JAFP-25-0046, License Amendment Request - Proposed Change to the Technical Specifications to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation

License Amendment Request - Proposed Change to the Technical Specifications to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation

ML25248A291
Person / Time
Site:	FitzPatrick
Issue date:	09/05/2025
From:	Knowles J Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
JAFP-25-0046
Download: ML25248A291 (1)

Text

200 Energy Way Kennett Square, PA 19348 www.constellation.com 10 CFR 50.90 JAFP-25-0046 September , 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

License Amendment Request - Proposed Change to the Technical Specifications to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-59 for James A.

FitzPatrick Nuclear Power Plant (JAF).

The proposed changes revise the JAF TS Allowable Value for Reactor Water Cleanup (RWCU)

System isolation on low Reactor Pressure Vessel (RPV) water level from Level 3 ( 177 inches) to Level 2 ( 107 inches) in Table 3.3.6.1-1 Primary Containment Isolation Instrumentation. JAF TS Table 3.3.5.2-1 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation is revised to be consistent with the modified Table 3.3.6.1-1.

The proposed changes have been reviewed by the JAF Plant Operations Review Committee in accordance with the requirements of the CEG Quality Assurance Program.

This letter contains no new regulatory commitments.

CEG has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92, "Issuance of amendment." provides the evaluation of the proposed changes. Attachment 2 provides a copy of the marked-up TS pages that reflect the proposed changes. Attachment 3 provides a copy of the marked-up TS Bases for information only. Attachment 4 provides Technical Specification Bases Pages Summarizing Setpoint Methodology for information only.

CEG requests approval of the proposed amendment by August 31, 2026, on NRC approval, the amendment shall be implemented within 90 days of issuance.

License Amendment Request RWCU RPV Water Level Isolation Setpoint Docket No. 50-333 September , 2025 Page 2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

CEG is notifying the State of New York of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

Should you have any questions concerning this letter, please contact Michael Henry at (267)533-5382.

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

Respectfully, Justin Knowles Sr. Manager - Licensing Constellation Energy Generation, LLC Attachments:

1.

Evaluation of Proposed Changes 2.

Markup of Proposed Technical Specification Pages 3.

Markup of Proposed Technical Specification Bases (For Information Only) 4.

Technical Specification Bases Pages Summarizing Setpoint Methodology cc:

USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, JAF USNRC Project Manager, JAF A. Kauk, NYSPSC A.L. Peterson, NYSERDA

Knowles, Justin W Digitally signed by Knowles, Justin W Date: 2025.09.05 12:50:34

-04'00'

ATTACHMENT 1 License Amendment Request James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 EVALUATION OF PROPOSED CHANGES

Subject:

License Amendment Request - Proposed Change to the Technical Specifications to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation 1.0

SUMMARY

DESCRIPTION

1.1 Background

2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration 4.3 Conclusions

6.0 REFERENCES

License Amendment Request Evaluation of Proposed Changes Docket No. 50-333 1

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), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed changes revise the JAF TS Allowable Value for Reactor Water Cleanup (RWCU)

System isolation on low Reactor Pressure Vessel (RPV) water level from Low Level 3 ( 177 inches) to Low Low Level 2 ( 107 inches) in Table 3.3.6.1-1 Primary Containment Isolation Instrumentation. In addition, TS Table 3.3.5.2-1 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation is revised to be consistent with the modified Table 3.3.6.1-1.

1.1 Background

The proposed change is similar to the License Amendment Request (LAR) submitted in reference 1. Due to the COVID-19 pandemic, the LAR was withdrawn in a letter to the NRC on July 28, 2020, (reference 8) to minimize the amount of personnel on site during the Refueling Outage (RFO) in the fall of 2020. The NRC acknowledged the withdrawal of the LAR in a letter on August 5, 2020 (reference 9). A significant amount of review for the LAR was complete and should be usable to support the review of this proposed change.

The LAR was supplemented on November 6, 2019, in reference 3 as requested by the NRC in reference 2. The supplemental information provided in reference 3 includes the calculation for the revised allowable value for the RWCU system isolation as well as information that supports using 107 inches for the level 2 setpoint. The calculations included in reference 3 require revision that is described below. The information in the supplement is valid and should be used for the review in support of this proposed change along with the description of the change to the calculations. The previously submitted LAR (reference 1) received two Requests for Additional Information (RAIs) reference 4 and reference 5. The RAI responses reference 6 and reference 7 have been reviewed and support this LAR, as such they should be used for the review of the proposed change.

2.0 DETAILED DESCRIPTION The proposed changes address issues related to initiation of RWCU System isolation at the same RPV water level as the Reactor Protection System (RPS) low RPV water level trip. RWCU System isolation coincident with reactor scram can complicate post-trip recovery due to the inability to reject water from the RPV bottom head region if the system cannot be quickly restored to service. Inability to remove water from the bottom head can lead to thermal stratification as the result of inflow of cold water through the Control Rod Drives.

Implementation of this change will involve installation of new trip units associated with RPV wide range water level transmitters to develop a trip signal for incorporation in the existing logic circuits for the isolation valves. This change is required since the existing logic is supplied from trip units associated with RPV narrow range level transmitters. The range of the narrow range transmitters is insufficient to support the desired lower nominal trip setpoint.

