Text

Stations - License Amendment Request to Adopt TSTF-309, Revise Pressureizer PORV Actions Not to Require Cycling of Block Vlave When Closed for Isolation, Revision 2
	ML25058A246
Person / Time
Site:	Byron, Braidwood, Ginna
Issue date:	02/27/2025
From:	Humphrey M; Constellation Energy Generation
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	RS-25-019
	Download: ML25058A246 (1)
	v • d • e

10 CFR 50.90 RS-25-019 February 27, 2025 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket Nos. 50-244

Subject:

License Amendment Request to adopt TSTF-309, "Revise Pressurizer PORV Actions to not require cycling of block valve when closed for isolation," Revision 2 Reference:

TSTF-309, "Revise Pressurizer PORV Actions to not require cycling of block valve when closed for isolation," Revision 2, dated July 26, 1999 (ADAMS Accession Number ML040620179)

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests amendments to the Technical Specifications (TS) for Braidwood Station (Braidwood), Units 1 and 2, Byron Station (Byron), Units 1 and 2, and R. E. Ginna Nuclear Power Plant (Ginna). The proposed amendment is consistent with NRC-approved Technical Specification Task Force (TSTF)

Traveler 309, Revision 2, "Revise Pressurizer PORV Actions to not require cycling of block valve when closed for isolation" (i.e., Reference). Specifically, the proposed change modifies TS 3.4.11, "Pressurizer Power Operated Relief Valves (PORVs)," to add notes stating that the Required Actions do not apply if the PORV block valve was declared inoperable solely as a result of complying with other Required Actions in TS 3.4.11.

This request is subdivided as follows.

x provides a description and evaluation of the proposed change.

February 27, 2025 U.S. Nuclear Regulatory Commission Page 2 x provides a markup of the affected TS page for Braidwood.

x provides a markup of the affected TS Bases pages for Braidwood. The Bases pages are provided for information only and do not require NRC approval.

x provides a markup of the affected TS page for Byron.

x provides a markup of the affected TS Bases pages for Byron. The Bases pages are provided for information only and do not require NRC approval.

x provides a markup of the affected TS pages for Ginna.

x provides a markup of the affected TS Bases page for Ginna. The Bases page is provided for information only and does not require NRC approval.

The proposed change has been reviewed by the Plant Operations Review Committees at each station in accordance with the requirements of the CEG Quality Assurance Program.

CEG requests approval of the proposed amendment by February 27, 2026. Once approved, the amendment shall be implemented within 60 days. This implementation period will provide adequate time for the affected station documents to be revised using the appropriate change control mechanisms.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), CEG is notifying the States of Illinois and 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 letter, please contact Mr. Aaron W. Hessenkemper at 309-227-4060.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th day of February 2025.

Respectfully, Mark Humphrey Sr. Manager Licensing Constellation Energy Generation, LLC Attachments:

1. Evaluation of Proposed Change

2. Markup of Braidwood Technical Specifications Page

3. Markup of Braidwood Technical Specifications Bases Pages (For Information Only)

4. Markup of Byron Technical Specifications Page

5. Markup of Byron Technical Specifications Bases Pages (For Information Only)

6. Markup of Ginna Technical Specifications Pages

7. Markup of Ginna Technical Specifications Bases Page (For Information Only)

Humphrey, Mark D.

Digitally signed by Humphrey, Mark D.

Date: 2025.02.27 12:27:42 -06'00'

February 27, 2025 U.S. Nuclear Regulatory Commission Page 3 cc:

NRC Regional Administrator, Region I NRC Regional Administrator, Region III NRC Senior Resident Inspector, Braidwood NRC Senior Resident Inspector, Byron NRC Senior Resident Inspector, Ginna Illinois Emergency Management Agency - Division of Nuclear Safety A. L. Peterson, NYSERDA Evaluation of Proposed Change Page 1

Subject:

