ML25322A341

From kanterella
Jump to navigation Jump to search
Draft TSTF-608, Relocate Main Steam Line (MSL) Area Temperature Automatic Isolation Functions
ML25322A341
Person / Time
Site: Technical Specifications Task Force
Issue date: 11/18/2025
From:
Technical Specifications Task Force
To:
References
Download: ML25322A341 (0)
v • d • e


Text

TSTF-608, Rev. 0 BWROG-152, Rev. 0 NUREGs Affected:

Relocate Main Steam Line (MSL) Area Temperature Automatic Isolation Functions Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler 1430 1431 1432 1433 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement:

Improvement NRC Fee Status:

Not Exempt Benefit:

Avoids a Plant Shutdown Changes Marked on ISTS Rev 5.0 PWROG RISD & PA (if applicable): None Revision History Affected Technical Specifications OG Revision 0 Revision Status: Active Original Issue The TSTF and NRC held a presubmittal discussion on TSTF-608 on August 7, 2025. Following consideration of a question from the NRC, the traveler was revised to relocate the MSL area temperature functions to licensee control and was renamed.

Revision

Description:

Revision Proposed by:

Hatch Owners Group Review Information Date Originated by OG:

26-Sep-25 Owners Group Comments (No Comments)

Date: 10-Oct-25 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

13-Oct-25 Date Distributed for Review 13-Oct-25 TSTF Comments:

(No Comments)

Date: 03-Nov-25 TSTF Resolution:

Approved S/A 3.3.6.1 Bases Table 3.3.6.1-1 Change

Description:

Primary Containment Isolation Instrumentation LCO 3.3.6.1 Table 3.3.6.1-1 Change

Description:

Primary Containment Isolation Instrumentation Action 3.3.6.1.B Bases Table 3.3.6.1-1 Change

Description:

Primary Containment Isolation Instrumentation 18-Nov-25 Copyright(C) 2025, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

DRAFT

TSTF-608, Rev. 0 BWROG-152, Rev. 0 Bkgnd 3.3.6.1 Bases NUREG(s)- 1433 Only Table 3.3.6.1-1 Change

Description:

Primary Containment Isolation Instrumentation 18-Nov-25 Copyright(C) 2025, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

DRAFT

TSTF-608, Rev. 0 Page 1 Table of Contents Table of Contents.................................................................................................................... 1

1.

SUMMARY

DESCRIPTION............................................................................................ 2

2.

DETAILED DESCRIPTION............................................................................................ 2 2.1.

System Design and Operation.................................................................................. 2 2.2.

Current Technical Specifications Requirements...................................................... 2 2.3.

Reason for Proposed Change................................................................................... 3 2.4.

Description of the Proposed Change........................................................................ 4

3.

TECHNICAL EVALUATION.......................................................................................... 5

4.

REGULATORY EVALUATION..................................................................................... 8

5.

REFERENCES................................................................................................................... 9 Model Application DRAFT

TSTF-608, Rev. 0 Page 2

1.

SUMMARY

DESCRIPTION The proposed change revises Technical Specification (TS) 3.3.6.1, "Primary Containment Isolation Instrumentation," to relocate from the TS to licensee control the requirements for automatic Main Steam Line (MSL) isolation based on area temperature. The proposed change affects the Standard Technical Specifications (STS) in NUREG-1433 and NUREG-14341.

2. DETAILED DESCRIPTION 2.1. System Design and Operation The temperature in areas around the MSLs is monitored in order to provide an indication of small leaks in the MSLs and as a backup to the main steam high flow instrumentation. Direct measurement of small amounts of MSL leakage is not practical, so monitoring the temperature near the MSLs is used as a surrogate indication of small MSL leakage. However, no credit is taken for the temperature monitoring function in any transient or accident analysis. The bounding analyses are performed for large breaks, such as the Main Steam Line Break (MSLB).

The temperature monitoring is performed using a number of thermocouples located in the area being monitored. The areas that are monitored and the number of thermocouples used in each area vary by plant, but eight to sixty-four thermocouples is typical and the logic ensures that no single instrument failure can preclude the isolation function.

The MSL area temperature monitoring functions isolate the Group 1 primary containment isolation valves, which consists of the Main Steam Isolation Valves (MSIVs). Closure of the MSIVs causes a reactor trip by TS 3.3.1.1, "Reactor Protection System Instrumentation,"

Function 5, "Main Steam Isolation Valve - Closure."

2.2. Current Technical Specifications Requirements Limiting Condition for Operation (LCO) 3.3.6.1 requires the primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 to be operable. Table 3.3.6.1-1, Function 1, "Main Steam Line Isolation," includes:

  • Function 1.e, "Main Steam Tunnel Temperature - High,"
  • Function 1.f, "Main Steam Tunnel Differential Temperature - High," and
  • Function 1.g, "Turbine Building Area Temperature - High" (NUREG-1433 only).

These Functions are applicable in Modes 1, 2, and 3. The required channels per trip system and the Allowable Values are plant-specific and vary by Function.

1 NUREG-1433 provides the STS for BWR/4 plant designs, but is also representative of the BWR/2, BWR/3, and, in some cases, of the BWR/5 plant design.

NUREG-1434 provides the STS for BWR/6 plant designs, but is also representative in some cases of the BWR/5 plant design.