License Amendment Request Evaluation of Proposed Changes Docket No. 50-333 2

Proposed Revision to Table 3.3.6.1-1:

Function 5.e in Table 3.3.6.1-1:, Reactor Water Cleanup (RWCU) System Isolation, Reactor Vessel Water Level - Low (Level 3) is changed to Reactor Vessel Water Level - Low Low (Level 2); and, Allowed Value is changed from 177 inches to 107 inches.

The purpose of the proposed change is to separate the RWCU System Isolation on low RPV water level from the reactor scram on the same parameter to facilitate improved control of RPV water level and bottom head temperature post-trip.

Proposed Revision to Table 3.3.5.2-1:

Function 2.a in Table 3.3.5.2-1:, Reactor Water Cleanup (RWCU) System Isolation, Reactor Vessel Water Level - Low Level 3 is changed to Reactor Vessel Water Level - Low Low (Level 2); and, the Allowed Value is changed from 177 inches to 107 inches.

Note: Parenthesis are added for format consistency around Level 2 for Function 2.a and Level 3 for Function 1.a Reactor Vessel Water Level - Low (Level 3).

The purpose of the proposed change is to maintain consistency between TS Tables 3.3.6.1-1 and 3.3.5.2-1.

3.0 TECHNICAL EVALUATION

Primary containment isolation instrumentation automatically initiates closure of Primary Containment Isolation Valves (PCIVs). PCIVs in conjunction with other accident mitigation systems limit fission product release during and following postulated Design Basis Accidents (DBAs). The low RPV water level signal is a diverse signal indicating that the capability to cool the fuel may be threatened. Isolation of the system on this signal potentially limits reactor coolant loss for breaks located in the RWCU system outside of the Primary Containment (see below for further discussion). RWCU isolation on low RPV water level is not directly assumed in Updated Final Safety Analysis Report (UFSAR) safety analyses since the effects of a RWCU line break are bounded by breaks in larger piping systems such as Reactor Water Recirculation (RWR) and Main Steam.

The primary RWCU System flow path is from the RWR System with a secondary path from the RPV bottom head drain. Breaks in RWCU piping are considered as part of the RWR pipe break spectrum analysis. The volume of water in the RWCU system is a small fraction of that contained in the RWR piping and RPV lower plenum. Any effect of this additional water on Peak Cladding Temperature is negligible, even without RWCU System isolation. The Emergency Core Cooling System - Loss of Coolant Accident (ECCS-LOCA) analysis methodology does not include assumption of RWCU isolation, nor include the water in the RWCU system for breaks inside of containment. Therefore, changing the RPV water level setpoint for RWCU isolation has no effect on the ECCS-LOCA analysis.

The bounding break for containment analysis is a double-ended guillotine break of an RWR suction line. If not isolated, a small additional source of hot water is available from the piping between the inboard isolation valve and the check valves at the discharge of the RWCU pumps.

This mass of water could be added to the RPV for non-recirculation line breaks, or directly to Primary Containment for RWCU or RWR line breaks. This mass and energy will ultimately be transported to the Suppression Pool and contribute an additional rise in pool temperature of less

License Amendment Request Evaluation of Proposed Changes Docket No. 50-333 3

than 0.1°F assuming no RWCU System isolation. This small change is bounded by conservatisms in the containment analysis methods and assumptions, or conservatisms in other inputs. As such, there is no significant effect on containment response.

Level Setpoint Analyses supporting JAF operation utilize two values for the RPV Level 2 Analytical Limit dependent on application. The higher of the two values is used for initiation of the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) Systems, while the lower value is used for Anticipated Transient Without Scram - Recirculation Pump Trip (ATWS-RPT) initiation (as well as for initiation of Alternate Rod Injection, ARI). Use of staggered limits (and associated setpoints) provides an opportunity for HPCI and/or RCIC to restore RPV water level during slow moving transients without further actions that would complicate transient response (including RWCU isolation). Allowable Values associated with each Analytical Limit is dependent on instrumentation characteristics and may differ between functions. A normal scram results in RPV level lowering below initiation setpoints required to support a 126.5 allowable value, but well above the new setpoint of RWCU. A level below 126.5 was selected to prevent isolation of the RWCU system during a normal scram.

Instrument Analyses supporting JAF operation utilize two values for the RPV Level 2 Analytical Limit dependent on application. The higher of the two values is used for initiation of the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) Systems, while the lower value is used for Anticipated Transient Without Scram-Recirculation Pump Trip (ATWS-RPT) initiation (as well as for initiation of Alternate Rod Injection (ARI)). The analysis supporting this License Amendment Request also used the lower of the two Analytical Limits. Use of staggered limits (and associated setpoints) provides an opportunity for HPCI and/or RCIC to restore RPV water level during slow moving transients without further actions that would complicate transient response. Allowable Values associated with each Analytical Limit is dependent on instrumentation characteristics and may differ between functions.

