Text

License Amendment Request (TSCR-146): Application to Revise Tech Specs to Adopt Technical Specifications Task Force (TSTF) Traveler-523,Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process
	ML14175B387
Person / Time
Site:	Duane Arnold
Issue date:	06/23/2014
From:	Richard Anderson; NextEra Energy Duane Arnold
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-08-001, NG-14-0143
	Download: ML14175B387 (58)
	v • d • e

NEX~era ENERG7y"4 DUANE ARNOLD June 23, 2014 NG-14-0143 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49 License Amendment Request (TSCR-146): Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF) Traveler-523, "Generic Letter 2008-01, Managqingq Gas Accumulation," Usingq the Consolidated Line Item Improvement Process

Reference:

Letter (NG-08-0777) from R. L. Anderson (FPL Energy Duane Arnold, LLC) to Document Control Desk (NRC), "Nine Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems,"

October 13, 2008 (ADAMS Accession No. ML082970263)

Pursuant to 10 CFR 50.90, NextEra Energy Duane Arnold, LLC (hereafter, NextEra Energy Duane Arnold) is submitting a request for amendment to the Technical Specifications for Duane Arnold Energy Center (DAEC).

The proposed amendment would modify Technical Specification (TS) requirements to address NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems,"

as described in TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation." NextEra Energy Duane Arnold committed to submit this proposed change in the referenced letter.

Attachment 1 provides a description and assessment of the proposed change.

Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides existing TS Bases pages marked to show the proposed change. Changes to the existing TS Bases, consistent with the technical and regulatory analyses, will be NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA52324

Document Control Desk NG-14-0143 Page 2 of 2 implemented under the Technical Specification Bases Control Program. They are provided in Attachment 4 for information only.

Approval of the proposed amendment is requested by February 28, 2015. Once approved the amendment shall be implemented within 90 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Iowa official.

This application has been reviewed by the NextEra Energy Duane Arnold Onsite Review Group.

This letter satisfies the commitment made in the referenced letter and makes no new commitments or changes to any existing commitments.

If you have any questions or require additional information, please contact J. Michael Davis at 319-851-7032.

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

Executed on June 23, 2014.

Tcard L. Ande'rs a ý Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Attachments: 1. Description and Assessment

2. Proposed TS Changes (marked-up pages)

3. Proposed TS Changes (clean/typed pages)

4. Proposed TS Bases Changes (marked-ups pages) - For information only cc: USNRC Regional Administrator Region III USNRC Project Manager, Duane Arnold Energy Center USNRC Resident Inspector, Duane Arnold Energy Center A. Leek (State of Iowa)

NG-14-0143 Attachment 1 License Amendment Request for Adoption of Technical Specifications Task Force.

(TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 1 NextEra Energy Duane Arnold Description and Assessment

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration 3.2 Applicable Regulatory Requirements/Criteria 4.0 ENVIRONMENTAL EVALUATION

5.0 REFERENCES

Page 1 of 5

NG-14-0143 Attachment 1 ATTACHMENT I DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification. The changes are being made to address the concerns discussed in NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," [Reference 2].

The proposed amendment is consistent with Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation" [Reference 3].

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation NextEra Energy Duane Arnold, LLC (hereafter, NextEra Energy Duane Arnold) has reviewed the model safety evaluation published January 15, 2014 as part of the Federal Register Notice of Availability "TSTF-523, Generic Letter 2008-01 Managing Gas Accumulation Using the Consolidated Line Item Improvement Process" (79 FR 2700) [Reference 4]. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-523. As described in the subsequent paragraphs, NextEra has concluded that the justifications presented in the TSTF-523 proposal and the model safety evaluation prepared by the NRC staff are applicable to the Duane Arnold Energy Center (Duane Arnold) and justify this amendment for incorporation of the changes to the Duane Arnold Technical Specifications (TS).

2.2 Optional Changes and Variations NextEra Energy Duane Arnold is proposing the following variations from the TS changes described in the TSTF-523, Revision 2, or the applicable parts of the NRC staff's model safety evaluation.

The Duane Arnold TS utilize different numbering than NUREG-1433, Standard Technical Specifications General Electric Plants BWR/4 [Reference 5] on which TSTF-523 was based.

Specifically, the numbering differences are provided in the table below.

NUREG-1433 Duane Arnold Standard Technical Specifications Technical Specifications BWR/4 3.4.8, RHR Shutdown Cooling System - 3.4.7, RHR Shutdown Cooling System -

Hot Shutdown Hot Shutdown 3.4.9, RHR Shutdown Cooling System - 3.4.8, RHR Shutdown Cooling System - Cold Cold Shutdown Shutdown 3.9.8, RHR - High Water Level 3.9.7, RHR - High Water Level 3.9.9, RHR - Low Water Level 3.9.8, RHR - Low Water Level These differences are editorial and do not affect the applicability of TSTF-523 to Duane Arnold.

Page 2 of 5

NG-14-0143 Attachment 1 TSTF-523 and the model safety evaluation discuss the applicable regulatory requirements and guidance including the10 CFR 50, Appendix A, General Design Criteria (GDC). Duane Arnold was not licensed to the 10 CFR 50, Appendix A, GDC. The Duane Arnold design criteria are discussed in the Updated Final Safety Analysis Report (UFSAR) Section 3.1, Conformance to AEC General Design Criteria for Nuclear Power Plants. The Duane Arnold design criteria that equates to GDC 1 are addressed in UFSAR Section 3.1.2.1, Group I, Overall Requirements and the design criteria that equates to GDC 34 through GDC 40 are addressed in UFSAR Section 3.1.2.4 Group IV, Fluid System, specifically, subsections 3.1.2.4.5 through 3.1.2.4.11. These differences do not alter the conclusion that the proposed change is applicable to Duane Arnold.

3.0 REGULATORY SAFETY ANALYSIS 3.1 No Significant Hazards Consideration Determination NextEra Energy Duane Arnold requests adoption of Technical Specification Task Force Traveler (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," which is an approved change to the standard technical specifications (STS), into the Duane Arnold Energy Center Technical Specifications (TS). The proposed change revises or adds Surveillance Requirements (SRs) to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.

NextEra has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1: Does the Proposed Change Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated?

Response: No The proposed change revises or adds SRs that require verification that the Emergency Core Cooling Systems (ECCS), Residual Heat Removal (RHR) System, and the Reactor Core Isolation Cooling (RCIC) System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. Gas accumulation in the subject systems is not an initiator of any accident previously evaluated.