DRAFT

TSTF-608, Rev. 0 Page 3 If one or more of the required channels are inoperable, or if one or more automatic functions are inoperable and the isolation capability is not maintained, TS 3.3.6.1, Action D, requires isolation of the associated MSL within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or to be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

TS 3.3.6.1 applies several Surveillance Requirements (SR) to these Functions:

NUREG-1433

  • SR 3.3.6.1.7, performance of a Logic System Function Test, and
  • SR 3.3.6.1.8, verification of the Isolation System Response Time.

NUREG-1434

The plant-specific TS requirements may vary. Not all of the Functions may appear in the plant-specific TS, and the monitored areas and names may be different. For example, some similar plant-specific Functions are:

  • Outboard MSIV Room Temperature - High
  • Reactor Building Main Steam Tunnel Temperature-High
  • Main Steam Line Pipe Tunnel Temperature - High The proposed change is applicable to any plant-specific Function that:
  • Measures the temperature around the MSLs as an indication of small MSL leakage, and
  • Initiates an automatic Group 1 isolation (or an equivalent action that closes the MSIVs).

2.3. Reason for Proposed Change The temperature in the areas around the MSLs is susceptible to variation and may approach or exceed the Allowable Value for reasons not related to MSL leakage. For example, hot weather, reduced efficiency or failure of the ventilation systems, or instrument drift could result in enough channels exceeding the Allowable Value to actuate the Function, resulting in a full Group 1 isolation and reactor trip. A Group 1 isolation closes the MSIVs, and loss of main steam can result in loss of main feedwater. While licensees have other means to remove decay heat and to maintain reactor water level (e.g., high pressure coolant injection (HPCI) or high pressure core spray (HPCS), reactor core isolation cooling (RCIC), and suppression pool cooling), NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 8, describes "Unplanned Scrams with Complications" as a scram without main feedwater available. Licensees wish to avoid complicated scrams.

DRAFT

TSTF-608, Rev. 0 Page 4 Given that the temperature in the area of the MSLs is not credited in any DBA or transient analysis and is only used as a surrogate indication for small MSL leakage, and that the accuracy of that surrogate indication may be affected by factors not related to MSL leakage, the safety benefit of an automatic Group 1 isolation based on these indications is not commensurate with the risk of initiating an unwarranted reactor scram.

The proposed change will remove the MSL automatic isolation Functions based on MSL area temperature from the TS. The requirements will be relocated to the Technical Requirements Manual (TRM) or the plant-specific equivalent. The TRM and similar documents are controlled under 10 CFR 50.59. After relocation, licensees may take appropriate action to revise the TRM to reduce the likelihood of an unnecessary Group 1 isolation, such as replacing the automatic function with a monitoring and manual action requirement. Such changes will be evaluated under 10 CFR 50.59, and if required by the regulation, prior NRC approval of the change will be obtained. The proposed change does not request NRC review or approval of any changes that may be made to the requirements after relocation, and the traveler will not result in any physical change to the plant or the manner in which the plant is operated or maintained.

2.4. Description of the Proposed Change The proposed change removes the Table 3.3.6.1 Functions associated with MSL isolation based on area temperature that are referenced in Limiting Conditions for Operation (LCO) 3.3.6.1.

The requirements are relocated to the licensee controlled TRM or the plant-specific equivalent.

The proposed change revises NUREG-1433 and NUREG-1434, TS 3.3.6.1, "Primary Containment Isolation Instrumentation," to eliminate:

  • Function 1.e, "Main Steam Tunnel Temperature - High,"
  • Function 1.f, "Main Steam Tunnel Differential Temperature - High," and
  • Function 1.g, "Turbine Building Area Temperature - High," (NUREG-1433 only) (or the plant-specific equivalents).

NUREG-1433 Function 1.h and NUREG-1434 Function 1.g, "Manual Initiation," are relabeled Function 1.e.

The Surveillance Requirements applicable to these Functions and the associated Action are also applicable to other Functions, and are not removed from the TS. Similar requirements are copied to licensee control with the relocated functions.

The TS Bases are revised to reflect the change to the TS. The associated TS Bases information will also be relocated to licensee control.

Some licensees have eliminated one or more of the MSL area temperature isolation instrumentation Functions and replaced them with a TS that requires monitoring the temperature and taking manual action. The justification for relocating the automatic instrumentation isolation Functions is also applicable to this TS, and the requirements are be relocated to licensee control.

The model application includes a variation for licensees to describe this situation.

DRAFT

TSTF-608, Rev. 0 Page 5 A model application is attached. The model should be used by licensees desiring to adopt the traveler following NRC approval.

3. TECHNICAL EVALUATION The proposed change relocates an automatic MSL isolation on MSL area temperature instrument Functions to the TRM or the plant-specific equivalent.

There are two purposes for the MSL area temperature isolation instrument Functions:

1. Leak Before Break - MSL area temperature increases may provide for timely detection and isolation of small MSL leaks prior to them growing to a critical crack size which can propagate into a full pipe rupture. Early intergranular stress corrosion crack (IGSCC) propagation studies on stainless steel reactor coolant pressure boundary (RCPB) pipes in the containment showed that isolating a small leak provided assurance that the leak would not grow to a break. This same basis was conservatively applied to the main steam carbon steel piping. However, later studies determined that cracks in main steam piping are not subject to IGSCC due to the lack of a corrosive environment. Therefore, this MSL leak-before-break detection and isolation capability is not credited to prevent or mitigate any design basis event.
2. Dose Limits - The consideration of small MSL leaks varies by plants. For some plants, the Loss of Coolant Accident (LOCA) analysis does not assume any release of post-accident radioactive material from small MSL leaks. Other plants may use different assumptions. A LOCA is not caused by a small MSL leak, and it is not required to assume they occur simultaneously. However, in all cases the post-accident dose effect of small MSL leaks is bounded by the worst-case leak, such as a MSLB, which is terminated by the high steam flow automatic isolation (TS 3.3.6.1, Function 1.c). This small leak detection capability is not credited to prevent or mitigate any design basis event.