Rosemount Static Pressure Effect is divided into two effects: a Static Pressure Zero Effect, which is a random uncertainty, and a Static Pressure Span Effect, which is a biased uncertainty that can be calibrated out. If the Static Pressure Span Effect bias is accounted for, the random uncertainty is as described in the product data sheet and manual. If the bias is not accounted for, the Static Pressure Span Effect includes the bias and random uncertainties.

At JAF, the static pressure span correction has been included in the calibration endpoints for all Rosemount Transmitters according to JAF calibration process. Therefore, the Static Pressure Zero Effect is treated as a random uncertainty.

Calculation Change Setpoint calculations were previously submitted in reference 3 as,

• : JAF-CALC-NBI-00205, Setpoint Calculation for Vessel Lo-Lo LVL Primary Containment Isolation Function (02-3LT-57A,B and 02-3STU-258A,B), Revision 0, and

• : JAF-CALC-NBI-00206, Setpoint Calculation for Vessel Lo-Lo LVL Primary Containment Isolation Function (02-3LT-58A, B and 02-3STU-259A,B) Revision 0.

They would have been implemented with the LAR, if it were approved.

License Amendment Request Evaluation of Proposed Changes Docket No. 50-333 4

After withdrawing the LAR in 2020, a change was performed in accordance with the Surveillance Frequency Control Program (SFCP) to extend the calibration frequency of these level transmitters. This was accomplished by utilizing actual recorded drift values (Determined Drift) for transmitters installed in the plant as opposed to the values provided by the vendor specification. Therefore, the calculations provided above are affected by the SFCP change. This change will be incorporated into the calculations prior to implementing this LAR.

Preliminary analysis of the impact of the SFCP changes to the Determined Drift (DDR) will move the Calculated Allowable Value (CAV) closer to the Analytical Limit while maintaining margin.

The Allowable Value will remain unchanged at the current value of 107 inches to ensure the Analytical Limit is not challenged during operation.

Environmental parameters for normal radiation dose value changed as a result of the incorporation of GNF3 fuel. The dose value is reference only and is not used in the calculation and thus has no impact on the conclusion of the calculation as provided in reference 3 since it is assumed to be calibrated out on a periodic basis.

High Energy Line Break (HELB)

Environmental Qualification of Electrical Equipment outside of Primary Containment includes consideration of RWCU High Energy Line Breaks (HELB). The JAF HELB analysis is based on system isolation due to high area temperatures in spaces enclosing postulated break locations.

No credit is taken for isolation on low RPV water level in these analyses, therefore lowering of the Allowable Value for the isolation setpoint can have no effect on analyzed HELB response.

The Rosemount level transmitters that are used to isolate RWCU on RPV level are not credited in mitigating HELB and the normal radiation effect can be considered negligible since it is assumed to be calibrated out on a periodic basis.

Other changes The proposed change to revise the JAF TS Allowable Value for RWCU system isolation on low RPV water level does not result in any changes to the existing manual operator actions and does not introduce any new manual operator actions associated with the action to isolate Primary Containment. Existing Emergency Operating Procedures (EOP) require a Licensed Operator to verify system isolations occur as designed. Furthermore, procedure for Operator Response Time Program at JAF does not include any time critical or time sensitive actions for verifying or manually isolating RWCU.

No significant changes to operator training are required. Operators will be trained to the new setpoint but actions and plant response will not change requiring new training.

RPV Water Inventory Control Instrumentation An evaluation was performed to determine the impact of lowering the setpoint in Table 3.3.5.2-1 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation Function 2.a.,

Reactor Water Cleanup (RWCU) System Isolation Reactor Vessel Water Level - Low Level 3 to Reactor Vessel Water Level - Low Low (Level 2) 107 inches. The effects of shear to the 6 RWCU supply line, draining the vessel outside containment, and the time required to isolate the line utilizing 12MOV-15 (RWCU supply inboard isolation valve), 12MOV-18 (RWCU supply

License Amendment Request Evaluation of Proposed Changes Docket No. 50-333 5

outboard isolation valve), and 12MOV-69 (RWCU return containment isolation valve), were evaluated. The evaluation provides reasonable assurance that the RWCU isolation valves will have sufficient time to automatically close and isolate the RWCU system prior to water level reaching the top of active fuel with the lowered isolation input signal of 107 inches.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The following regulatory requirements have been considered:

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, "Technical specifications,"

in which the Commission established its regulatory requirements related to the contents of the TS. Specifically, 10 CFR 50.36(c)(2)(i) states, in part, "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility." 10 CFR 50.36(c)(2)(ii) states, "A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria:" 10 CFR 50.36(c)(2)(ii)(A) states, Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

The proposed changes to the Primary Containment Isolation and RPV Water Inventory Control Instrumentation Allowable Values do not affect compliance with these regulations.

The applicable 10 CFR Part 50, Appendix A, General Design Criteria (GDC), were considered as follows:

Criterion 13 - Instrumentation and control. Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

The proposed change maintains RPV water level as a parameter monitored to detect degradation of the Reactor Coolant Pressure Boundary and initiate action to isolate Primary Containment to limit fission product release. The instrumentation used to perform the RWCU isolation function will be the JAF Analog Transmitter Trip System (ATTS) that includes redundant Reactor vessel wide range level transmitters, Master Trip Units and Slave Trip Units.