As a result, the probability of any accident previously evaluated is not significantly increased. The proposed SRs ensure that the subject systems continue to be capable to perform their assumed safety function and are not rendered inoperable due to gas accumulation. Thus, the consequences of any accident previously evaluated are not significantly increased.

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

2. Does the Proposed Change Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated?

Response: No Page 3 of 5

NG-14-0143 Attachment 1 The proposed change revises or adds SRs that require verification that the ECCS, RHR System, and RCIC System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.

In addition, the proposed change does not impose any new or different requirements that could initiate an accident. The proposed change does not alter assumptions made in the safety analysis and is consistent with the safety analysis assumptions.

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 Change Involve a Significant Reduction in a Margin of Safety?

Response: No The proposed change revises or adds SRs that require verification that the ECCS, RHR System, and RCIC System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change adds new requirements to manage gas accumulation in order to ensure that the subject systems are capable of performing their assumed safety functions. The proposed SRs are more comprehensive than the current SRs and will ensure that the assumptions of the safety analysis are protected. The proposed change does not adversely affect any current plant safety margins or the reliability of the equipment assumed in the safety analysis. Therefore, there are no changes being made to any safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

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

3.2 Applicable Regulatory Requirements/Criteria Based on the above, NextEra Energy Duane Arnold concludes that the proposed change does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(b),

and, accordingly, a finding of "no significant hazards consideration" is justified.

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

Page 4 of 5

NG-14-0143 Attachment 1

5.0 REFERENCES

1. Letter (NG-08-0777) from R. L. Anderson (FPL Energy Duane Arnold, LLC) to Document Control Desk (NRC), "Nine Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," October 13, 2008 (ADAMS Accession No. ML082970263)

2. Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," January 11, 2008, (ADAMS Accession No. ML072910759)

3. Technical Specifications Task Force (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," February 23, 2013, (ADAMS Accession No. ML13053A075)

4. Federal Register Notice of Availability, "TSTF-523, Generic Letter 2008-01 Managing Gas Accumulation Using the Consolidated Line Item Improvement Process" published January 15, 2014 (79 FR 2700).

5. NUREG-1433, Revision 4, Standard Technical Specifications - General Electric BWR/4 Plants, April 2012, (ADAMS Accession No. ML12104A192)

Page 5 of 5

NG-1 4-0143 Attachment 2 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 2 Duane Arnold Technical Specifications Changes Marked Up Pages This coversheet plus 10 pages

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 ------------ NOTE ---------------------------

Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor steam dome pressure is < the RCIC Steam Supply Line Pressure - Low isolation pressure.

Verify one required RHR shutdown cooling In accordance subsystem or recirculation pump is operating. with the Surveillance Frequency Control Program SR 3.4.7.2-- ------------------- NOTE ---------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is < the RCIC Steam Supply Line Pressure - Low isolation pressure.

Verify RHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation the Surveillance are sufficiently filled with water. Frequency Control Program DAEC 3.4-17 Amendment 280-

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR shutdown B.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in circulation by an discovery of no operation. alternate method. reactor coolant circulation AND AND No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.2 Monitor reactor Once per hour coolant temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one required RHR shutdown cooling In accordance with the subsystem or one recirculation pump is Surveillance Frequency operating. Control Program SR 3.4.8.2 Verify RHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation the Surveillance are sufficiently filled with water. Frequency Control Program DAEC 3.4-19 Amendment 26e-

ECCS- Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME N. Two or more low N.1 Enter LCO 3.0.3. Immediately pressure ECCS subsystems inoperable for reasons other than Condition C or D.

OR HPCI System and two or more ADS valves inoperable.

OR HPCI System and two or more low pressure ECCS subsystems inoperable.

OR One ADS valve and two or more low pressure ECCS subsystems inoperable.

OR One ADS valve and HPCI System and one low pressure ECCS subsystem inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray In accordance with the subsvsterthz piping "^filled with w.t.r Surveillance

. h e... . ... .. valve to tile Frequency Control

'njcction -I-. Program (continued) locations susceptible to gas accumulation are sufficiently filled with water.

DAEC 3.5-4 Amendment 28--

NOTE T E................

Not required to be met for system vent flow paths ECCS- Operating opened under administrative control. 3.5.1

/ SURVEILLANCE REQUIREMENTS (continued) ~1*

SURVEILLANCE FREQUENCY SRt3.5.1.2 ------------------- NOTE -------------------

The low pressure coolant injection (LPCI) system may be considered OPERABLE during alignment and operation for decay heat removal in MODE 3, if capable of being manually realigned and not otherwise inoperable.

Verify each ECCS injection/spray subsystem power In accordance operated and automatic valve in the flow path, that is not with the locked, sealed, or otherwise secured in position, is in the Surveillance correct position. Frequency Control Program SR 3.5.1.3 Verify a 100 day supply of nitrogen exists for each ADS In accordance accumulator. with the Surveillance Frequency Control Program SR 3.5.1.4 Verify the following ECCS pumps develop the specified In accordance flow rate against a system head corresponding to the with the specified reactor pressure. Inservice Testing Program SYSTEM HEAD NO. CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF Core Spray _ 2718 gpm 1 > 113 psig LPCI _ 4320 gpm 1 _ 20 psig_

(continued)

DAEC 3.5-5 Amendment280-

ECCS - Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE I FREQUENCY SR 3.5.2.2 Verify, for each required Core Spray (CS) In accordance subsystem, the: with the Surveillance

a. Suppression pool water level is > 8.0 ft; or Frequency Control Program

b. -------------- NOTE -------------------------

Only one required CS subsystem may take credit for this option during OPDRVs.

Condensate storage tank water level in linjection/spray one CST is > 11 ft or > 7 ft in both CSTs.

SR 3.5.2.3 Verify, for each required ECCS b**system, 4Mhe In accordance

_ w-. oe: fiI ... :.:*.1.k

_wS ;.A ;; m.r.m_ i_I . with the dischargce valve te the injeetien valve. Surveillance Frequency locations susceptible to gas accumulation Control Program are sufficiently filled with water.

I SR 3.5.2.4 ---------------------------- NOTE ----------------------------

One LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

Verify each required ECCS subsystem In accordance power operated and automatic valve in the with the flow path, that is not locked, sealed, or Surveillance otherwise secured in position, is in the Frequency correct position. Control Program (continued)

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

Not required to be met for system vent flow paths opened under administrative control.

DAEC 3.5-10 Amendment 28G)

RCIC System 3.5.3 locations susceptible to gas accumulation are sufficiently filled with water.