These purposes do warrant inclusion of these automatic isolation instrument Functions in the TS.

Small MSL leaks are not considered in the accident analyses. If a large MSL break occurs, the following TS functions will automatically close the MSIVs and shut down the reactor:

  • Condenser Vacuum - Low Evaluation of the 10 CFR 50.36(c)(2)(ii) Criteria On July 22, 1993, the NRC published its Final Policy Statement of Technical Specifications Improvements for Nuclear Power Reactors, 58 FR 39132. The Final Policy Statement established four objective criteria as guidance for determining which regulatory requirements and operating restrictions should be included in TS. The Final Policy Statement also stated that DRAFT

TSTF-608, Rev. 0 Page 6 LCOs that do not meet any of the four criteria may be removed from the TS and relocated to licensee-controlled documents, such as the Updated Final Safety Analysis Report (UFSAR), the TRM or the plant-specific equivalent. The relocated requirements will be subject to the controls of 10 CFR 50.59. The four criteria were later incorporated into 10 CFR 50.36, Technical Specifications, under 10 CFR 50.36(c)(2)(ii) (60 FR 36953).

Limiting Condition for Operation (LCO) 3.3.6.1 requires the primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 to be operable. Therefore, each Function in Table 3.3.6.1-1 is part of the LCO and should satisfy 10 CFR 50.36(c)(2)(ii), which 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."

The MSL area temperature automatic isolation instrument Functions were compared to each of the criteria to determine if they are required to be retained in the TS. The criteria application considers the Commission's discussion of each criteria in the Commission's Final Policy Statement.

Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Discussion of Criterion 1 from the Final Policy Statement:

A basic concept in the adequate protection of the public health and safety is the prevention of accidents. Instrumentation is installed to detect significant abnormal degradation of the reactor coolant pressure boundary so as to allow operator actions to either correct the condition or to shut down the plant safely, thus reducing the likelihood of a loss-of-coolant accident.

This criterion is intended to ensure that Technical Specifications control those instruments specifically installed to detect excessive reactor coolant system leakage. This criterion should not, however, be interpreted to include instrumentation to detect precursors to reactor coolant pressure boundary leakage or instrumentation to identify the source of actual leakage (e.g., loose parts monitor, seismic instrumentation, valve position indicators).

Evaluation of Criterion 1. The MSLs are part of the reactor coolant pressure boundary (RCPB).

However, the MSL area temperature automatic isolation instrument Functions are not used to detect a significant abnormal degradation of the RCPB. As stated in the TS Bases, the Functions isolate the MSL when a very small leak has occurred, and a very small leak does not represent a significant degradation in the RCPB. Elevated MSL area temperature could potentially indicate a precursor to RCPB leakage or identify the source of actual leakage, but these capabilities do not satisfy Criterion 1. Therefore, the MSL area temperature automatic isolation instrument Functions do not satisfy Criterion 1.

DRAFT

TSTF-608, Rev. 0 Page 7 Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Excerpt from the Discussion of Criterion 2 from the Final Policy Statement:

The purpose of this criterion is to capture those process variables that have initial values assumed in the Design Basis Accident and Transient analyses, and which are monitored and controlled during power operation. As long as these variables are maintained within the established values, risk to the public safety is presumed to be acceptably low. This criterion also includes active design features (e.g., high pressure /low pressure system valves and interlocks) and operating restrictions (pressure/temperature limits) needed to preclude unanalyzed accidents and transients.

Evaluation of Criterion 2. The temperature of the areas around the MSLs is a process variable.

However, MSL area temperature is not an initial condition of any Design Basis Accident or Transient analysis, and no initial value is assumed. Automatic isolation of the MSLs by the MSL area temperature automatic isolation instrument Functions is not an initial condition of any Design Basis Accident or Transient. As stated in the TS Bases, "credit for these instruments is not taken in any transient or accident analysis in the FSAR, since bounding analyses are performed for large breaks such as MSLBs." Automatic isolation of the MSLs based on MSL area temperature is not an operating restriction needed to preclude unanalyzed accidents and transients. The analysis for large breaks, such as the MSLB, encompasses any accidents or transients associated with very small MSL leakage. Therefore, the MSL area temperature automatic isolation instrument Functions do not satisfy Criterion 2.

Criterion 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Excerpt from the Discussion of Criterion 3 from the Final Policy Statement:

It is the intent of this criterion to capture into Technical Specifications only those structures, systems, and components that are part of the primary success path of a safety sequence analysis. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function. The primary success path for a particular mode of operation does not include backup and diverse equipment (e.g., rod withdrawal block which is a backup to the average power range monitor high flux trip in the startup mode, safety valves which are backup to low temperature overpressure relief valves during cold shutdown).

Evaluation of Criterion 3. The MSL area temperature automatic isolation instrument Functions are not a structure, system, or component which functions or actuates to mitigate a Design Basis Accident or Transient. As stated in the TS Bases, "credit for these instruments is not taken in any transient or accident analysis in the FSAR, since bounding analyses are performed for large DRAFT

TSTF-608, Rev. 0 Page 8 breaks such as MSLBs." Therefore, the MSL area temperature automatic isolation instrument Functions do not satisfy Criterion 3.