License Amendment Request to adopt TSTF-309, "Revise Pressurizer PORV Actions to not require cycling of block valve when closed for isolation," Revision 2 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration 4.3 Conclusions 5.0 ENVIRONMENTAL CONSIDERATION 6.0 REFERENCES Evaluation of Proposed Change Page 2 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests amendments to the Technical Specifications (TS) for Braidwood Station (Braidwood), Units 1 and 2, Byron Station (Byron), Units 1 and 2, and R. E. Ginna Nuclear Power Plant (Ginna). The proposed changes would revise the Operating Licenses to add notes to Technical Specifications (TS) Section 3.4.11, "Pressurizer Power Operated Relief Valves (PORVs)." The notes state that the Required Actions do not apply if the PORV block valve was declared inoperable solely as a result of complying with other TS Required Actions. Markups of the proposed changes are provided in Attachments 2, 4, and 6 for Braidwood, Byron, and Ginna, respectively.

Additionally, TS Bases Section 3.4.11 is revised to describe how the notes modify the affected Required Actions. Markups of the affected Bases changes are provided in Attachments 3, 5, and 7 for Braidwood, Byron, and Ginna, respectively. The Bases pages are provided for information only, and do not require NRC approval.

The proposed changes are consistent with Technical Specification Task Force (TSTF) change Traveler TSTF-309, Revision 2, "Revise Pressurizer PORV Actions to not require cycling of block valve when closed for isolation," which was approved by the NRC on July 26, 1999 (i.e.,

Reference 1). Minor differences between the TSTF changes and plant-specific TS are discussed in Sections 2.0 and 3.0 of this evaluation.

2.0 DETAILED DESCRIPTION When a PORV is inoperable and not capable of being manually cycled, TS 3.4.11 requires closing and de-energizing the associated block valve. Operability of the PORV must also be restored within the applicable TS Completion Time. Closing and de-energizing the block valve isolates the PORV line and renders the block valve inoperable but does not restore operability to the associated PORV. The restoration of PORV operability is still required within the applicable TS Completion Time.

For a single inoperable PORV block valve, current TS 3.4.11 Condition C for Braidwood and Byron require the associated PORV be placed in manual control within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and block valve operability restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or in accordance with Risk Informed Completion Times (RICT). Ginna's current TS 3.4.11 Condition C requires placing the associated PORV in manual control within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and restoring block valve operability within 7 days, or in accordance with RICT if the opposite train PORV is operable.

For two block valves inoperable, Braidwood and Byron current TS 3.4.11 Condition F requires restoration of one block valve to operable status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . For Ginna, TS 3.4.11 Condition D requires the associated PORVs be placed in manual control within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and restoring at least one block valve to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Consistent with NRC-approved TSTF-309, Revision 2, the proposed TS and Bases changes include:

Evaluation of Proposed Change Page 3 x

For Braidwood and Byron, revised TS Section 3.4.11 Required Actions C.1, C.2 and F.1 to add notes stating the Actions are not required if the inoperable block valve is inoperable solely to comply with other TS Required Actions.

x For Ginna, revised TS Section 3.4.11 Required Actions C.1, C.2, D.1 and D.2 to add notes stating the Actions are not required if the inoperable block valve is inoperable solely to comply with other TS Required Actions.

x Revised TS Section 3.4.11 Bases to add discussion for how notes modify the Required Actions for inoperable PORV block valves.

Implementing these changes will eliminate the need to enter and execute actions for PORV block valves that are intentionally made inoperable solely to comply with the Required Actions for inoperable PORVs. In these cases, the Required Actions for PORV inoperability are adequate to address inoperability of the affected pressure relief line(s), including the block valves. This is further described in Section 3.0 of this evaluation.

3.0 TECHNICAL EVALUATION

Pressurized Water Reactor pressurizer PORVs are air operated valves that are controlled to open at a specific set pressure when the pressurizer pressure increases and close when the pressurizer pressure decreases. The PORVs may also be manually operated from the control room.

Motor-operated block valves, which are normally open, are located between the pressurizer and the PORVs. The block valves are used to isolate the PORVs in case of excessive leakage or a stuck open PORV. Block valve closure is accomplished manually using controls in the control room. A stuck open PORV is, in effect, a small break Loss Of Coolant Accident (LOCA). As such, block valve closure terminates the RCS depressurization and coolant inventory loss. The PORVs and their associated block valves may be used by plant operators to depressurize the RCS to recover from certain transients if normal pressurizer spray is not available.