The use of ATTS assures an acceptable operating range and takes advantage of existing surveillance requirements as specified with the Technical Specifications.

Criterion 20 - Protective system functions. The protection system shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.

License Amendment Request Evaluation of Proposed Changes Docket No. 50-333 6

The proposed change senses RPV water level to detect degradation of the Reactor Coolant Pressure Boundary and initiate action to isolate Primary Containment to limit fission product release.

The proposed Allowable Value is based on new setpoint and uncertainty calculations. These calculations utilize the methodology as described within the Technical Specification Bases Revision 62 section B.3.3.6.1 and as referenced within section B.3.3.5.2 (attachment 4). This methodology was reviewed by the NRC during the JAF conversion to Improved Technical Specifications and utilizes an Analytical Limit that ensures the Safety Limit is not exceeded. The Nominal Trip Setpoint is selected to assure the proposed Allowable Value is not exceeded. The RWCU isolation function will be performed using the JAF ATTS thus the instrument loop error and calibration limits (As Found and As Left) are calculated consistent with the other JAF ATTS uncertainty calculations.

Criterion 22 - Protection system independence. The protection system shall be designed to assure that the effects of natural phenomena, and of normal operating, maintenance, testing, and postulated accident conditions on the redundant channels do not result in loss of the protection function or shall be demonstrated to be acceptable on some other defined basis.

Design techniques, such as functional diversity in component design and principles of operation, shall be used to the extent practical to prevent loss of the protection function.

The proposed change continues to use RPV water level to detect degradation of the Reactor Coolant Pressure Boundary and initiate action to isolate Primary Containment to limit fission product release. This is a signal diverse from monitoring drywell pressure to accomplish the same purposes.

Criterion 24 - Separation of protection and control systems. The protection system shall be separated from control systems to the extent that failure of any single control system component or channel, or failure or removal from service of any single protection system component or channel which is common to the control and protection systems leaves intact a system satisfying all reliability, redundancy, and independence requirements of the protection system.

Interconnections of the protection and control systems shall be limited so as to assure that safety is not significantly impaired.

The proposed change maintains RPV water level as a parameter monitored to detect degradation of the Reactor Coolant Pressure Boundary and initiate action to isolate Primary Containment to limit fission product release. The revised system configuration is consistent with the current design in use of separate level transmitters processed through analog trip units to generate signals further processed by relay logic to initiate RWCU isolation valve motion.

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), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed changes revise the JAF TS Allowable Value for Reactor Water Cleanup (RWCU)

System isolation on low Reactor Pressure Vessel (RPV) water level from Level 3 ( 177 inches) to Level 2 ( 107 inches) in Table 3.3.6.1-1 Primary Containment Isolation Instrumentation.

License Amendment Request Evaluation of Proposed Changes Docket No. 50-333 7

JAF TS Table 3.3.5.2-1 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation is revised to be consistent with the modified Table 3.3.6.1-1.

1.

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

Response: No RWCU System isolation on changing RPV water level is a response to an accident, rather than an initiator, therefore changing the Allowable Value at which this is accomplished has no effect on the probability of occurrence.

The fuel peak cladding temperature response to line breaks the RWCU low RPV water level isolation mitigates are bounded by Reactor Water Recirculation and Main Steam line breaks, therefore there is no increase in consequences of these accidents as a result of lowering the Allowable Value for the isolation.

There may be a small increase in peak suppression pool temperature as a result of lowering the RWCU low RPV water level isolation Allowable Value. This potential effect is bounded by conservative modeling assumptions, inputs, and methods and is insignificant.

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

2.

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

Response: No Implementation of the proposed amendment will require installation of new trip units to develop signals for input to the RWCU isolation logic utilizing RPV wide range water level transmitters instead of the narrow range transmitters currently used. This will not alter the principles of operation of the system, therefore no new failure modes or mechanisms are introduced.

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

3.

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

Response: No Lowering the Allowable Value for the RWCU isolation on RPV water level from Low (Level 3) to Low Low (Level 2) will introduce a small delay in isolation valve closure for line breaks within Primary Containment. The LOCA radiological analysis assumes no specific closure time for Primary Containment Isolation Valves, therefore there can be no effect on this safety margin.

As stated previously, the change in Allowable Value has an insignificant effect on peak suppression pool temperature, therefore there is also no significant reduction in margin of safety for this parameter.

License Amendment Request Evaluation of Proposed Changes Docket No. 50-333 8

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

Based on the above evaluation, CEG concludes that the proposed amendment presents no 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 amendments will not be inimical to the common defense and security or the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

CEG has determined that the proposed changes 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 changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, in accordance with 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.

6.0 REFERENCES

1.

James A. FitzPatrick Nuclear Power Plant, "Proposed Change to the Technical Specification to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation," JAFP-19-0083, dated September 5, 2019 (ML19248B085)

2.

