NL-06-2872, Technical Specifications Revision to Adopt TSTF-484, Revision 0 Use of TS 3.10.1 for Scram Time Testing Activities
| ML070360149 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 02/02/2007 |
| From: | Stinson L Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-06-2872 | |
| Download: ML070360149 (35) | |
Text
Southern Nuclear Operating Company, Inc.
Post Off ice Box 1295 Birmingham, Alabama 35201 -1 295 February 2, 2007 Docket Nos.:
50-321 50-366 Energy to Serve Your World" U. S. Nuclear Regulatory Commission A m : Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Technical Specifications Revision to Adopt TSTF-484, Revision 0 Use of TS 3.10.1 for Scram Time Testing Activities Ladies and Gentlemen:
In accordance with the provisions of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby proposes a change to the Edwin I. Hatch Nuclear Plant Unit 1 and Unit 2 Technical Specifications, Appendix A to operating licenses DPR-57 and NPF-5, respectively.
This request proposes to revise LC0 3.10.1 of the Plant Hatch Technical Specifications (TS) to expand its scope to include provisions for temperature excursions greater than 21 2°F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of this TS improvement was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the consolidated line item improvement process (CLIIP). provides an evaluation of the proposed change. Enclosure 2 provides the marked-up and clean typed TS pages and Enclosure 3 provides the marked-up and clean typed TS Bases pages.
In accordance with 10 CFR 50.91, a copy of this letter and all applicable attachments will be sent to the designated state official of the Environmental Protection Division of the Georgia Department of Natural Resources.
SNC requests approval of the proposed changes no later than February 1,2008 with the amendment being implemented within 30 days of receiving the approval.
U. S. Nuclear Regulatory Commission NL-06-2872 Page 2 Mr. L. M. Stinson states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.
This letter contains no NRC commitments. If you have any questions, please advise.
Respectllly submitted, SOUTHERN NUCLEAR OPERATING COMPANY L. M. Stinson Vice President - Fleet Operations Support Sworn to and subscribed before me thisdnd day of hhr* ff r v Notary Public My commission expires:."/ 5, 2010
Enclosures:
- 1. Evaluation of Proposed Change
- 2. Marked-up and Clean Typed TS Pages
- 3. Marked-up and Clean Typed TS Bases Pages cc:
Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. D. R. Madison, Vice President - Hatch RTYPE: CHA02.004 U. S. Nuclear Regulatory Commission Dr. W. D. Travers, Regional Administrator Mr. R, E. Martin, NRR Project Manager - Hatch Mr. D. S. Simpkins, Senior Resident Inspector - Hatch State of Georgia Mr. L. C. Barrett, Commissioner - Department of Natural Resources Edwin I. Hatch Nuclear Plant Technical Specifications Revision LC0 3.10.1 -Inservice Leak and Hydrostatic Testing Operation Evaluation of Proposed Change Edwin I. Hatch Nuclear Plant Technical Specifications Revision LC0 3.10.1 -Inservice Leak and Hydrostatic Testing Operation Evaluation of Proposed Change 1.0 Description The proposed amendment would revise LC0 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 212°F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.1 0.1 for Scram Time Testing Activities." The availability of the TS 3.10.1 revision was announced in the Federal Register on October 27,2006 (71 FR 63050) as part of the consolidated line item improvement process (CLIP).
2.0 Proposed Change Consistent with the NRC approved Revision 0 of TSTF-484, the proposed changes to HNP 1 and HNP 2 Technical Specifications (TS) include a revised TS 3.10.1, "Inservice Leak and Hydrostatic Testing Operation." Proposed revisions to the TS Bases are also included in this application. Adoption of the TS Bases associated with TSTF-484, Revision 0 is an integral part of implementing this TS amendment. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.
This application is being made in accordance with the CLIIP. SNC is not proposing variations or deviations from the TS changes described in TSTF-484, Revision 0, or the NRC staffs model safety evaluation (SE) published on October 27,2006 (71 FR 63050) as part of the CLIP Notice of Availability.
3.0 Background
The background for this application is adequately addressed by the NRC Notice of Availability published on October 27,2006 (71 FR 63050).
4.0 Technical Analysis SNC has reviewed the safety evaluation (SE) published on October 27,2006 (71 FR 63050) as part of the CLIP Notice of Availability. SNC has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to HNP, Units 1 and 2 and therefore justify this amendment for the incorporation of the proposed changes to the HNP TS.
5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Determination SNC has reviewed the no significant hazards determination published on August 21,2006 (71 FR 48561) as part of the CLIIP Notice for Comment. The no significant hazards determination was made available on October 27,2006 (7 1 FR 63050) as part of the CLIIP Notice of Availability.
Technical Specifications Revision LC0 3.10.1 -Inservice Leak and Hydrostatic Testing Operation Evaluation of Proposed Change Page 2 Of 2 SNC has concluded that the determination presented in the notice is applicable to HNP, Units I and 2, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).
5.2 Applicable Regulatory Requirements/Criteria A description of the proposed TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability published on October 27, 2006 (71 FR 63050).