TS Limiting Conditions of Operation (LCOs) for pressurizer PORVs and the associated block valves are delineated in TS Section 3.4.11, "Pressurizer Power Operated Relief Valves (PORVs)." The technical specifications covering PORVs on most operating PWRs that deal with closing the block valve and removing power were developed to prevent excessive leakage through the valves and were not to ensure the operability of the PORVs. The current TS 3.4.11 requirement to place an associated PORV in manual control when the PORV block valve is inoperable does not preserve pressurizer pressure control when the affected PORV is unable to stroke. Additionally, pressure relief through the affected line is not available when the block valve is incapable of being opened.

The change proposed in this evaluation will add notes to the Required Actions for TS 3.4.11 Conditions C and F for Braidwood and Byron, and Conditions C and D for Ginna. The new notes will preclude performance of the Required Actions for an inoperable PORV block valve when the block valve is only inoperable because it was closed and de-energized in response to inoperable PORVs. In these conditions, the TS Required Actions for PORV inoperability are Evaluation of Proposed Change Page 4 adequate to address inoperability of the affected pressure relief line(s), including the block valves. The PORV Required Actions bound the additional actions that are required for the block valves that were rendered inoperable solely to comply with the PORV Required Actions.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The regulatory requirements associated with this amendment application include the following:

10 CFR 50.36, "Technical specifications," details the content and information that must be included in a station's Technical Specifications (TS). In accordance with 10 CFR 50.36, TSs are required to include (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. The proposed TS changes are consistent with the format, level of detail, and structure of NUREG 1431, Standard Technical Specifications Westinghouse Plants, Volume 1 Specifications, Revision 5.0 dated March 2021.

The following regulatory requirements and criteria were reviewed during development of the proposed license amendment:

x Generic Letter 90-06, "Resolution of Generic Issue 70, 'Power-Operated Relief Valve and Block Valve Reliability' and Generic Issue 94, 'Additional Low-Temperature Over Pressure Protection for Light-Water Reactors' Pursuant to 10 CFR 50.54(f),"

x NUREG-1316, "Technical Findings and Regulatory Analysis Related to Generic Issue 70, Evaluation of Power-Operated Relief Valve and Block Valve Reliability in PWR Nuclear Power Plants,"

x 10 CFR 50, Appendix A, Criterion 31 - "Fracture prevention of reactor coolant pressure boundary." (Note that Ginna was licensed using the 1967 Atomic Industrial Forum General Design Criteria; however, the Ginna UFSAR discusses the adequacy of the Ginna design relative to the 1972 version of the GDC in 10 CFR 50, Appendix A.) and x

10 CFR 50, Appendix G, "Fracture Toughness Requirements."

CEG has determined that the proposed amendment is consistent with the regulatory requirements and criteria described in the above cited documents.

4.2 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Facility Operating License Nos. NPF-72, NPF-77, NPF-37, NPF-66 and DPR-18 for Braidwood Station (Braidwood) Units 1 and 2, Byron Station (Byron) Units 1 and 2, and R.E. Ginna Nuclear Power Plant (Ginna), respectively. The proposed change is consistent with NRC-approved Technical Specification Task Force (TSTF) Traveler 309, "Revise Pressurizer PORV Actions to not require cycling of block valve when closed for isolation," Revision 2. Specifically, the proposed change modifies Technical Specifications (TS) 3.4.11, "Pressurizer Power Operated Evaluation of Proposed Change Page 5 Relief Valves (PORVs)," to add notes stating that the Required Actions do not apply if the PORV block valve was declared inoperable solely as a result of complying with other Required Actions in TS 3.4.11.

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.

CEG has evaluated the proposed change, using the criteria in 10 CFR 50.92, and has determined that the proposed change does not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

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

Response: No For Braidwood and Byron stations, the proposed change relieves adherence to TS 3.4.11 Required Actions C.1, C.2 and F.1 for one or more inoperable PORV block valves when the block valves have been intentionally made inoperable solely to comply with Required Action B.2.