James A. FitzPatrick Nuclear Power Plant, "FitzPatrick Supplemental Information Needed for Acceptance: Revise Allowable Value for Reactor Water Cleanup System Primary Containment Isolation (EPID L-2019-LLA-0190)," dated October 18, 2019 (ML19291A035)

3.

James A. FitzPatrick Nuclear Power Plant, " Response to Request for Supplemental Information by the Office of Nuclear Reactor Regulation to support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU)

System Primary Containment Isolation," JAFP-19-0105, dated November 6, 2019 (ML19310D579)

4.

James A. FitzPatrick Nuclear Power Plant, "FitzPatrick request for additional information:

License Amendment Request for Change to the Technical Specifications to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation," dated January 23, 2020 (ML20027A011)

5.

NRC letter, FitzPatrick request for additional information: License Amendment Request for Change to the Technical Specifications to Revise the Allowable Value for Reactor

License Amendment Request Evaluation of Proposed Changes Docket No. 50-333 9

Water Cleanup (RWCU) System Primary Containment (EPID: L-2019-LLA-0190), dated March 5, 2020 (ML20066L368)

6.

JAF letter, Response to Request for Additional Information to Support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation, JAFP-20-0020, dated February 21, 2020 (ML20052E056)

7.

JAF letter, Response to Request for Additional Information to Support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation, JAFP-20-0026, dated March 31, 2020 (ML20091F513)

8.

JAF letter, Withdrawal of License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation, JAFP-20-2020, dated July 28, 2020 (ML20210M333)

9.

NRC letter, James A. FitzPatrick Nuclear Power Plant - Withdrawal of an Amendment Request (EPID L-2019-LLA-0190), dated August 5, 2020 (ML20216A374)

License Amendment Request Evaluation of Proposed Changes Docket No. 50-333 ATTACHMENT 2 License Amendment Request James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Markup of Proposed Technical Specification Pages

Subject:

License Amendment Request - Proposed Change to the Technical Specifications to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation REVISED TECHNICAL SPECIFICATIONS PAGES 3.3.5.2-4 3.3.6.1-10

RPV Water Inventory Control Instrumentation 3.3.5.2 JAFNPP 3.3.5.2-4 Amendment 345 Table 3.3.5.2-1 (page 1 of 1)

Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION ALLOWABLE VALUE 1.

RHR System Isolation a.

Reactor Vessel Water Level - Low (Level 3)

(a) 2 in one trip system

> 177 inches 2.

Reactor Water Cleanup (RWCU) System Isolation a.

Reactor Vessel Water Level - Low Low (Level 32)

(a) 2 in one trip system

> 177 107 inches (a) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

Primary Containment Isolation Instrumentation 3.3.6.1 JAFNPP 3.3.6.1-10 Amendment 357 Table 3.3.6.1-1 (page 5 of 6)

Primary Containment Isolation Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER TRIP SYSTEM CONDITIONS REFERENCED FROM REQUIRED ACTION C.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

5.

Reactor Water Cleanup (RWCU)System Isolation

a. RWCU Suction Line Penetration Area Temperature - High 1,2,3 1

F SR 3.3.6.1.3 SR 3.3.6.1.7 144°F

b. RWCU Pump Area Temperature - High 1,2,3 1 per room F

SR 3.3.6.1.3 SR 3.3.6.1.7 165°F for Pump Room A and 175°F for Pump Room B

c.

RWCU Heat Exchanger Room Area Temperature - High 1,2,3 1

F SR 3.3.6.1.3 SR 3.3.6.1.7 155°F

d. SLC System Initiation 1,2,3 2(d)

I SR 3.3.6.1.7 NA

e. Reactor Vessel Water Level - Low Low (Level 23) 1,2,3 2

F SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.7 177107 inches

f.

Drywell Pressure -

High 1,2,3 2

F SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.7 2.7 psig

6.

Shutdown Colling System Isolation

a. RCIC Steam Line Flow - High 1,2,3 1

F SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.7 74 psig

b. RCIC Steam Supply Line Pressure - Low 3

2 J

SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.1.1.7 177 inches (continued)

(d) SLC System Initiation only inputs into one of the two trip systems and only isolates one valve in the RWCU suction and return line.

License Amendment Request Evaluation of Proposed Changes Docket No. 50-333 ATTACHMENT 3 License Amendment Request James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Markup of Proposed Technical Specification Bases Pages

Subject:

License Amendment Request - Proposed Change to the Technical Specifications to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.3.5.2-2 B 3.3.5.2-3 B 3.3.5.2-4 B 3.3.6.1-4 B 3.3.6.1-18 B 3.3.6.1-19

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES JAFNPP B 3.3.5.2-2 Revision 52 The purpose of the RPV Water Inventory Control Instrumentation is to support the requirements of LCO 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control, and the definition of DRAIN TIME.

There are functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

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

A double-ended guillotine break of the Reactor Coolant System (RCS) is not considered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems.

Instead, an event is considered in which an initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure. It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety. Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy.

RHR System Isolation 1.a - Reactor Vessel Water Level - Low, (Level 3)

The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low, (Level 3)

Function associated with RHR System isolation may be credited for automatic isolation of penetration flow paths associated with the RHR System.