6.0 Environmental Consideration SNC has reviewed the environmental evaluation included in the safety evaluation (SE) published on October 27,2006 (71 FR 63050) as part of the CLIP Notice of Availability. SNC has concluded that the staffs findings presented in that evaluation are applicable to HNP, Units 1 and 2, and the evaluation is hereby incorporated by reference for this application.
7.0 References
- 1. Federal Register Notice, Notice of Availability published on November 27,2006 (71 FR 68642)
- 2. Federal Register Notice, Notice of Availability published on October 27, 2006 (71 FR 63050)
- 3. Federal Register Notice, Notice for Comment published on August 21, 2006 (71 FR 48561)
Edwin I. Hatch Nuclear Plant Technical Specifications Revision LC0 3.10.1 -1nservice Leak and Hydrostatic Testing Operation Marked-up and Clean Typed TS Pages
lnservice Leak and Hydrostatic Testing Operation 3.10.1 3.1 0 SPECIAL OPERATIONS 3.1 0.1 lnservice Leak and Hydrostatic Testing Operation The average reactor coolant temperature specified in Table 1.l-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LC0 3.4.8, "Residual Heat Removal suspendea
- a.
LC0 3.3.6.2, "Secondary Containment Isolation Instrumentation,"
Functions 1.3. a n d L L o f ~ A M. ~ 1 ; - - - - - - - -
LC0 3.6.4.1, "Secondary Containment";
LC0 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)";
and LC0 3.6.4.3, "Standby Gas Treatment (SGT) System."
APPLICABILITY:
MODE 4 with average reactor coolant temperature > 212°F.
ACTIONS NOTE............................................................
Separate Condition entry is allowed for each requirement of the LCO.
A.
One or more of the above requ~rements not met.
Required Actions to be in MODE 4 include reducing average reactor coolant temperature to s 21 2°F.
Enter the applicable Condition of the affected LCO.
HATCH UNIT 1 Amendment No.
Inservice Leak and Hydrostatic Testing Operation 3.10.1 ACTIONS CONDITION A.
(continued)
REQUIRED ACTION A.2.1 Suspend activities that could increase the average reactor coolant temperature or pressure.
AND -
A.2.2 Reduce average i-e-*---
temperature to s 212°F.
COMPLETION TIME Immediately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SURVEILLANCE REQUIREMENTS I
Perform the applicable SRs for the required MODE 3 LCOs.
SURVEILLANCE According to the applicable SRs FREQUENCY HATCH UNIT 1 Amendment No.
lnservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 lnservice Leak and Hydrostatic Testing Operation The average reactor coolant temperature specified in Table 1.l-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3: and the requirements of LC0 3.4.8. "Residual Heat Removal (RHR) suspended r*d the following MODE 3 LCOs are met:
b I heft A
LC0 3.3.6.2, 'Secondary Containment Isolation Instrumentation,'
Functions 1 3 and 4 of T&le3AW-1;_
U LC0 3.6.4.1, "Secondary Containmentn; LC0 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)";
and LC0 3.6.4.3, 'Standby Gas Treatment (SGT) System."
APPLICABILITY.
MODE 4 with average reactor coolant temperature > 212°F ACTIONS
NOTE ------------------------------------------------------------
Separate Condition entry is allowed for each requirement of the LCO.
NOTE ------------
requ~rements not met.
Required Actions to be in MODE 4 include reducing average reactor coolant temperature to s 21 2°F Enter the applicable Condition of the affected LCO.
HATCH UNIT 2 Amendment No.
ACTIONS CONDITION A.
(continued)
Inservice Leak and Hydrostatic Testing Operation 3.10.1 REQUIRED ACTION A.2.1 Suspend activities that could increase the average reactor coolant temperature or pressure.
AND -
A.2.2 Reduce average
-- r e a e b r e o d a p l f - - -
temperature to 5 212°F.
COMPLETION TIME Immediately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Perform the applicable SRs for the required MODE 3 LCOs.
SURVEILLANCE REQUIREMENTS According to the applicable SRs SURVEILLANCE HATCH UNIT 2 FREQUENCY Amendment No.
reactor coolant temperature > 21 2°F:
For performance of an inservice leak or hydrostatic test, As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test,
lnservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 lnservice Leak and Hydrostatic Testing Operation LC0 3.10.1 The average reactor coolant temperature specified in Table 1.1 -1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LC0 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," may be suspended to allow reactor coolant temperature > 212°F:
For performance of an inservice leak or hydrostatic test, I
As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:
- a.
LC0 3.3.6.2, "Secondary Containment Isolation Instrumentation,"
Functions 1, 3, and 4 of Table 3.3.6.2-1 ;
- b.
LC0 3.6.4.1, "Secondary Containment";
- c.
LC0 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)";
and
- d.
LC0 3.6.4.3, "Standby Gas Treatment (SGT) System."
APPLICABILITY:
MODE 4 with average reactor coolant temperature > 212°F.
HATCH UNIT 1 Amendment No.