For Ginna station, the proposed change relieves adherence to TS 3.4.11 Required Actions C.1, C.2, D.1 and D.2 for one or more inoperable PORV block valves when the block valves have been intentionally made inoperable solely to comply with Required Actions B.2 or F.3 When a PORV block valve has been closed and de-energized as a Required Action for an inoperable PORV, the Required Actions for the block valve may not be appropriate or even possible, and steam line inoperability is already bounded by the inoperable PORV Required Actions. In such cases, the existing Required Actions for the inoperable PORV establish the most conservative timeline for pressurizer relief line restoration. The existing Required Actions for an inoperable PORV block valve do not restore or maintain pressurizer pressure relief functions when the associated PORV is inoperable and unable to open for pressure control.

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

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

Evaluation of Proposed Change Page 6 Response: No The proposed change does not involve a physical modification or alteration of plant equipment (i.e., no new or different type of equipment will be installed) or a change to the methods governing normal plant operation. The Required Actions and associated Completion Times in the proposed change have been evaluated to ensure that no new accident initiators are introduced.

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 relaxed Required Actions do not involve a significant reduction in a margin of safety.

When a PORV block valve has been closed and de-energized as a Required Action for an inoperable PORV, the Required Actions for the block valve may not be appropriate or even possible, and steam line inoperability is already bounded by the inoperable PORV Required Actions. In such cases, the existing Required Actions for the inoperable PORV establish the most conservative timeline for pressurizer relief line restoration. As the proposed change will not alter the bounding timeline for PORV inoperability, and overall safety margins are therefore unchanged.

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

Based on the above, CEG concludes that the proposed amendments do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c), and, accordingly, a finding of no significant hazards consideration is justified.

4.3 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 Commission's 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 CONSIDERATION 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. However, the proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet the eligibility Evaluation of Proposed Change Page 7 criterion for categorical exclusion set forth in 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," paragraph (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 amendments.

6.0 REFERENCES

1.

TSTF-309, Revision 2, " Revise Pressurizer PORV Actions to not require cycling of block valve when closed for isolation" (ADAMS Accession Number ML040620179)

Markup of Braidwood Technical Specifications Page Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 REVISED TECHNICAL SPECIFICATIONS PAGE 3.4.11-2

Pressurizer PORVs 3.4.11 BRAIDWOOD UNITS 1 & 2 3.4.11 2 Amendment 206 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

One block valve inoperable.

C.1 Place associated PORV in manual control.

AND C.2 Restore block valve to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours OR In accordance with the Risk Informed Completion Time Program D.

Required Action and associated Completion Time of Condition A, B, or C not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours E.

Two PORVs inoperable and not capable of being manually cycled.

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours F.

Two block valves inoperable.

F.1 Restore one block valve to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months G.

Required Action and associated Completion Time of Condition F not met.

G.1 Be in MODE 3.

AND G.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours INSERT 1 INSERT 2

INSERT 1

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

Required Actions C.1 and C.2 do not apply when block valve is inoperable solely as a result of complying with Required Action B.2.

INSERT 2

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

Required Action F.1 does not apply when block valve is inoperable solely as a result of complying with Required Action B.2.

Markup of Braidwood Technical Specifications Bases Pages Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.4.11-6 B 3.4.11-7

Pressurizer PORVs B 3.4.11 BRAIDWOOD UNITS 1 & 2 B 3.4.11 6 Revision 127 BASES ACTIONS (continued)

Because at least one PORV remains OPERABLE, the operator is permitted a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the inoperable block valve to OPERABLE status. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. The time allowed to restore the block valve is based upon the Completion Time for restoring an inoperable PORV in Condition B, since the PORVs may not be capable of mitigating an event if the inoperable block valve is not full open. If the block valve is restored within the Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the power will be restored, and the PORV restored to OPERABLE status. If it cannot be restored within this additional time, the unit must be brought to a MODE in which the LCO does not apply, as required by Condition D.