(continued)

BACKGROUND (continued)

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES JAFNPP B 3.3.5.2-3 Revision 52 1.a - Reactor Vessel Water Level - Low, (Level 3) (continued)

Reactor Vessel Water Level - Low, (Level 3) signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.

While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low, (Level 3) Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low, (Level 3) Allowable Value was chosen to be the same as the Primary Containment Isolation Instrumentation Reactor Vessel Water Level - Low, Level 3 Allowable Value (LCO 3.3.6.1), since the capability to cool the fuel may be threatened.

The Reactor Vessel Water Level - Low, (Level 3) Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. This Function isolates the Group 11 valves.

Reactor Water Cleanup (RWCU) System Isolation 2.a - Reactor Vessel Water Llevel - Low Low, (Level 32)

The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low Low (Level

23) Function associated with RWCU System isolation may be credited for automatic isolation of penetration flow paths associated with the RWCU System.

Reactor Vessel Water Level - Low Low, (Level 32) signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.

While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low Low (Level 23) Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The HPCI (Table 3.3.5.1-1, Function 3.a), RCIC (Table 3.3.5.3-1, Function 1), ATWS-RPT (LCO 3.3.4.1.a including SR 3.3.4.1.4), and RWCU System Isolation from Reactor Vessel Water (Table 3.3.5.2-1, Function 2.a and Table 3.3.6.1-1, Function 5.e) describe the reactor APPLICABLE SAFETY ANALYSIS, LCO, and APPLICABILITY

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES JAFNPP B 3.3.5.2-4 Revision 52 vessel water level initiation function as "Low Low (Level 2)." The Allowable Values associated with the HPCI and RCIC initiation function is different from the Allowable Value associated with the RWCU System Isolation function and from the ATWS-RPT function. RWCU System Isolation has a separate analog trip unit from each of the other functions above. Nevertheless, consistent with the nomenclature typically used in design documents, the "Low Low (Level 2)" designation is retained in describing each of these four initiation function values.The Reactor Vessel Water Level -- Low Low (Level 32) Allowable Value was chosen to be the same as the RPS Reactor Vessel Water Level - Low (Level 3) Allowable Value (LCO 3.3.1.1), since the capability to cool the fuel 2.a - Reactor Vessel Water level - Low Low, (Level 32) (continued) may be threatened. The allowable value is referenced from a level of water 352.56 inches above the lowest point in the inside bottom of the RPV and also corresponds to the top of a 144 inch fuel column (Ref 6).

The Reactor Vessel Water Level - Low Low (Level 32) Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. This Function isolates the Group 5 valves.

ACTIONS A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control instrumentation channel.

A.1 and A.2 RHR System Isolation, Reactor Vessel Water Level - Low Level 3, and Reactor Water Cleanup System, Reactor Vessel Water Level - Low, Level 3 functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating Drain Time.

APPLICABLE SAFETY ANALYSIS, LCO, and APPLICABILITY (continued)

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES JAFNPP B 3.3.6.1-4 Revision 57 3, 4. High Pressure Coolant Injection System Isolation and Reactor Core Isolation Cooling System Isolation (continued) two-out-of-two trip systems. The output of each equipment area temperature channel is connected to one trip system so that any channel will trip its associated trip system. This arrangement is consistent with all other area temperature Functions, in that any channel will trip its associated trip system.

5. Reactor Water Cleanup System Isolation The Reactor Vessel Water Level Low Low (Level 32) and Drywell Pressure High Isolation Functions (Functions 5.e and 5.f) receive input from four channels. The outputs from these channels are connected into two two-out-of-two trip systems for each function. The SLC System Initiation Function (Function 5.d) receives input from two channels, with both channels providing input to one trip system. Any channel will initiate the trip logic. The Function is initiated by placing the SLC System initiation switch in any position other than stop (start system A or start system B). Therefore, a channel is defined as the circuitry required to trip the trip logic when the switch is in position start system A or start system B. The Area Temperature High Functions (Functions 5.a, 5.b and 5.c) receive input from eight temperature monitors, four to each trip system. These are configured so that any one input will trip the associated trip system. Each of the two trip systems is connected to one of the two valves on the RWCU suction penetration and only one trip system is connected to the RWCU return penetration outboard valve. The trip system associated with the SLC System Initiation Function is connected to the outboard RWCU suction valve and the outboard RWCU return penetration valve.

6. Shutdown Cooling System Isolation The Reactor Vessel Water Level Low (Level 3) Function (Function 6.b) receives input from four reactor vessel water level channels. The outputs from the reactor vessel water level channels are connected to two two-out-of-two trip systems. Each of the two trip systems is connected to one of the two valves on the RHR shutdown cooling pump suction penetration and on one of the two inboard LPCI injection valves if in shutdown cooling mode. The Reactor Pressure High Function (Function 6.a) receives input from two channels, with each channel providing input into each trip system using a one-out-of-two logic. However, only one channel input is required to be OPERABLE for a trip system to be considered OPERABLE. Each of the two trip systems is connected to one of the two valves on the shutdown cooling pump suction penetration.