Criterion 4: A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

Excerpt from the Discussion of Criterion 4 from the Final Policy Statement:

It is the Commission policy that licensees retain in their Technical Specifications LCOs, action statements and Surveillance Requirements for the following systems (as applicable), which operating experience and PSA have generally shown to be significant to public health and safety.

Evaluation of Criterion 4. The MSL area temperature automatic isolation instrument Functions are not risk-significant contributors (either as explicitly modeled or are unmodeled due to low risk contribution) in plant's probabilistic risk assessments. A review of Event Notifications since 1998 and Licensee Event Reports since 1992 did not reveal any instances in which the MSL area temperature automatic isolation instrument Functions actuated in response to a MSL leak.

Consequently, operating experience has not shown that MSL isolation based on the area temperature detector readings is significant to public health and safety. Therefore, the MSL area temperature automatic isolation instrument Functions do not satisfy Criterion 4.

Since the MSL area temperature automatic isolation instrument Functions do not meet the criteria in 10 CFR 50.36(c)(2)(ii) requiring a TS LCO, the Functions may be relocated to the TRM or the plant-specific equivalent, and any subsequent changes will be adequately controlled by the provisions of 10 CFR 50.59. These provisions will continue to be implemented by appropriate station procedures (i.e., operating procedures, maintenance procedures, surveillance and testing procedures, and work control procedures).

4. REGULATORY EVALUATION In 10 CFR 50.36, "Technical specification," the Commission established its regulatory requirements related to the content of the TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) Limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. Based on the assessments described in Section 3, the MSL area temperature isolation instrumentation Functions do not meet the four criteria of 10 CFR 50.36(c)(2)(ii) for retention in the Technical Specifications.

Per 10 CFR 50.90, whenever a holder of a license desires to amend the license, application for an amendment must be filed with the Commission, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.

Section IV, "The Commission Policy," of the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58FR39132), dated July 22, 1993, states in part that improved STS have been developed and will be maintained for each NSSS DRAFT

TSTF-608, Rev. 0 Page 9 owners group. The Commission Policy encourages licensees to use the improved STS as the basis for plant-specific Technical Specifications." The industry's proposal of travelers and the NRC's approval of travelers is the method used to maintain the improved STS as described in the Commission's Policy. Following NRC approval, licensees adopt travelers into their plant-specific technical specifications following the requirements of 10 CFR 50.90. Therefore, the traveler process facilitates the Commission's policy while satisfying the requirements of the applicable regulations.

The regulation at 10 CFR 50.36(a)(1) also requires the application to include a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls." The proposed traveler revises the Bases to be consistent with the changes to the TS, and therefore complies with 10 CFR 50.36(a)(1).

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

5. REFERENCES None.

DRAFT

TSTF-608, Rev. 0 Model Application DRAFT

TSTF-608, Rev. 0 Page 1

[DATE]

10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 PLANT NAME DOCKET NO. [50]-[xxx]

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-608, "Relocate Main Steam Line (MSL) Area Temperature Automatic Isolation Functions" Pursuant to 10 CFR 50.90, [LICENSEE] is submitting a request for an amendment to the Technical Specifications (TS) for [PLANT NAME, UNIT NOS.].

[LICENSEE] requests adoption of TSTF-608, "Relocate Main Steam Line (MSL) Area Temperature Automatic Isolation Functions," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-608 relocates from the TS to licensee control the requirements for automatic [or manual] MSL isolation based on area temperature.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. [Attachment 2 provides revised (clean) TS pages.] [Attachment [3] provides the existing TS Bases pages marked to show the changes associated with the proposed TS changes and is provided for information only.]

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

There are no regulatory commitments in this letter.

[In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated [STATE] Official.]

[In accordance with 10 CFR 50.30(b), a license amendment request must be executed in a signed original under oath or affirmation. This can be accomplished by attaching a notarized affidavit confirming the signature authority of the signatory, or by including the following statement in the cover letter: "I declare under penalty of perjury that the foregoing is true and correct.

Executed on (date)." The alternative statement is pursuant to 28 USC 1746. It does not require notarization.]

DRAFT

TSTF-608, Rev. 0 Page 2 If you should have any questions regarding this submittal, please contact [NAME, TELEPHONE NUMBER].

Sincerely,

[Name, Title]

Enclosure:

Description and Assessment Attachments: 1.

Proposed Technical Specification Changes (Mark-Up)

[2. Revised Technical Specification Pages]

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

[The attachments are to be provided by the licensee and are not included in the model application.]

cc:

NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact DRAFT

TSTF-608, Rev. 0 Page 3 ENCLOSURE DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

[LICENSEE] requests adoption of TSTF-608, "Relocate Main Steam Line (MSL) Area Temperature Automatic Isolation Functions," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. The traveler relocates from the TS to licensee control the requirements for automatic [or manual] MSL isolation based on area temperature.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation

[LICENSEE] has reviewed the safety evaluation for TSTF-608 provided to the Technical Specifications Task Force in a letter dated [DATE]. This review included the NRC staffs evaluation, as well as the information provided in TSTF-608. [LICENSEE] has concluded that the justifications presented in TSTF-608 and the safety evaluation prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this amendment for the incorporation of the changes to the [PLANT] TS.

[LICENSEE] is proposing to relocate the following Functions in Specification 3.3.6.1, "Primary Containment Isolation Instrumentation" to licensee control:

  • [Function 1.e, "Main Steam Tunnel Temperature - High,"]
  • [Function 1.f, "Main Steam Tunnel Differential Temperature - High,"] and
  • [Function 1.g, "Turbine Building Area Temperature - High."]