D.1 and D.2 If the Required Action of Condition A, B, or C is not met, then the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 4, 5, and 6 with the reactor vessel head on, automatic PORV OPERABILITY may be required. See LCO 3.4.12.

INSERT 3

Pressurizer PORVs B 3.4.11 BRAIDWOOD UNITS 1 & 2 B 3.4.11 7 Revision 0 BASES ACTIONS (continued)

E.1 and E.2 If two PORVs are inoperable and not capable of being manually cycled, Condition B and its associated Required Actions would already be entered. The Required Actions would either restore at least one valve within the Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or isolate the flow path by closing and removing the power to the associated block valves. The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time and provides the operator time to correct the situation. If no PORVs are restored within the Completion Time, then the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 4, 5, and 6 with the reactor vessel head on, automatic PORV OPERABILITY may be required. See LCO 3.4.12.

F.1 If two block valves are inoperable, it is necessary to restore at least one block valve within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The Completion Time is reasonable, based on the small potential for challenges to the system during this time and provide the operator time to correct the situation.

G.1 and G.2 If the Required Actions of Condition F are not met, the unit must be brought to a MODE in which the LCO does not apply.

To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 4, 5, and 6 with the reactor vessel head on, automatic PORV OPERABILITY may be required. See LCO 3.4.12.

INSERT 4

INSERT 3 The Required Actions C.1 and C.2 are modified by a Note stating that the Required Actions do not apply if the sole reason for the block valve being declared inoperable is as a result of power being removed to comply with other Required Actions. In this event, the Required Actions for inoperable PORV(s) (which require the block valve power to be removed once it is closed) are adequate to address the condition. While it may be desirable to also place the PORV(s) in manual control, this may not be possible for all causes of Condition B entry with PORV(s) inoperable and not capable of being manually cycled (e.g., as a result of failed control power fuse(s) or control switch malfunction(s).)

INSERT 4 The Required Action F.1 is modified by a Note stating that the Required Action does not apply if the sole reason for the block valve being declared inoperable is as a result of power being removed to comply with other Required Actions. In this event, the Required Actions for inoperable PORV(s) (which require the block valve power to be removed once it is closed) are adequate to address the condition. While it may be desirable to also place the PORV(s) in manual control, this may not be possible for all causes of Condition B entry with PORV(s) inoperable and not capable of being manually cycled (e.g., as a result of failed control power fuse(s) or control switch malfunction(s).)

Markup of Byron Technical Specifications Page Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 REVISED TECHNICAL SPECIFICATIONS PAGE 3.4.11-2

Pressurizer PORVs 3.4.11 BYRON UNITS 1 & 2 3.4.11 2 Amendment 212 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One block valve inoperable.

C.1 Place associated PORV in manual control.

AND C.2 Restore block valve to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours OR In accordance with the Risk Informed Completion Time Program D. Required Action and associated Completion Time of Condition A, B, or C not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours E. Two PORVs inoperable and not capable of being manually cycled.

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours F. Two block valves inoperable.

F.1 Restore one block valve to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months G. Required Action and associated Completion Time of Condition F not met.

G.1 Be in MODE 3.

AND G.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours INSERT 1 INSERT 2

INSERT 1

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

Required Actions C.1 and C.2 do not apply when block valve is inoperable solely as a result of complying with Required Action B.2.

INSERT 2

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

Required Action F.1 does not apply when block valve is inoperable solely as a result of complying with Required Action B.2.

Markup of Byron Technical Specifications Bases Pages Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.4.11-6 B 3.4.11-7

Pressurizer PORVs B 3.4.11 BYRON UNITS 1 & 2 B 3.4.11 6 Revision 115 BASES ACTIONS (continued)

Because at least one PORV remains OPERABLE, the operator is permitted a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the inoperable block valve to OPERABLE status. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. The time allowed to restore the block valve is based upon the Completion Time for restoring an inoperable PORV in Condition B, since the PORVs may not be capable of mitigating an event if the inoperable block valve is not full open. If the block valve is restored within the Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the power will be restored, and the PORV restored to OPERABLE status. If it cannot be restored within this additional time, the unit must be brought to a MODE in which the LCO does not apply, as required by Condition D.