SURVEILLANCE REQUIREMENTS /

SURVEILLANCE / FREQUENCY i

SR 3.5.3.1 Verify the RCIC System piping is6 filld With In accordance

=.* =M = --feffr ...... -Cý with the injocvtion valve. Surveillance Frequency Control Program

>~ I SR 3.5.3.2 Verify each RCIC System power operated and In accordance automatic valve in the flow path, that is not with the E -

locked, sealed, or otherwise secured in position, Surveillance 1>0 is in the correct position. Frequency Control Program E~c 0w cc w>w SR 3.5.3.3 --------------

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

I- C Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

C7-0 I Verify, with reactor pressure < 1025 psig and In accordance I0I > 940 psig, the RCIC pump can develop a flow with the I Z 0I rate _Ž 400 gpm against a system head Inservice Testing corresponding to reactor pressure. Program SR 3.5.3.4 -NOTE Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure _<160 psig, the RCIC pump can develop a flow rate _>400 gpm against a system head corresponding to In accordance with the Surveillance / /1 reactor pressure. Frequency Control Program (continued)

DAEC 3.5-13 Amendment 28&-

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify by administrative means each RHR In accordance suppression pool cooling subsystem with the manual, power operated and automatic Surveillance valve in the flow path that is not locked, Frequency sealed, or otherwise secured in position is in Control Program the correct position or can be aligned to the correct position.

SR 3.6.2.3.2 Verify each RHR pump develops a flow rate In accordance

> 4800 gpm through the associated heat with the exchanger while operating in the suppression Inservice pool cooling mode. Testing Program SR 3 .6.2.3.3 Verify subsystem RHR locations susceptible to gas the Surveillance suppression accumulation are sufficiently pool filled with water. Frequency Control)I cooling In accordance with]

DAEC 3.6-29 Amendment 28--

RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify by an air test that the suppression In accordance with pool spray header and nozzles are the Surveillance unobstructed. Frequency Control Program SR 3.6.2.4.2 Verify RHR suppression pool spray In accordance with subsystem locations susceptible to gas the Surveillance accumulation are sufficiently filled with water. Frequency Control Program DAEC 3.6-31 Amendment 289-

RHR-High Water Level 3.9.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem circulation by an discovery of no in operation with alternate method. reactor coolant reactor coolant circulation temperature

> 150 0 F.

AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.7.1 Verify one RHR shutdown cooling subsystem is In accordance with operating when reactor coolant temperature is the Surveillance

> 150 'F. Frequency Control Program SR 3.9.7.2 Verify required RHR shutdown cooling In accordance with subsystem locations susceptible to gas the Surveillance accumulation are sufficiently filled with water. Frequency Control Program DAEC 3.9-12 Amendment 280-

RHR-Low Water Level 3.9.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Verify one RHR shutdown cooling In accordance with subsystem is operating. the Surveillance Frequency Control Program SR 3.9.8.2 Verify RHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation the Surveillance are sufficiently filled with water. Frequency Control Program DAEC 3.9-15 Amendment 280

NG-14-0143 Attachment 3 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 3 Duane Arnold Technical Specifications Changes Retyped/Clean Pages This coversheet plus 10 pages

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 ------------------- NOTE--------------

Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor steam dome pressure is < the RCIC Steam Supply Line Pressure - Low isolation pressure.

Verify one required RHR shutdown cooling In accordance subsystem or recirculation pump is operating. with the Surveillance Frequency Control Program SR 3.4.7.2 ------------------- NOTE --------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is < the RCIC Steam Supply Line Pressure - Low isolation pressure.

Verify RHR shutdown cooling subsystem In accordance locations susceptible to gas accumulation are with the sufficiently filled with water. Surveillance Frequency Control Program DAEC 3.4-17 Amendment

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR shutdown B.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in circulation by an discovery of no operation. alternate method. reactor coolant circulation AND AND No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.2 Monitor reactor Once per hour coolant temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one required RHR shutdown cooling In accordance with the subsystem or one recirculation pump is Surveillance Frequency operating. Control Program SR 3.4.8.2 Verify RHR shutdown cooling subsystem In accordance with the locations susceptible to gas accumulation are Surveillance Frequency sufficiently filled with water. Control Program DAEC 3.4-19 Amendment

ECCS- Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME N. Two or more low N.1 Enter LCO 3.0.3. Immediately pressure ECCS subsystems inoperable for reasons other than Condition C or D.

OR HPCI System and two or more ADS valves inoperable.

OR HPCI System and two or more low pressure ECCS subsystems inoperable.

OR One ADS valve and two or more low pressure ECCS subsystems inoperable.

OR One ADS valve and HPCI System and one low pressure ECCS subsystem inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray In accordance with the subsystem, locations susceptible to gas Surveillance accumulation are sufficiently filled with Frequency Control water. Program (continued)

DAEC 3.5-4 Amendment

ECCS- Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.2 --------------------- NOTE--- -----------------

The low pressure coolant injection (LPCI) system may be considered OPERABLE during alignment and operation for decay heat removal in MODE 3, if capable of being manually realigned and not otherwise inoperable.

NOTE Not required to be met for system slow paths opened under administrative control.

Verify each ECCS injection/spray subsystem power In accordance operated and automatic valve in the flow path, that is not with the locked, sealed, or otherwise secured in position, is in the Surveillance correct position. Frequency Control Program SR 3.5.1.3 Verify a 100 day supply of nitrogen exists for each ADS In accordance accumulator. with the Surveillance Frequency Control Program SR 3.5.1.4 Verify the following ECCS pumps develop the specified In accordance flow rate against a system head corresponding to the with the specified reactor pressure. Inservice Testing Program SYSTEM HEAD NO. CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF Core Spray _ 2718 gpm 1 > 113 psig LPCI _ 4320 gpm 1 _ 20 psig I (continued)

DAEC 3.5-5 Amendment

ECCS - Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for each required Core Spray (CS) In accordance subsystem, the: with the Surveillance

a. Suppression pool water level is > 8.0 ft; or Frequency Control Program

b. -------------- NOTE -------------

Only one required CS subsystem may take credit for this option during OPDRVs.

Condensate storage tank water level in one CST is >_11 ft or _>7 ft in both CSTs.

SR 3.5.2.3 Verify, for each required ECCS injection/spray In accordance subsystem, locations susceptible to gas with the accumulation are sufficiently filled with water. Surveillance Frequency Control Program SR 3.5.2.4 ------------------- NOTE ---------------

One LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

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

Not required to be met for system vent flow paths opened under administrative control.