[LICENSEE] verifies that these functions:

  • Measure the temperature around the MSLs as an indication of small MSL leakage, and

((LICENSEE] is also proposing to relocate [TS 3.7.7, Main Steam Line Area Temperature] to the licensee control.]

2.2 Variations

[LICENSEE is not proposing any variations from the TS changes described in TSTF-608 or the applicable parts of the NRC staffs safety evaluation.] [LICENSEE is proposing the following variations from the TS changes described in TSTF-608 or the applicable parts of the NRC staffs safety evaluation:]

[The [PLANT] TS utilize different [numbering][and][titles] than the STS on which TSTF-608 was based. Specifically, [describe differences between the plant-specific TS numbering and/or titles and the TSTF-608 numbering and titles.] These differences are administrative and do not affect the applicability of TSTF-608 to the [PLANT] TS.]

DRAFT

TSTF-608, Rev. 0 Page 4

[The [PLANT] TS contain requirements that differ from the STS on which TSTF-608 was based but are encompassed in the TSTF-608 justification. [Describe the differences and why TSTF-608 is still applicable.))

[The [PLANT] design is different from the plant design described in the STS and TSTF-608, but is encompassed in the TSTF-608 justification. [Describe the differences and why TSTF 608 is still applicable.))

((LICENSEE] has eliminated [one of] of the MSL area temperature isolation instrumentation Functions and replaced [it/them] with TS [3.7.7, Main Steam Line Area Temperature.] The change was approved by [reference to NRC license amendment]. This TS performs the same function as the automatic isolation instrumentation Functions, but action is taken manually. The justification in the traveler is applicable to this TS and the requirements are also relocated to licensee control.] {Note: if a plant's TS only have automatic functions, do not include the bracketed term "manual" in the application.}

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis

[LICENSEE] requests adoption of TSTF-608, "Relocate Main Steam Line (MSL) Area Temperature Automatic Isolation Functions," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. The proposed change relocates to licensee control the automatic [and manual] isolation of the MSLs based on the temperature in the surrounding areas.

[LICENSEE] has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Response: No The proposed change relocates to licensee control the automatic [and manual] isolation of the MSLs based on the temperature in the surrounding areas.

Isolation of the MSLs on MSL high area temperature is not an initiator of any accident previously evaluated.

There is no credit taken in any licensing basis analysis for the main steam isolation valve (MSIV) closure on MSL area high temperature. Therefore, relocating the requirement to licensee control will have no effect on the consequences of any accident previously evaluated.

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

DRAFT

TSTF-608, Rev. 0 Page 5

2.

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

Response: No The proposed change relocates to licensee control the automatic [and manual] isolation of the MSLs based on the temperature in the surrounding areas.

Relocating to licensee control the automatic [and manual] isolation of the MSIVs based on the temperature of the surrounding areas will not create a new or different kind of accident from those previously evaluated as a Main Steam Line Break (MSLB).

Relocation of the requirements to licensee control will not create a new failure mechanism as the requirements are not changed by the relocation. In the unlikely event that the relocation results in failure to identify a small MSL leak that leads to an MSLB, that accident has already been evaluated and is not a new type of accident.

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

3.

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

Response: No The proposed change relocates to licensee control the automatic [and manual] isolation of the MSLs based on the temperature in the surrounding areas.

The proposed change does not affect any Safety Limits or controlling numerical values for a parameter established in the updated final safety analysis report or any specific values that define margin that are established in the plants licensing basis. MSIV isolation on MSL area temperature is not credited as a mitigating feature in any analysis which establishes thermal limits, evaluates peak vessel pressure, evaluates peak containment or drywell pressure, or evaluates onsite and offsite radiological consequences.

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

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

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

DRAFT

TSTF-608, Rev. 0 Page 6

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

DRAFT

TSTF-608, Rev. 0 Technical Specifications Changes DRAFT

Primary Containment Isolation Instrumentation 3.3.6.1 General Electric BWR/4 STS 3.3.6.1-7 Rev. 5.0 Table 3.3.6.1-1 (page 1 of 7)

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

1. Main Steam Line Isolation
a.

Reactor Vessel Water Level - Low Low Low, Level 1 1, 2, 3

[2]

D SR 3.3.6.1.1 SR 3.3.6.1.2

[SR 3.3.6.1.3]

SR 3.3.6.1.6 SR 3.3.6.1.7 SR 3.3.6.1.8

[-113] inches

b.

Main Steam Line Pressure - Low 1

[2]

E

[SR 3.3.6.1.1]

[SR 3.3.6.1.2]

SR 3.3.6.1.4 SR 3.3.6.1.7 SR 3.3.6.1.8

[825] psig

c.

Main Steam Line Flow - High 1, 2, 3

[2] per MSL D

SR 3.3.6.1.1 SR 3.3.6.1.2

[SR 3.3.6.1.3]

SR 3.3.6.1.6 SR 3.3.6.1.7 SR 3.3.6.1.8

[138]% rated steam flow

d.

Condenser Vacuum

- Low 1, 2(a), 3(a)

[2]

D SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.7

[7] inches Hg vacuum

e.

Main Steam Tunnel Temperature - High 1, 2, 3

[8]

D SR 3.3.6.1.1 SR 3.3.6.1.2

[SR 3.3.6.1.3]

SR 3.3.6.1.6 SR 3.3.6.1.7 SR 3.3.6.1.8

[194] °F

[ f. Main Steam Tunnel Differential Temperature - High 1,2,3

[2]

D SR 3.3.6.1.1 SR 3.3.6.1.2

[SR 3.3.6.1.3]

SR 3.3.6.1.6 SR 3.3.6.1.7

[ ] °F ]

g.