BACKGROUND (continued)

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES JAFNPP B 3.3.6.1-18 Revision 57 5.a, 5.b, 5.c. RWCU Area Temperatures High (continued) avoid spurious isolation yet low enough to provide timely detection and isolation of a break in the RWCU System.

These Functions isolates both RWCU suction valves and the return valve.

5.d. SLC System Initiation The isolation of the RWCU System is required when the SLC System has been initiated to prevent dilution and removal of the boron solution by the RWCU System (Ref. 6). The RWCU isolation signal is initiated when the control room SLC initiation switch is in any position other than stop.

There is no Allowable Value associated with this Function since the channels are mechanically actuated based solely on the position of the SLC System initiation switch.

Two channels (start system A or start system B) of the SLC System Initiation Function are available and are required to be OPERABLE only in MODES 1 and 2, since these are the only MODES where the reactor can be critical, and MODE 3 for suppression pool pH control.

These MODES are consistent with the Applicability for the SLC System (LCO 3.1.7).

As noted (footnote (d) to Table 3.3.6.1-1), this Function is only required to close one of the RWCU suction isolation valves and one return isolation valve since the signals only provide input into one of the two trip systems.

5.e. Reactor Vessel Water Level Low Low (Level 32)

Low RPV water level indicates that the capability to cool the fuel may be threatened. Should RPV water level decrease too far, fuel damage could result. Therefore, isolation of some interfaces with the reactor vessel occurs to isolate the potential sources of a break. The isolation of the RWCU System on Level 3 2 supports actions to ensure that the fuel peak cladding temperature remains below the limits of 10 CFR 50.46. The Reactor Vessel Water Level Low Low (Level 32)

Function associated with RWCU isolation is not directly assumed in the UFSAR safety analyses because the RWCU System line break is bounded by breaks of larger systems (recirculation and MSL breaks are more limiting).

Reactor Vessel Water Level Low Low (Level 32) signals are initiated from four level transmitters that sense the difference between the APPLICABLE SAFETY ANALYSIS, LCO, and APPLICABILITY (continued)

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES JAFNPP B 3.3.6.1-19 Revision 57 5.e. Reactor Vessel Water Level Low Low (Level 32) (continued) pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.

Four channels of Reactor Vessel Water Level Low Low (Level 32)

Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function.

The HPCI (Table 3.3.5.1-1, Function 3.a), RCIC (Table 3.3.5.3-1, Function 1), ATWS-RPT (LCO 3.3.4.1.a including SR 3.3.4.1.4), and RWCU System Isolation from Reactor Vessel Water (Table 3.3.5.2-1, Function 2.a and Table 3.3.6.1-1, Function 5.e) describe the reactor vessel water level initiation function as "Low Low (Level 2)." The Allowable Values associated with the HPCI and RCIC initiation function is different from the Allowable Value associated with the RWCU System Isolation function and from the ATWS-RPT function.

RWCU System Isolation has a separate analog trip unit from each of the other functions above. Nevertheless, consistent with the nomenclature typically used in design documents, the "Low Low (Level 2)" designation is retained in describing each of these four initiation function values.The Reactor Vessel Water Level Low Low (Level 32) Allowable Value was chosen to be the same as the RPS Reactor Vessel Water Level Low (Level 3) Allowable Value (LCO 3.3.1.1), since the capability to cool the fuel may be threatened.

The Allowable Value is referenced from a level of water 352.56 inches above the lowest point in the inside bottom of the RPV and also corresponds to the top of a 144 inch fuel column (Ref. 13).

This Function isolates both RWCU suction valves and the RWCU return valve.

5.f. Drywell Pressure High High drywell pressure can indicate a break in the RCPB inside the primary containment. The isolation of some of the primary containment isolation valves on high drywell pressure supports actions to ensure that offsite dose limits of 10 CFR 100 are not exceeded. The Drywell Pressure High Function, associated with isolation of the primary containment, is implicitly assumed in the UFSAR accident analysis as these leakage paths are assumed to be isolated post LOCA.

High drywell pressure signals are initiated from pressure transmitters that sense the pressure in the drywell. Four channels of Drywell Pressure High are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation APPLICABLE SAFETY ANALYSIS, LCO, and APPLICABILITY

License Amendment Request Evaluation of Proposed Changes Docket No. 50-333 ATTACHMENT 4 License Amendment Request James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Technical Specification Bases Pages Summarizing Setpoint Methodology (for information only)

Subject:

License Amendment Request - Proposed Change to the Technical Specifications to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation

RPV Water Inventory Control Instrumentation B 3.3.5.2 B 3.3 INSTRUMENTATION B 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation BASES JAFNPP B 3.3.5.2-1 Revision 52 BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the aactive irradiated fuel at all times to prevent such elevated cladding temperatures.

Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSS) for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is nnot exceeded.

Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for iinstrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The actual settings for the automatic isolation channels are the same as those established for the same functions in MODES 1, 2, and 3 in LCO 3.3.6.1, "Primary Containment Isolation instrumentation".

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

Under the definition of DRAIN TIME, some penetration flow paths may be excluded from the DRAIN TIME calculation if they will be isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation.