D.1 and D.2 If the Required Action of Condition A, B, or C is not met, then the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 4, 5, and 6 with the reactor vessel head on, automatic PORV OPERABILITY may be required. See LCO 3.4.12.

INSERT 3

Pressurizer PORVs B 3.4.11 BYRON UNITS 1 & 2 B 3.4.11 7 Revision 0 BASES ACTIONS (continued)

E.1 and E.2 If two PORVs are inoperable and not capable of being manually cycled, Condition B and its associated Required Actions would already be entered. The Required Actions would either restore at least one valve within the Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or isolate the flow path by closing and removing the power to the associated block valves. The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time and provides the operator time to correct the situation. If no PORVs are restored within the Completion Time, then the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 4, 5, and 6 with the reactor vessel head on, automatic PORV OPERABILITY may be required. See LCO 3.4.12.

F.1 If two block valves are inoperable, it is necessary to restore at least one block valve within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The Completion Time is reasonable, based on the small potential for challenges to the system during this time and provide the operator time to correct the situation.

G.1 and G.2 If the Required Actions of Condition F are not met, the unit must be brought to a MODE in which the LCO does not apply.

To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 4, 5, and 6 with the reactor vessel head on, automatic PORV OPERABILITY may be required. See LCO 3.4.12.

INSERT 4

INSERT 3 The Required Actions C.1 and C.2 are modified by a Note stating that the Required Actions do not apply if the sole reason for the block valve being declared inoperable is as a result of power being removed to comply with other Required Actions. In this event, the Required Actions for inoperable PORV(s) (which require the block valve power to be removed once it is closed) are adequate to address the condition. While it may be desirable to also place the PORV(s) in manual control, this may not be possible for all causes of Condition B entry with PORV(s) inoperable and not capable of being manually cycled (e.g., as a result of failed control power fuse(s) or control switch malfunction(s).)

INSERT 4 The Required Action F.1 is modified by a Note stating that the Required Action does not apply if the sole reason for the block valve being declared inoperable is as a result of power being removed to comply with other Required Actions. In this event, the Required Actions for inoperable PORV(s) (which require the block valve power to be removed once it is closed) are adequate to address the condition. While it may be desirable to also place the PORV(s) in manual control, this may not be possible for all causes of Condition B entry with PORV(s) inoperable and not capable of being manually cycled (e.g., as a result of failed control power fuse(s) or control switch malfunction(s).)

Markup of Ginna Technical Specifications Pages R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 REVISED TECHNICAL SPECIFICATIONS PAGES 3.4.11-2 3.4.11-3

Pressurizer PORVs 3.4.11 CONDITION REQUIRED ACTION COMPLETION TIME AND B.3.2.2 Restore PORV to OPERABLE status 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR

NOTE------

Not applicable if there is a loss of function.

In accordance with the Risk Informed Completion Time Program C.

One block valve inoperable.

C.1 Place associated PORV in manual control.

AND C.2.1 Restore block valve to OPERABLE status.

OR C.2.2.1 Verify Opposite Train PORV and PORV Block Valve are OPERABLE AND C.2.2.2 Restore PORV Block Valve to OPERABLE status 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 7 days 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 7 days OR

NOTE------

Not applicable if there is a loss of function.

In accordance with the Risk Informed Completion Time Program R.E. Ginna Nuclear Power Plant 3.4.11-2 Amendment 150 INSERT 5

Pressurizer PORVs 3.4.11 CONDITION REQUIRED ACTION COMPLETION TIME D.

Both block valves inoperable.

D.1 Place associated PORVs in manual control.

AND D.2 Restore at least one block valve to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours E.

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

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours F.

Two PORVs inoperable.

F.1 Initiate action to restore one PORV to OPERABLE status.

AND F.2 Close associated block valves.

AND F.3 Remove power from associated block valves.

AND F.4 Be in MODE 3 with Tavg

< 500qF.

Immediately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months R.E. Ginna Nuclear Power Plant 3.4.11-3 Amendment 150 INSERT 6

INSERT 5

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

Required Actions C.1 and C.2 do not apply when block valve is inoperable solely as a result of complying with Required Action B.2 or F.3.