Turbine Building Area Temperature -

High 1, 2, 3

[32]

D

[SR 3.3.6.1.1]

SR 3.3.6.1.2 SR 3.3.6.1.6 SR 3.3.6.1.7

[200] °F

[ eh. Manual Initiation 1, 2, 3

[1]

G SR 3.3.6.1.7 NA ]

(a)

With any turbine [stop valve] not closed.

DRAFT

Primary Containment Isolation Instrumentation B 3.3.6.1 General Electric BWR/4 STS B 3.3.6.1-2 Rev. 5.0 BASES BACKGROUND (continued)

The exceptions to this arrangement is are the Main Steam Line Flow -

High Function and Area and Differential Temperature Functions. The Main Steam Line Flow - High Function uses 16 flow channels, four for each steam line. One channel from each steam line inputs to one of the four trip strings. Two trip strings make up each trip system and both trip systems must trip to cause an MSL isolation. Each trip string has four inputs (one per MSL), any one of which will trip the trip string. The trip strings are arranged in a one-out-of-two taken twice logic. This is effectively a one-out-of-eight taken twice logic arrangement to initiate isolation of the MSIVs. Similarly, the 16 flow channels are connected into two two-out-of-two logic trip systems (effectively, two one-out-of-four twice logic), with each trip system isolating one of the two MSL drain valves on the associated steam line.

The Main Steam Tunnel Temperature - High Function receives input from 16 channels. The logic is arranged similar to the Main Steam Line Flow -

High Function. The Turbine Building Area Temperature - High Function receives input from 64 channels. The inputs are arranged in a one-out-of-thirty-two taken twice logic trip system to isolate all MSIVs. Similarly, the inputs are arranged in two one-out-of-sixteen twice logic trip systems, with each trip system isolating one of the two MSL drain valves per drain line.

MSL Isolation Functions isolate the Group 1 valves.

2. Primary Containment Isolation Most Primary Containment Isolation Functions receive inputs from four channels. The outputs from these channels are arranged into two two-out-of-two logic trip systems. One trip system initiates isolation of all inboard primary containment isolation valves, while the other trip system initiates isolation of all outboard primary containment isolation valves.

Each logic closes one of the two valves on each penetration, so that operation of either logic isolates the penetration.

The exception to this arrangement is the Drywell Radiation - High Function. This Function has two channels, whose outputs are arranged in two one-out-of-one logic trip systems. Each trip system isolates one valve per associated penetration, similar to the two-out-of-two logic described above.

DRAFT

Primary Containment Isolation Instrumentation B 3.3.6.1 General Electric BWR/4 STS B 3.3.6.1-8 Rev. 5.0 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) 1.d. Condenser Vacuum - Low The Condenser Vacuum - Low Function is provided to prevent overpressurization of the main condenser in the event of a loss of the main condenser vacuum. Since the integrity of the condenser is an assumption in offsite dose calculations, the Condenser Vacuum - Low Function is assumed to be OPERABLE and capable of initiating closure of the MSIVs. The closure of the MSIVs is initiated to prevent the addition of steam that would lead to additional condenser pressurization and possible rupture of the diaphragm installed to protect the turbine exhaust hood, thereby preventing a potential radiation leakage path following an accident.

Condenser vacuum pressure signals are derived from four pressure transmitters that sense the pressure in the condenser. Four channels of Condenser Vacuum - Low Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function.

The Allowable Value is chosen to prevent damage to the condenser due to pressurization, thereby ensuring its integrity for offsite dose analysis.

As noted (footnote (a) to Table 3.3.6.1-1), the channels are not required to be OPERABLE in MODES 2 and 3 when all turbine stop valves (TSVs) are closed, since the potential for condenser overpressurization is minimized. Switches are provided to manually bypass the channels when all TSVs are closed.

This Function isolates the Group 1 valves.

1.e, 1.f, 1.g. Area and Differential Temperature - High Area and differential temperature is provided to detect a leak in the RCPB and provides diversity to the high flow instrumentation. The isolation occurs when a very small leak has occurred. If the small leak is allowed to continue without isolation, offsite dose limits may be reached.

However, credit for these instruments is not taken in any transient or accident analysis in the FSAR, since bounding analyses are performed for large breaks, such as MSLBs.

Area temperature signals are initiated from thermocouples located in the area being monitored. Sixteen channels of Main Steam Tunnel Temperature - High Function and 64 channels of Turbine Building Area Temperature - High Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. Each Function has one temperature element.

DRAFT

Primary Containment Isolation Instrumentation B 3.3.6.1 General Electric BWR/4 STS B 3.3.6.1-9 Rev. 5.0 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

Eight thermocouples provide input to the Differential Temperature - High Function. The output of these thermocouples is used to determine the differential temperature. Each channel consists of a differential temperature instrument that receives inputs from thermocouples that are located in the inlet and outlet of the area cooling system for a total of four available channels.

The ambient and differential temperature monitoring Allowable Value is chosen to detect a leak equivalent to between 1% and 10% rated steam flow.

These Functions isolate the Group 1 valves.

1.eh. Manual Initiation The Manual Initiation push button channels introduce signals into the MSL isolation logic that are redundant to the automatic protective instrumentation and provide manual isolation capability. There is no specific FSAR safety analysis that takes credit for this Function. It is retained for the overall redundancy and diversity of the isolation function as required by the NRC in the plant licensing basis.