Verify each required ECCS subsystem In accordance power operated and automatic valve in the with the flow path, that is not locked, sealed, or Surveillance otherwise secured in position, is in the Frequency correct position. Control Program (continued)

DAEC 3.5-10 Amendment

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System locations susceptible In accordance to gas accumulation are sufficiently filled with with the water. Surveillance Frequency Control Program SR 3.5.3.2 ------------------- NOTE --------------

Not required to be met for system vent flow paths opened under administrative control.

Verify each RCIC System power operated and In accordance automatic valve in the flow path, that is not with the locked, sealed, or otherwise secured in position, Surveillance is in the correct position. Frequency Control Program SR 3.5.3.3 -------------------- NOTE --------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure ___

1025 psig and In accordance

>_ 940 psig, the RCIC pump can develop a flow with the rate __400 gpm against a system head Inservice Testing corresponding to reactor pressure. Program SR 3.5.3.4 ------------------- NOTE ---------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure < 160 psig, the In accordance RCIC pump can develop a flow rate >_ 400 with the gpm against a system head corresponding to Surveillance reactor pressure. Frequency Control Program (continued)

DAEC 3.5-13 Amendment

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify by administrative means each RHR In accordance suppression pool cooling subsystem with the manual, power operated and automatic Surveillance valve in the flow path that is not locked, Frequency sealed, or otherwise secured in position is in Control Program the correct position or can be aligned to the correct position.

SR 3.6.2.3.2 Verify each RHR pump develops a flow rate In accordance

_>4800 gpm through the associated heat with the exchanger while operating in the suppression Inservice pool cooling mode. Testing Program SR 3.6.2.3.3 Verify RHR suppression pool cooling In accordance subsystem locations susceptible to gas with the accumulation are sufficiently filled with water. Surveillance Frequency Control Program DAEC 3.6-29 Amendment

RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify by an air test that the suppression In accordance with pool spray header and nozzles are the Surveillance unobstructed. Frequency Control Program SR 3.6.2.4.2 Verify RHR suppression pool spray In accordance with subsystem locations susceptible to gas the Surveillance accumulation are sufficiently filled with Frequency Control water. Program DAEC 3.6-31 Amendment

RHR-High Water Level 3.9.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown C. 1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem circulation by an discovery of no in operation with alternate method, reactor coolant reactor coolant circulation temperature

> 150 0 F.

AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.7.1 Verify one RHR shutdown cooling subsystem is In accordance with operating when reactor coolant temperature is the Surveillance

>150 OF. Frequency Control Program SR 3.9.7.2 Verify required RHR shutdown cooling In accordance with subsystem locations susceptible to gas the Surveillance accumulation are sufficiently filled with water. Frequency Control Program DAEC 3.9-12 Amendment

RHR-Low Water Level 3.9.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Verify one RHR shutdown cooling In accordance with subsystem is operating. the Surveillance Frequency Control Program SR 3.9.8.2 Verify RHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation the Surveillance are sufficiently filled with water. Frequency Control Program DAEC 3.9-15 Amendment

NG-14-0143 Attachment 4 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 4 Duane Arnold Technical Specifications Bases Changes Marked Up Pages For Information Only This coversheet plus 28 pages

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 BASES LCO associated heat exchanger in each of the two loops must be (continued) OPERABLE. Since the piping and heat exchangers are passive components that are assumed not to fail, they are allowed to be common to both subsystems. Thus, two RHR pumps in a common RHR subsystem, together with the associated heat exchanger and flow path components, constitutes two OPERABLE RHR shutdown cooling subsystems. Each shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. In MODE 3, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy. Operation of one subsystem can maintain or reduce the reactor coolant temperature as required. To ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation of one RHR shutdown cooling Management of gas subsystem is requrjed.>

voids is important to RHR Shutdown Cooling Note 1 permits both required RHR shutdown cooling subsystems.

System OPERABILITY. to not be in operation for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

l INIULe i adllUWs UIIe Ieq*rIeu rl-r- SIlULUUWII coUUolng SU SLeytM Lu be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillance tests. These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR System in an inoperable status during the performance. This is permitted because the core heat generation can be low enough and the heatup rate slow enough to allow some changes to the RHR subsystems or other operations requiring RHR flow interruption and loss of redundancy.

APPLICABILITY In MODE 3 with reactor steam dome pressure below the RCIC Steam Supply Line Pressure - Low isolation pressure the RHR System must be OPERABLE and shall be operated in the shutdown cooling mode to remove decay heat to reduce or maintain coolant temperature. Otherwise, a recirculation pump is required to be in operation.

In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RCIC Steam Supply Line Pressure - Low isolation pressure, this LCO is not applicable. Operation of the RHR System in the shutdown cooling mode is not allowed above the RHR shutdown cooling isolation interlock pressure (which is slightly higher than the (continued)

DAEC B 3.4-38 4seR=26 DAEC B3.4-38

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 BASES SURVEILLANCE SR 3.4.7.1 (continued)

REQUIREMENTS of this Specification in accordance with SR 3.0.4 since the Surveillance will not be "not met" at the time of entry into the Applicability.

REFERENCES Non.

INSERT 1 next page DAEC B 3.4-42 Amendment22-

INSERT 1 I SR 3.4.7.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

Ifaccumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

This SR is modified by a Note that states the SR is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is less than RCIC Steam Supply Line Pressure - Low isolation pressure. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering the Applicability.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR Shutdown Cooling System - Cold Shutdown B 3.4.8 BASES LCO Thus, to meet the LCO, both pumps and a heat exchanger in one (continue d) loop or one pump and an associated heat exchanger in each of the two loops must be OPERABLE. Since the piping and heat exchangers are passive components that are assumed not to fail, they are allowed to be common to both subsystems. Thus, two RHR pumps in a common RHR subsystem, together with the associated heat exchanger and flow path components, constitute two OPERABLE RHR shutdown cooling subsystems. In addition, the RHR cross tie valve (MO-2010) may be opened to allow pumps in one loop to discharge through the opposite recirculation loop to make a complete subsystem. Additionally, each shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. In MODE 4, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy. Operation of one subsystem can maintain or reduce the reactor coolant temperature as required. To ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring nearly continuous operation of a recirculation pump or one RHR shutdown cooling subsystem is reauiwrd>

Management of gas voids is Note 1 permits both required RHR shutdown cooling subsystems important to RHR to not be in operation for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

Shutdown Cooling Note 2 allows one required RHR shutdown cooling subsystem to System be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of OPERABILITY. Surveillance tests. These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR System in an inoperable status during the performance. This is permitted because the core heat generation can be low enough and the heatup rate slow enough to allow some changes to the RHR subsystems or other operations requiring RHR flow interruption and loss of redundancy.

