.2 is not applicable to Functions 4.h and 5.g (which also require entry into this Condition if a channel in these Functions is inoperable), since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of these functions for 30 days (as allowed by Required Action H.3) is allowed.

Required Action H.3 is intended to ensure that appropriate actions are taken if inoperable channels within one ADS trip system do not result in loss of automatic initiation capability to respond to a design basis event, but require restoration per Table 3.3.5.1-1. This applies to Functions 4.e, 4.f, 4.h, 5.e, and 5.g. The 30 day Completion Time of Required Action H.3 is acceptable, based on operating experience, considering the multiple channels available for meeting the low pressure ECCS pump discharge pressure permissive, and the availability of automatic ADS initiation. If the inoperable channel cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.

INSERT H.1, H.2, H.3 continued

I (LPCS, LPCI, HPCS, or ADS)

v t e Letter Sequence Request
EPID:L-2024-LLA-0133, TSTF-592 (Open)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2024-09-19 [Table View]

ML24263A271

Text

Subject:

References:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

5.0 REFERENCES

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