There are two push buttons for the logic, one manual initiation push button per trip system. There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons.

Two channels of Manual Initiation Function are available and are required to be OPERABLE in MODES 1, 2, and 3, since these are the MODES in which the MSL isolation automatic Functions are required to be OPERABLE.

Primary Containment Isolation 2.a. Reactor Vessel Water Level - Low, Level 3 Low RPV water level indicates that the capability to cool the fuel may be threatened. The valves whose penetrations communicate with the primary containment are isolated to limit the release of fission products.

The isolation of the primary containment on Level 3 supports actions to ensure that offsite dose limits of 10 CFR 100 are not exceeded. The Reactor Vessel Water Level - Low, Level 3 Function associated with isolation is implicitly assumed in the FSAR analysis as these leakage paths are assumed to be isolated post LOCA.

DRAFT

Primary Containment Isolation Instrumentation B 3.3.6.1 General Electric BWR/4 STS B 3.3.6.1-23 Rev. 5.0 BASES ACTIONS (continued) can receive an isolation signal from the given Function. For Functions 1.a, 1.b, and 1.d, and 1.f, this would require both trip systems to have one channel OPERABLE or in trip. For Function 1.c, this would require both trip systems to have one channel, associated with each MSL, OPERABLE or in trip. For Functions 1.e and 1.g, each Function consists of channels that monitor several locations within a given area (e.g.,

different locations within the main steam tunnel area). Therefore, this would require both trip systems to have one channel per location OPERABLE or in trip. For Functions 2.a, 2.b, 2.d, 2.e, 3.b, 3.c, 4.b, 4.c, 5.e, and 6.b, this would require one trip system to have two channels, each OPERABLE or in trip. For Functions 2.c, 3.a, 3.d, 3.e, 3.f, 3.g, 3.h, 3.i, 4.a, 4.d, 4.e, 4.f, 4.g, 4.h, 4.i, 4.j, 5.a, 5.d, and 6.a, this would require one trip system to have one channel OPERABLE or in trip. For Functions 5.b and 5.c, each Function consists of channels that monitor several different locations. Therefore, this would require one channel per location to be OPERABLE or in trip (the channels are not required to be in the same trip system). The Condition does not include the Manual Initiation Functions (Functions 1.eh, 2.d, 3.j, 4.k, and 5.f), since they are not assumed in any accident or transient analysis. Thus, a total loss of manual initiation capability for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (as allowed by Required Action A.1) is allowed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

C.1 Required Action C.1 directs entry into the appropriate Condition referenced in Table 3.3.6.1-1. The applicable Condition specified in Table 3.3.6.1-1 is Function and MODE or other specified condition dependent and may change as the Required Action of a previous Condition is completed. Each time an inoperable channel has not met any Required Action of Condition A or B and the associated Completion Time has expired, Condition C will be entered for that channel and provides for transfer to the appropriate subsequent Condition.

DRAFT

Primary Containment Isolation Instrumentation 3.3.6.1 General Electric BWR/6 STS 3.3.6.1-7 Rev. 5.0 Table 3.3.6.1-1 (page 1 of 7)

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

1. Main Steam Line Isolation
a.

Reactor Vessel Water Level - Low Low Low, Level 1 1,2,3

[2]

D SR 3.3.6.1.1 SR 3.3.6.1.2

[SR 3.3.6.1.3]

SR 3.3.6.1.5 SR 3.3.6.1.6 SR 3.3.6.1.7

[-152.5]

inches

b.

Main Steam Line Pressure - Low 1

[2]

E SR 3.3.6.1.1 SR 3.3.6.1.2

[SR 3.3.6.1.3]

SR 3.3.6.1.5 SR 3.3.6.1.6 SR 3.3.6.1.7

[837] psig

c.

Main Steam Line Flow - High 1,2,3

[2] per MSL D

SR 3.3.6.1.1 SR 3.3.6.1.2

[SR 3.3.6.1.3]

SR 3.3.6.1.5 SR 3.3.6.1.6 SR 3.3.6.1.7

[176.5] psig

d.

Condenser Vacuum -

Low 1,2(a),

3(a)

[2]

D SR 3.3.6.1.1 SR 3.3.6.1.2

[SR 3.3.6.1.3]

SR 3.3.6.1.5 SR 3.3.6.1.6

[8.7] inches Hg vacuum

e.

Main Steam Tunnel Temperature - High 1,2,3

[2]

D SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.5 SR 3.3.6.1.6

[191]°F

f.

Main Steam Tunnel Differential Temperature - High 1,2,3

[2]

D SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.5 SR 3.3.6.1.6

[104]°F

[ eg. Manual Initiation 1,2,3

[2]

G SR 3.3.6.1.6 NA ]

(a)

With any turbine [stop valve] not closed.

DRAFT

Primary Containment Isolation Instrumentation B 3.3.6.1 General Electric BWR/6 STS B 3.3.6.1-7 Rev. 5.0 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) possible rupture of the diaphragm installed to protect the turbine exhaust hood, thereby preventing a potential radiation leakage path following an accident.

Condenser vacuum pressure signals are derived from four pressure transmitters that sense the pressure in the condenser. Four channels of Condenser Vacuum - Low Function are available and are required to be OPERABLE to ensure no single instrument failure can preclude the isolation function.

The Allowable Value is chosen to prevent damage to the condenser due to pressurization, thereby ensuring its integrity for offsite dose analysis.