(continued)

DAEC B 3.4-44 DAECB 3.-44-¶8eR--26A-

RHR Shutdown Cooling System - Cold Shutdown B 3.4.8 BASES ACTIONS B.1 and B.2 (continued)

With no RHR shutdown cooling subsystem and no recirculation pump in operation except as permitted by LCO Note 1, and until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This alternate method may consist of the losses to ambient surroundings if such losses are sufficiently large so as to prevent RCS temperature from increasing and if natural circulation has been established. This will provide the necessary circulation for monitoring coolant temperature. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation. Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This will provide assurance of continued temperature monitoring capability. Alternate methods of reactor coolant circulation that can be used include (but are not limited to) raising reactor water level above the minimum natural circulation level (i.e., lowest turnaround point for water in the steam separator) and Reactor Water Cleanup System.

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR Shutdown Cooling System or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This Surveillance verifies that one required RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The RHR shutdown cooling subsystem or recirculation pump flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability.

The Surveillance Frequency is controlled under the Surveillance \I/

Frequency Control Program. The Frequency is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR subsystem in the control room.

INSERT 2 next page (continued)

DAEC B 3.4-47

SR 3.4.8.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

ECCS - Operating B 3.5.1 BASES LCO Each ECCS injection/spray subsystem and four ADS valves are required to be OPERABLE. The ECCS injection/spray subsystems are defined as the two CS subsystems, the LPCI System, and one HPCI System. The low pressure ECCS subsystems are defined as the two CS subsystems and the LPCI Management of System.

gas voids is With less than the required number of ECCS subsystems important to ECCS OPERABLE, the potential exists that during a limiting design basis injection/spray LOCA concurrent with the worst case single failure, the limits subsystem specified in Reference 10 could be exceeded. All ECCS OPERABILITY. subsystems must therefore be OPERABLE to satisfy the single failure criterion required by Reference 10.

The LPCI System may be considered OPERABLE during alignment and operation for decay heat removal (i.e.- Shutdown Cooling) when below the actual RHR Shutdown Cooling interlock pressure in MODE 3, if capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable.

At these low pressures and decay heat levels, a reduced complement of ECCS subsystems should provide the required core cooling, thereby allowing operation of RHR shutdown cooling when necessary. In addition, the risk of a LOCA during the transition from the RHR interlock pressure to cold shutdown is minimal.

APPLICABILITY All ECCS subsystems are required to be OPERABLE during MODES 1, 2, and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure is

< 150 psig, HPCI is not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. In MODES 2 and 3, when reactor steam dome pressure is _<100 psig, ADS is not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. ECCS requirements for MODES 4 and 5 are specified in LCO 3.5.2, "ECCS -

Shutdown."

(continued)

DAEC B 3.5-6 D3SR-112

ECCS - Operating B 3.5.1 BASES ACTIONS M.1 and M.2 (continued)

If any Required Action and associated Completion Time of Condition K or L is not met, or if two or more ADS valves are inoperable, the plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reactor steam dome pressure reduced to < 100 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

N.1 When multiple ECCS subsystems are inoperable, as stated in Condition N, the plant is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS L* mat mm* m ba..a aato.i-. naanlub n p ets of entrained air. Maintaining the pump discharge linee the I system, CS system, and LPCI subsystems full o ater (up to the rmally closed injection valve) ensures tha e ECCS will perform p erly, injecting its full capacity into RCS upon demand. This wi Iso prevent a potential wa ammer following an ECCS in" tion signal. An ac table method of nxNSt Tg ensuring that the CS or LlI dischar ines are full is to vent at Inext page the respective high points. h cceptable method for CS and LPCI is to verify the abse their respective discharge line Low Pressure Annuciator rms. Ac table methods for HPCI are the combination o nting at high poi and, either ensuring adequate CST wa level or that the HPCI Lo Pressure Keep Fill is in servic . he Surveillance Frequency is c rolled under the Survei ce Frequency Control Program. The Fr ency is based the gradual nature of bubble buildup in the EC pi g, the procedural controls governing system operation an (continued)

DAEC B 3.5-13 B3,5-13TseR=12(e-rAEr

JINSERT 3I The ECCS injection/spray subsystem flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS injection/spray subsystems and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of ECCS injection/spray subsystem locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The ECCS injection/spray subsystem is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS injection/spray subsystem is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS injection/spray subsystem locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

ECCS - Operating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.2 REQUIREMENTS (continued) Verifying the correct alignment for power operated and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply 0j 0 -o to manual valves or valves that cannot be inadvertently misaligned, such as check valves. For the HPCI System, this SR also includes the steam flow path for the turbine and the flow

0) =.0 controller position.

CL

ý0 0 a

. 02 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Frequency of this SR was derived from the Inservice Testing Program requirements for

> -t performing valve testing. The Frequency is further justified because the valves are operated under procedural control and CL C W a because improper valve position would only affect a single Ea) .--

,. 0 subsystem. This Frequency has been shown to be acceptable X 0I through operating experience.

0I >

aD a) >- In Mode 3 with reactor steam dome pressure less than the actual RHR interlock pressure, the RHR System may be required to cc a) a operate in the shutdown cooling mode to remove decay heat and ca a)4 o0 -a 0 sensible heat from the reactor. Therefore, this SR is modified by 2 cU Note 1, which allows the LPCI System to be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable. Manual alignment I 0 0 E C of the RHR cross tie valves (M02010 and V-19-48) may only be ,/

. CM LI) cc CS E . credited when the valves are soft seated per normal operating X a

procedure in order to prevent inoperability due to thermal binding.

-.r 0 0 cc ' U 0 Alignment and operation for decay heat removal includes when the required RHR pump is not operating or when the system is U)~4) realigned from or to the RHR shutdown cooling mode. At the low pressures and decay heat loads associated with operation in

.CC~ 0 (a H 0. .9C Mode 3 with reactor steam dome pressure less than the RHR interlock pressure, a reduced complement of low pressure ECCS subsystems should provide the required core cooling, thereby allowing operation of RHR shutdown cooling, when necessary.

(continued)

-TseR-1~

B 3.5-14 DAEC B 3.5-14 T-6GR 1

ECCS - Shutdown B 3.5.2 BASES LCO Vessel (RPV)*. Each LPCI subsystem consists of one motor (continued) driven RHR pump, piping, and valves to transfer water from the suppression pool to the RPV. Only a single RHR pump is required per subsystem because of the larger injection capacity in relation to a CS subsystem. In MODES 4 and 5, the RHR System Management of cross tie valve is noto be oper.. The necessary portions gas voids is of Emergency Service Water are also required to provide important to ECCS appropriate cooling to each required CS subsystem. One LPCI injection/spray subsystem may be aligned for decay heat removal and considered OPERABLE for the ECCS function, if it can be subsystem manually realigned (remote or local) to the LPCI mode and is not OPERABILITY. otherwise inoperable. Because of low pressure and low temperature conditions in MODES 4 and 5, sufficient time will be available to manually align and initiate LPCI subsystem operation to provide core cooling prior to postulated fuel uncovery.