INSERT 6

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

Required Actions D.1 and D.2 do not apply when block valve is inoperable solely as a result of complying with Required Action B.2 or F.3.

Markup of Ginna Technical Specifications Bases Page R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 REVISED TECHNICAL SPECIFICATIONS BASES PAGE B 3.4.11-5

B 3.4.11-5 Revision 107 R.E. Ginna Nuclear Power Plant Pressurizer PORVs B 3.4.11 If the RICT does not apply for an inoperable PORV, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is provided to restore the inoperable PORV to OPERABLE status. If the PORV cannot be restored within this time, the plant must be brought to a MODE in which the LCO does not apply, as required by Condition E.

If the RICT does not apply for an inoperable PORV Block Valve, the operator is permitted a Completion Time of 7 days to restore the inoperable block valve to OPERABLE status. The time allowed to restore the block valve is limited to 7 days since the PORVs are not capable of automatically mitigating an overpressure event when placed in manual control. If the block valve is restored within the Completion Time of 7 days, the PORV will again be capable of automatically responding to an overpressure event, and the block valves capable of isolating a stuck open PORV which may result from the overpressure event. If it cannot be restored within this additional time, the plant must be brought to MODE in which the LCO does not apply, as required by Condition E.

D.1 and D.2 If both block valves are inoperable, then it is necessary to either restore at least one block valve to OPERABLE status within the Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or place the PORVs in manual control. The prime importance for the capability to close the block valve is to isolate a stuck open PORV.

Therefore, if the block valves cannot be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the Required Action is to place the PORVs in manual control to preclude its automatic opening for an overpressure event and to avoid the potential for a stuck open PORV at a time that the block valve is inoperable. Manual control is accomplished by placing the PORV control board switch in the closed position. The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time period, and provides the operator time to correct the situation. Because the PORV is not capable of automatically opening and the small potential for an SGTR or other event requiring Manual operation, the operator is permitted a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or as permitted by RICT, to restore at least one inoperable block valve to OPERABLE status. The time allowed to restore one block valve is limited since the PORVs are not capable of automatically mitigating an overpressure event when placed in manual control. If at least one block valve is restored within the determined Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , at least one PORV will again be capable of automatically responding to an overpressure event, and the associated block valve capable of isolating a stuck open PORV which may result from the overpressure event. If it cannot be restored within this additional time, the plant must be brought to a MODE in which the LCO does not apply, as required by Condition E.

INSERT 7 INSERT 8

INSERT 7 The Required Actions C.1 and C.2 are modified by a Note stating that the Required Actions do not apply if the sole reason for the block valve being declared inoperable is as a result of power being removed to comply with other Required Actions. In this event, the Required Actions for inoperable PORV(s) (which require the block valve power to be removed once it is closed) are adequate to address the condition. While it may be desirable to also place the PORV(s) in manual control, this may not be possible for all causes of Condition B or F entry with PORV(s) inoperable and not capable of being manually cycled (e.g., as a result of failed control power fuse(s) or control switch malfunction(s).)

INSERT 8 The Required Actions D.1 and D.2 are modified by a Note stating that the Required Actions do not apply if the sole reason for the block valve being declared inoperable is as a result of power being removed to comply with other Required Actions. In this event, the Required Actions for inoperable PORV(s) (which require the block valve power to be removed once it is closed) are adequate to address the condition. While it may be desirable to also place the PORV(s) in manual control, this may not be possible for all causes of Condition B or F entry with PORV(s) inoperable and not capable of being manually cycled (e.g., as a result of failed control power fuse(s) or control switch malfunction(s).)

RS-25-019, Stations - License Amendment Request to Adopt TSTF-309, Revise Pressureizer PORV Actions Not to Require Cycling of Block Vlave When Closed for Isolation, Revision 2

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RS-25-019, Stations - License Amendment Request to Adopt TSTF-309, Revise Pressureizer PORV Actions Not to Require Cycling of Block Vlave When Closed for Isolation, Revision 2

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Subject:

Subject:

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4.0 REGULATORY EVALUATION

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3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

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