As noted (footnote (a) to Table 3.3.6.1-1), the channels are not required to be OPERABLE in MODES 2 and 3, when all turbine stop valves (TSVs) are closed, since the potential for condenser overpressurization is minimized. Switches are provided to manually bypass the channels when all TSVs are closed.

This Function isolates the Group 1 valves.

1.e, 1.f. Main Steam Tunnel Ambient and Differential Temperature - High Ambient and Differential Temperature - High is provided to detect a leak in the RCPB, and provides diversity to the high flow instrumentation. The isolation occurs when a very small leak has occurred. If the small leak is allowed to continue without isolation, offsite dose limits may be reached.

However, credit for these instruments is not taken in any transient or accident analysis in the FSAR, since bounding analyses are performed for large breaks such as MSLBs.

Ambient temperature signals are initiated from thermocouples located in the area being monitored. Four channels of Main Steam Tunnel Temperature - High Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. Each Function has one temperature element.

Eight thermocouples provide input to the Main Steam Tunnel Differential Temperature - High Function. The output of these thermocouples is used to determine the differential temperature. Each channel consists of a differential temperature instrument that receives inputs from thermocouples that are located in the inlet and outlet of the area cooling system for a total of four available channels.

The ambient and differential temperature monitoring Allowable Value is chosen to detect a leak equivalent to 25 gpm.

DRAFT

Primary Containment Isolation Instrumentation B 3.3.6.1 General Electric BWR/6 STS B 3.3.6.1-8 Rev. 5.0 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

These Functions isolate the Group 1 valves.

1.eg. Manual Initiation The Manual Initiation push button channels introduce signals into the MSL isolation logic that are redundant to the automatic protective instrumentation and provide manual isolation capability. There is no specific FSAR safety analysis that takes credit for this Function. It is retained for overall redundancy and diversity of the isolation function as required by the NRC in the plant licensing basis.

There are four push buttons for the logic, two manual initiation push buttons per trip system. There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons.

Four channels of Manual Initiation Function are available and are required to be OPERABLE in MODES 1, 2, and 3, since these are the MODES in which the MSL Isolation automatic Functions are required to be OPERABLE.

2. Primary Containment Isolation 2.a, 2.e. Reactor Vessel Water Level - Low Low, Level 2 Low RPV water level indicates the capability to cool the fuel may be threatened. The valves whose penetrations communicate with the primary containment are isolated to limit the release of fission products.

The isolation of the primary containment on Level 2 supports actions to ensure that offsite dose limits of 10 CFR 100 are not exceeded. The Reactor Vessel Water Level - Low Low, Level 2 Function associated with isolation is implicitly assumed in the FSAR analysis as these leakage paths are assumed to be isolated post LOCA.

Reactor Vessel Water Level - Low Low, Level 2 signals are initiated from 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. Four channels of Reactor Vessel Water Level - Low Low, Level 2 Function are available and are required to be OPERABLE to ensure no single instrument failure can preclude the isolation function.

The Reactor Vessel Water Level - Low Low, Level 2 Allowable Value was chosen to be the same as the ECCS Reactor Vessel Water Level - Low Low, Level 2 Allowable Value (LCO 3.3.5.1), since isolation of these valves is not critical to orderly plant shutdown.

DRAFT

Primary Containment Isolation Instrumentation B 3.3.6.1 General Electric BWR/6 STS B 3.3.6.1-24 Rev. 5.0 BASES ACTIONS (continued)

B.1 Required Action B.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same Function result in redundant automatic isolation capability being lost for the associated penetration flow path(s). The MSL isolation Functions are considered to be maintaining isolation capability when sufficient channels are OPERABLE or in trip such that both trip systems will generate a trip signal from the given Function on a valid signal. The other isolation Functions are considered to be maintaining isolation capability when sufficient channels are OPERABLE or in trip such that one trip system will generate a trip signal from the given Function on a valid signal. This ensures that one of the two PCIVs in the associated penetration flow path can receive an isolation signal from the given Function. For Functions 1.a, 1.b, and 1.d, 1.e, and 1.f, this would require both trip systems to have one channel OPERABLE or in trip. For Function 1.c, this would require both trip systems to have one channel, associated with each MSL, OPERABLE or in trip. For Functions 2.a, 2.b, 2.c, 2.d, 2.e, 2.f, 2.g, 3.d, 4.k, 5.c, 5.d, and 5.e, this would require one trip system to have two channels, each OPERABLE or in trip. For Functions 3.a, 3.b, 3.c, 3.e, 3.f, 3.g, 3.h, 3.i, 3.l, 3.m, 4.a, 4.b, 4.c, 4.d, 4.g, 4.h, 4.i, 4.j, and 4.l, this would require one trip system to have one channel OPERABLE or in trip. For Functions 3.j, 3.k, 4.e, 4.f, 5.a, and 5.b, each Function consists of channels that monitor several different locations. Therefore, this would require one channel per location to be OPERABLE or in trip (the channels are not required to be in the same trip system). The Condition does not include the Manual Initiation Functions (Functions 1.eg, 2.h, 3.n, and 4.m), since they are not assumed in any accident or transient analysis. Thus, a total loss of manual initiation capability for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (as allowed by Required Action A.1) is allowed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

C.1 Required Action C.1 directs entry into the appropriate Condition referenced in Table 3.3.6.1-1. The applicable Condition specified in Table 3.3.6.1-1 is Function and MODE or other specified condition dependent and may change as the Required Action of a previous Condition is completed. Each time an inoperable channel has not met DRAFT

Retrieved from "https://kanterella.com/w/index.php?title=ML25322A341&oldid=5559327"