During Refuel Outage (RFO) 23, the CS minimum flow path is not required to{,

be available for CS to be considered OPERABLE.

APPLICABILITY OPERABILITY of the low pressure ECCS subsystems is required in MODES 4 and 5 to ensure adequate coolant inventory and sufficient heat removal capability for the irradiated fuel in the core in case of an inadvertent draindown of the vessel. Requirements for ECCS OPERABILITY during MODES 1, 2, and 3 are discussed in the Applicability section of the Bases for LCO 3.5.1.

ECCS subsystems are not required to be OPERABLE during MODE 5 with the spent fuel storage pool gates removed and the water level maintained at > 21 ft 1 inch above the RPV flange.

This provides sufficient coolant inventory to allow operator action to terminate the inventory loss prior to fuel uncover in case of an inadvertent draindown.

The Automatic Depressurization System is not required to be OPERABLE during MODES 4 and 5 because the RPV pressure is

_<100 psig, and the CS and LPCI subsystems can provide core cooling without any depressurization of the primary system.

The High Pressure Coolant Injection System is not required to be OPERABLE during MODES 4 and 5 since the low pressure ECCS subsystems can provide sufficient flow to the vessel and because insufficient reactor pressure is available to drive the HPCI turbine.

(continued)

DAEC B 3.5-22 TseR-1

ECCS - Shutdown B 3.5.2 BASES SURVEILLANCE SR 3.5.2.4 (continued)

REQUIREMENTS valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it 0 *involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply

°+ U) to manual valves or to valves that cannot be inadvertently

-" ,misaligned, such as check valves. The Surveillance Frequency is

-> controlled under the Surveillance Frequency Control Program.

E 0'0 The Frequency is appropriate because the valves are operated W () :S

>'=cI under procedural control and the probability of their being

-I E mispositioned during this time period is low.

W=

C>0 In Modes 4 and 5, the RHR System may be required to operate in

=. the shutdown cooling mode to remove decay heat and sensible

-o o . heat from the reactor. Therefore, this SR is modified by a Note

'u *that allows one LPCI subsystem to be considered OPERABLE SE -- " during alignment and operation for decay heat removal, if capable a) 0 2 ca of being manually realigned (remote or local) to the LPCI mode CU, and not otherwise inoperable. Alignment and operation for decay 0- heat removal includes when the required RHR pump is not I- .E operating or when the system is realigned from or to the RHR 4- Co >* shutdown cooling mode. Because of the low pressure and low 0 0 E temperature conditions in Modes 4 and 5, sufficient time will be

_ -. available to manually align and initiate LPCI subsystem operation

= 0 to provide core coverage prior to postulated fuel uncovery. This co 8C will ensure adequate core cooling if an inadvertent RPV draindown should occur.

REFERENCES 1. UFSAR, Section 15.2.1.1.

DAEC B 3.5-26 DAECB 3.-26 SGR 126-

RCIC System B 3.5.3 BASES BACKGROUND The RCIC pump is provided with a minimum flow bypass line, (continued) which discharges to the suppression pool. The valve in this line automatically opens to prevent pump damage due to overheating when other discharge line valves are closed. To ensure rapid delivery of water to the RPV and to minimize water hammer effects, the RCIC System discharge piping is kept full of water.

The RCIC System is normally aligned to the CST. The height of water in the CST is sufficient to maintain the piping full of water up to the first isolation valve. The relative height of the feedwater line connection for RCIC is such that the water in the feedwater lines keeps the remaining portion of the RCIC discharge line full of water. Therefore, RCIC does not require a "keep fill" system when its suction is aligned to the CST. When RCIC suction is aligned to the suppression pool and the system is not in operation, an alternate means of keeping the discharge piping full is required to support system OPERABILITY.

APPLICABLE The function of the RCIC System is to respond to transient events SAFETY by providing makeup coolant to the reactor. The RCIC System is ANALYSES not an Engineered Safety Feature System and no credit is taken in the safety analyses of design basis events for RCIC System operation. Based on its contribution to the reduction of overall plant risk, however, the system satisfies Criterion 4 of 10 CFR V

50.36(c)(2)(ii).

LCO The OPERABILITY of the RCIC System provides adequate core cooling in the event of RPV isolation accompanied by a loss of Feedwater flow. The RCIC System has sufficient capacity for maintaining RPV inventory during an isolation event.

APPLICABILITY The RCIC System is required to be OPERABLE during MODE 1, and MODES 2 and 3 with reactor steam dome pressure

> 150 psig, since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized. In MODES 2 and 3 with reactor steam dome pressure < 150 psig, and in MODES 4 and 5, RCIC is not required to be OPERABLE since the low pressure ECCS subsystems can provide sufficient flow to the RPV and since RPV pressure is insufficient to drive the RCIC turbine.

Management of gas voids is important to RCIC System OPERABILITY.

(continued)

DAEC B 3.5-28 44 conti)seR

RCIC System B 3.5.3 BASES ACTIONS B.1 and B.2 (continued)

If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reactor steam dome pressure reduced to < 150 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.5.3.1 REQUIREMENT FS 27poc of entrained air. Maintaining the pump dischar of the RCIC em full of water ensures that the sys ill perform properly, injectin i ull capacity into the R G-on demand.

INSER T 4' This will also prevent ettntial watej-.J~amer following an next pager initiation signal. One accep ethod of ensuring that the lines are full is to vent at the h oints *tRCICsuction aligned to the CST. The Su nce Frequency is trolled under the N Surveillance quency Control Program. The uency is base e gradual nature of bubble buildup in the C piping,~

procedural controls governing system operation and op ng SR 3.5.3.2 Verifying the correct alignment for power operated and automatic valves in the RCIC flow path provides assurance that the proper flow path will exist for RCIC operation. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to manual valves or to valves that cannot be inadvertently misaligned, such as check valves. For the RCIC System, this SR also includes the steam flow path for the turbine and the flow controller position.