(continued)

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES JAFNPP B 3.3.5.2-2 Revision 52 The purpose of the RPV Water Inventory Control Instrumentation is to support the requirements of LCO 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control, and the definition of DRAIN TIME.

There are functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

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

A double-ended guillotine break of the Reactor Coolant System (RCS) is not considered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems.

Instead, an event is considered in which an initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure. It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety. Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy.

RHR System Isolation 1.a - Reactor Vessel Water Level - Low, Level 3 The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low, Level 3 Function associated with RHR System isolation may be credited for automatic isolation of penetration flow paths associated with the RHR System.

(continued)

BACKGROUND (continued)

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES JAFNPP B 3.3.6.1-5 Revision 57

7. Traversing Incore Probe System Isolation The Reactor Vessel Water Level Low (Level 3) Isolation Function receives input from two reactor vessel water level channels. The outputs from the reactor vessel water level channels are connected into one two-out-of-two logic trip system. The Drywell Pressure High Isolation function receives input from two drywell pressure channels.

The outputs from the drywell pressure channels are connected into one two-out-of-two logic trip system.

When either Isolation Function actuates, the TIP drive mechanisms will withdraw the TIPs, if inserted, and close the inboard TIP system isolation ball valves when the TIPs are fully withdrawn. The outboard TIP system isolation valves are manual shear valves.

APPLICABLE SAFETY ANALYSIS, LCO, and APPLICABILITY The isolation signals generated by the primary containment isolation instrumentation are implicitly assumed in the safety analyses of References 2 and 3 to initiate closure of valves to limit offsite doses.

Refer to LCO 3.6.1.3, "Primary Containment Isolation Valves (PCIVs),"

Applicable Safety Analyses Bases for more detail of the safety analyses.

Primary containment isolation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 4). Certain instrumentation Functions are retained for other reasons and are described below in the individual Functions discussion.

The OPERABILITY of the primary containment instrumentation is dependent on the OPERABILITY of the individual instrumentation channel Functions specified in Table 3.3.6.1-1. Each Function must have a required number of OPERABLE channels, with their setpoints within the specified Allowable Values, where appropriate. A channel is inoperable if its actual trip setpoint is not within its required Allowable Value. The actual setpoint is calibrated consistent with applicable setpoint methodology assumptions. Each channel must also respond within its assumed response time, where appropriate.

Allowable Values are specified for each Primary Containment Isolation Function specified in the Table. Nominal trip setpoints are specified in the setpoint calculations. The nominal setpoints are selected to ensure that the setpoints do not exceed the Allowable Value between CHANNEL CALIBRATIONS. Operation with a trip setpoint less conservative than the nominal trip setpoint, but within its Allowable Value, is acceptable. Trip setpoints are those predetermined values of BACKGROUND (continued)

(continued)

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES JAFNPP B 3.3.6.1-6 Revision 57 output at which an action should take place. The setpoints are compared to the actual process parameter (e.g., reactor vessel water level), and when the measured output value of the process parameter exceeds the setpoint, the associated device (e.g., trip unit) changes state. The analytic limits are derived from the limiting values of the process parameters obtained from the safety analysis or other appropriate documents. The trip setpoints are derived from the analytical limits and account for all worst case instrumentation uncertainties as appropriate (e.g., drift, process effects, calibration uncertainties, and severe environmental errors (for channels that must function in harsh environments as defined by 10 CFR 50.49)).

The trip setpoints derived in this manner provide adequate protection because all expected uncertainties are accounted for. The Allowable Values are then derived from the trip setpoints by accounting for normal effects that would be seen during periodic surveillance or calibration. These effects are instrumentation uncertainties observed during normal operation (e.g., drift and calibration uncertainties).

Certain Emergency Core Cooling Systems (ECCS) and RCIC valves (e.g., minimum flow) also serve the dual function of automatic PCIVs.

The signals that isolate these valves are also associated with the automatic initiation of the ECCS and RCIC. The instrumentation requirements and ACTIONS associated with these signals are addressed in LCO 3.3.5.1, "Emergency Core Cooling Systems (ECCS)

Instrumentation," and LCO 3.3.5.3, "Reactor Core Isolation Cooling (RCIC) System Instrumentation," and are not included in this LCO.

In general, the individual Functions are required to be OPERABLE in MODES 1, 2, and 3 consistent with the Applicability for LCO 3.6.1.1, "Primary Containment." Functions that have different Applicabilities are discussed below in the individual Functions discussion.

The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.

Main Steam Line Isolation 1.a. Reactor Vessel Water Level Low Low Low (Level 1)

Low reactor pressure vessel (RPV) water level indicates that the capability to cool the fuel may be threatened. Should RPV water level decrease too far, fuel damage could result. Therefore, isolation of the MSIVs and other interfaces with the reactor vessel occurs to prevent offsite dose limits from being exceeded. The Reactor Vessel Water Level Low Low Low (Level 1) Function is one of the many Functions assumed to be OPERABLE and capable of providing isolation signals.

The Reactor Vessel Water Level Low Low Low (Level 1) Function APPLICABLE SAFETY ANALYSIS, LCO, and APPLICABILITY (continued)

(continued)