(continued)

DAEC B 3.5-30 Ts ;1ýý

JINSERT 4 The RCIC System flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RCIC System and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RCIC System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The RCIC System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. Ifaccumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RCIC System is not rendered inoperable by the accumulated (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RCIC System locations susceptible to gas accumulation are monitored and, ifgas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RCIC System B 3.5.3 BASES SURVEILLANCE SR 3.5.3.2 (continued)

REQUIREMENTS The Surveillance Frequency is controlled under the Surveillance

'n E Frequency Control Program. The Frequency of this SR was derived from the Inservice Testing Program requirements for Co Cn performing valve testing. The Frequency is further justified because the valves are operated under procedural control and

/IK\

-C 0~~U because improper valve position would affect only the RCIC System. This Frequency has been shown to be acceptable 0 > F)

CU) through operating experience.

ao ) -0 0>

CoU) 0 -'-

-o SR 3.5.3.3 and SR 3.5.3.4 0)

X .-

.E C.)0~

- -0 The RCIC pump flow rates ensure that the system can maintain reactor coolant inventory during pressurized conditions with the RPV isolated. The flow tests for the RCIC System are performed 405 E at two different pressure ranges such that system capability to 0 WE provide rated flow is tested both at the higher and lower operating 0 0~~C>

ranges of the system. Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the RCIC System E 0 .0 (n ca diverts steam flow. Reactor steam pressure must be > 940 psig to Cocc 0 00 o. perform SR 3.5.3.3, the high pressure test, and < 160 psig to perform SR 3.5.3.4, the low pressure test. Adequate steam flow is represented by approximately 0.4 turbine bypass valves open.

Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these SRs. Reactor startup is 0 Z0.C)> allowed prior to performing the low pressure Surveillance because the reactor pressure is low and the time allowed to satisfactorily perform the Surveillance is short. The reactor pressure is allowed to be increased to normal operating pressure since it is assumed that the low pressure Surveillance has been satisfactorily completed and there is no indication or reason to believe that RCIC is inoperable.

Therefore, these SRs are modified by Notes that state the Surveillances are not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam pressure and flow are adequate to perform the test. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance to reach the required pressure and flow is sufficient to achieve stable conditions for testing and provide a reasonable time to complete the SRs.

(continued)

DAEC B 3.5-31

RHR Suppression Pool Cooling B 3.6.2.3 BASES (continued)

APPLICABLE Reference 1 contains the results of analyses used to predict SAFETY primary containment pressure and temperature following large ANALYSES and small break LOCAs. The intent of the analyses is to demonstrate that the heat removal capacity of the RHR Suppression Pool Cooling System is adequate to maintain the primary containment conditions within design limits. The suppression pool temperature is calculated to remain below the design limit.

The RHR Suppression Pool Cooling System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO During a DBA, a minimum of one RHR suppression pool cooling subsystem is required to maintain the primary containment peak pressure and temperature below design limits (Ref. 1) To ensure that these requirements are met, two RHR suppression pool Management of cooling subsystems must be OPERABLE. Therefore, in the event gas voids is of an accident, at least one subsystem is OPERABLE assuming important to RHR the worst case single active failure. An RHR suppression pool Suppression Pool cooling subsystem is OPERABLE when both of the RHR pumps, Cooling System the heat exchanger, and associated piping, valves, OPERABILITY. -- --. instrumentation, and controls are OPERAB APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment and cause a heatup and pressurization of primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES.

Therefore, the RHR Suppression Pool Cooling System is not required to be OPERABLE in MODE 4 or 5.

(continued)

DAEC B 3.6-60 -TSGR-E)44-

RHR Suppression Pool Cooling B 3.6.2.3 BASES (continued)

SURVEILLANCE SR 3.6.2.3.1 REQUIREMENTS Verifying by administrative means the correct alignment for manual, power operated and automatic valves in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool cooling mode is manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to manual valves or to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Frequency is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the subsystem is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.

SR 3.6.2.3.2 Verifying that each RHR pump develops a flow rate > 4800 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that the primary containment peak pressure and temperature and the local suppression pool temperature can be maintained below design limits. This test also verifies that pump performance has not degraded during the surveillance interval. Flow is a normal test of centrifugal pump performance required by ASME Code,Section XI (Ref. 2). This test confirms one point on the pump design curve, and the results are indicative of overall performance. Such inservice testing confirms component OPERABILITY, trends performance, and detects incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservice Testing Program.

INSERT 5 next page (continued)

DAEC B 3.6-63

fINSERT 5 1 SR 3.6.2.3.3 RHR Suppression Pool Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR Suppression Pool Cooling subsystems and may also prevent a water hammer and pump cavitation.

Selection of RHR Suppression Pool Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The RHR Suppression Pool Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. Ifaccumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. Ifit is determined by subsequent evaluation that the RHR Suppression Pool Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Suppression Pool Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR Suppression Pool Spray B 3.6.2.4 BASES (continued)

APPLICABLE Reference 1 contains the results of analyses used to predict SAFETY primary containment pressure and temperature following large ANALYSES and small break loss of coolant accidents. These analyses demonstrate that the pressure reduction capacity of the RHR Suppression Pool Spray System is not required to maintain the primary containment conditions within design limits. The time history for primary containment pressure is calculated to demonstrate that the maximum pressure remains below the design limit even without the use of RHR Suppression Pool Spray.

The RHR Suppression Pool Spray is retained in the conversion from the DAEC Technical Specifications to the Improved Technical Specifications (ITS)(see Reference 2), because this function was found to satisfy Criterion 3 of 10 CFR 50.36 (c)(2)(ii) during the development of NUREG-1433.

LCO One RHR suppression pool spray subsystem should be available to assist with any potential bypass leakage (Ref. 1). To ensure that this back-up capability is available, two RHR suppression Management of pool spray subsystems must be OPERABLE with power from two gas voids is safety related independent power supplies. Therefore, at least important to RHR one subsystem will be OPERABLE assuming the worst case single active failure. An RHR suppression pool spray subsystem Suppression Pool is OPERABLE when one of the pumps and associated piping Spray System (including spargers), valves, instrumentation, and controls are OPERABILITY.

APPLICABILITY In MODES 1, 2, and 3, the reactor is pressurized and could cause pressurization of primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES.

Therefore, maintaining RHR suppression pool spray subsystems OPERABLE is not required in MODE 4 or 5.

(continued)

DAEC B 3.6-66 (continued)

RHR Suppression Pool Spray B 3.6.2.4 BASES (continued)

SURVEILLANCE SR 3.6.2.4.1 REQUIREMENTS Verifying that the spray header and nozzles are unobstructed assures that the suppression pool airspace can be sprayed when desired. An air test is specified as this test is generally performed on both the drywell and suppression pool spray nozzles at the same time and it is not desirable to spray water into the drywell, due to the adverse impact on equipment located there.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Operating experience has shown 1K that these components usually pass the SR when performed at INSERT 6 this Frequency. Therefore, the Frequency was concluded to be acceptable from the reliability standpoint.

next page REFERENCES 1. UFSAR, Section 15.2.1.

2. NG-98-0342, J. Franz (IES) to U.S. NRC, "Request for Technical Specification Change (RTS-291): Revision E to the Duane Arnold Energy Center Improved Technical Specifications," February 26, 1998.

DAEC B 3.6-68 DAEC B3.6-68-feeR1-!2

JINSERT 6 SR 3.6.2.4.2 RHR Suppression Pool Spray System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR Suppression Pool Spray subsystem and may also prevent a water hammer and pump cavitation.

Selection of RHR Suppression Pool Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The RHR Suppression Pool Spray System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Suppression Pool Spray System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Suppression Pool Spray System locations susceptible to gas accumulation are monitored and, ifgas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR - High Water Level B 3.9.7 BASES (continued)

LCO Only one RHR shutdown cooling subsystem is required to be OPERABLE in MODE 5 with irradiated fuel in the RPV and the water level > 21 ft-1 inch above the top of the RPV flange. A minimum water level of 21 ft-1 inch above the top of the RPV flange corresponds to a level of 36 ft in the Spent Fuel Pool (SFP). Therefore, SFP water level indication may be used to monitor RPV level when the RPV is flooded up and the SFP gates are removed. Other means of monitoring RPV water level are used when those conditions are not present. Only one subsystem is required because the volume of water above the RPV flange provides backup decay heat removal capability. In addition, when the reactor coolant temperature is > 150'F, one RHR shutdown cooling subsystem is required to be in operation to provide an active decay heat removal capability. At reactor coolant temperatures less than 150 0F, natural circulation alone is adequate to provide the required decay heat removal capability while maintaining adequate margin to the reactor coolant temperature (212'F) at which a MODE change would occur.

An OPERABLE RHR shutdown cooling subsystem consists of one RHR pump, a heat exchanger, an RHRSW pump providing cooling to the heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path. In addition, the necessary portions of the Emergency Service Water and River Water Supply System and Ultimate Heat Sink are required to provide appropriate cooling and a suction source to each required RHRSW pump.

Additionally, each RHR shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat.

Operation (either continuous or intermittent) of one subsystem can maintain and reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring when the reactor coolant temperature is _>150°F, nearly continuous operation is required. A Note is provided to allow a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months exception for the operating subsystem to not be in operation during any 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. This 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period is a continuous rolling clock. The 2 Management of gas hour exception provides operational flexibility for varying plant voids is important to conditions.

RHR Shutdown Cooling System OPERABILITY.

(continued)

DAEC B 3.9-23 TI%-, - A,*

RHR - High Water Level B 3.9.7 BASES ACTIONS C.1 and C.2 (continued)

If no RHR shutdown cooling is in operation when reactor coolant temperature is > 150'F, except as permitted by the LCO Note, an alternate method of coolant circulation is required to be established within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . However, with the water level high, coolant circulation is assured by virtue of being flooded up to a level significantly higher than the minimum natural circulation level (i.e., lowest turnaround point for water in the steam separator) and thus, Required Action C.1 is met.

During the period of time when the reactor coolant is either being naturally circulated or circulated by another alternate method, the reactor coolant temperature must be periodically monitored to ensure proper circulation is maintained. The once per hour Completion Time is deemed appropriate due to the passive nature of the circulation process.

SURVEILLANCE SR 3.9.7.1 REQUIREMENTS This Surveillance demonstrates that the RHR subsystem is in operation and circulating reactor coolant when reactor coolant temperature is 2! 150'F.

The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability corresponding to the decay heat load that is present. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Frequency is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR INSERT 7 subsystem in the control room.

next page]

REFERENCES 1. UFSAR, Section 3.1.2.4.5.

2. UFSAR, Section 5.4.7.2.2.

DAEC B 3.9-26 T-eR=

JINSERT 7 SR 3.9.7.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

Ifaccumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR - Low Water Level B 3.9.8 BASES (continued)

LCO In MODE 5 with irradiated fuel in the RPV and the water level

< 21 ft-1 inch above the top of the RPV flange, two RHR shutdown cooling subsystems must be OPERABLE.

An OPERABLE RHR shutdown cooling subsystem consists of one RHR pump, a heat exchanger, an RHRSW pump providing cooling to the heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path. To meet the LCO, both pumps in one loop or one pump in each of the two loops must be OPERABLE. In addition, the necessary portions of the Emergency Service Water and River Water Supply Systems and the Ultimate Heat Sink are required to provide appropriate cooling Management of gas and a suction source to each required RHRSW u voids is important to RHR Shutdown Additionally, each RHR shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or Cooling System local) in the shutdown cooling mode for removal of decay heat.

OPERABILITY. Operation (either continuous or intermittent) of one subsystem can maintain and reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required. A Note is provided to allow a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months exception for the operating subsystem to not be in operation during any 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. This 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period is a continuously rolling clock. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months exception provides operational flexibility for varying plant conditions.

APPLICABILITY Two RHR shutdown cooling subsystems are required to be OPERABLE, and one must be in operation in MODE 5, with irradiated fuel in the RPV and with the water level < 21 ft-1 inch above the top of the RPV flange, to provide decay heat removal.

RHR System requirements in other MODES are covered by LCOs in Section 3.4, REACTOR COOLANT SYSTEM (RCS). RHR Shutdown Cooling System requirements in MODE 5 with irradiated fuel in the RPV and with the water level 2!21 ft-1 inch above the top of the RPV flange are given in LCO 3.9.7, "Residual Heat Removal (RHR) - High Water Level."

(continued)

DAEC B 3.9-28 D-TCR-026A

RHR - Low Water Level B 3.9.8 BASES (continued)

SURVEILLANCE SR 3.9.8.1 REQUIREMENTS This Surveillance demonstrates that one RHR shutdown cooling subsystem is in operation and circulating reactor coolant. The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability corresponding to the decay heat load that is present.

The Surveillance Frequency is controlled under the Surveillance INSERT 8 Frequency Control Program. The Frequency is sufficient in view next page oof other visual and audible indications available to the operator for monitoring the RHR subsystems in the control room.

REFERENCES 1. UFSAR, Section 3.1.2.4.5.

2. UFSAR, Section 5.4.7.2.2.

DAEC B 3.9-31 TSCR-120

INSERT 8 SR 3.9.8.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.