Inservice Leak and Hydrostatic Testing Operation 3.10.1 ACTIONS NOTE............................................................
Separate Condition entry is allowed for each requirement of the LCO.
CONDITION A.
One or more of the above requirements not met.
SR 3.10.1.1 Perform the applicable SRs for the required MODE 3 LCOs.
SURVEILLANCE REQUIREMENTS According to the applicable SRs REQUIRED ACTION A.l
NOTE ------------
Required Actions to be in MODE 4 include reducing average reactor coolant temperature to s 21 2°F.
Enter the applicable Condition of the affected LCO.
OR -
A.2.1 Suspend activities that could increase the average reactor coolant temperature or pressure.
AND -
A.2.2 Reduce average reactor coolant temperature to I 212°F.
SURVEILLANCE HATCH UNIT 1 COMPLETION TIME Immediately Immediately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> FREQUENCY Amendment No.
I
lnservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.1 0.1 lnservice Leak and Hydrostatic Testing Operation LC0 3.10.1 The average reactor coolant temperature specified in Table 1.l-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LC0 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," may be suspended to allow reactor coolant temperature > 212°F:
For performance of an inservice leak or hydrostatic test, As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:
- a.
LC0 3.3.6.2, "Secondary Containment Isolation Instrumentation,"
Functions 1, 3, and 4 of Table 3.3.6.2-1 ;
- b.
LC0 3.6.4.1, "Secondary Containment";
- c.
LC0 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)";
and
- d.
LC0 3.6.4.3, "Standby Gas Treatment (SGT) System."
APPLICABILITY:
MODE 4 with average reactor coolant temperature > 212°F.
HATCH UNIT 2 Amendment No.
Inservice Leak and Hydrostatic Testing Operation 3.10.1 ACTIONS NOTE............................................................
Separate Condition entry is allowed for each requirement of the LCO.
SURVEILLANCE REQUIREMENTS CONDITION A.
One or more of the above requirements not met.
SR 3.10.1.1 Perform the applicable SRs for the required MODE 3 LCOs.
REQUIRED ACTION A.l
NOTE ------------
Required Actions to be in MODE 4 include reducing average reactor coolant temperature to r 212°F.
Enter the applicable Condition of the affected LCO.
OR -
A.2.1 Suspend activities that could increase the average reactor coolant temperature or pressure.
AND A.2.2 Reduce average reactor coolant temperature to 5 212°F.
SURVEILLANCE According to the applicable SRs COMPLETION TIME Immediately Immediately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> FREQUENCY HATCH UNIT 2 3.10-2 Amendment No.
I Edwin I. Hatch Nuclear Plant Technical Specifications Revision LC0 3.10.1 -Inservice Leak and Hydrostatic Testing Operation Marked-up and Clean Typed TS Bases Pages
lnservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.1 0 SPECIAL OPERATIONS B 3.1 0.1 lnservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LC0 is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testin temperatures > 212°F (normally corresponding to MODE 3 I
lnswt B I
System hydrostatic testing and system leakage (same as inservice leakage tests) pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. lnservice system leakage tests are performed at the end of each refueling outage with the system set for normal power operation. Some parts of the Class 1 boundary are not pressurized during these system tests. System hydrostatic tests are required once per interval and include all the Class 1 boundary unless the test is broken into smaller portions. Recirculation pump operation and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits required by LC0 3.4.9, "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits."
These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.
The hydrostatic test requires increasing pressure to approximately 1139 psig. The system leakage test requires increasing pressure to approximately 1045 psig--- ?3mwn tOme Wng requked by SR 3.1.4 1 and SR Olther testkg may be fmffamed h 3.1.4.4 reauires reactor Presswe r 800 ueh.
With increased reactor vesse m c e o v e m m y m m m e r n mjunction with th9 allowable vessel temperature increases at a given pressure. Periodic allowgnciestoti9wfe~
updates to the RCS P/T limit curves are performed as necessary, b a a k o r w t k : m based upon the results of analyses of irradiated surveillance a n d ~ r o d s ~ r e m specimens removed from the vessel.
the I m R C I
APPLICABLE Allowin the reactor to be considered in MODE SAFETY ANALYSES &
when the reactor coolant tem effectively provides an exception to MODE 3 OPERABILITY of primary containment and the full complement of redundant Emergency Core Cooling Systems. Since the (continued)
HATCH UNIT 1 B 3.10-1 REVISION
Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES I
APPLICABLE tests are performed nearly water solid (except for an air bubble SAFETY ANALYSES for pressure control), at low decay heat values, and near MODE 4 (continued) conditions, the stored energy in the reactor core will be very low.
Under these conditions, the potential for failed fuel and a subsequent increase in coolant activity above the LC0 3.4.6, "RCS Specific Activity," limits are minimized. In addition, the secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment.
In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LC0 3.5.2, "ECCS - Shutdown," would be more than adequate to keep the core flooded under this low decay heat load condition. Small system leaks would be detected by leakage inspections before significant inventory loss occurred.
For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to the secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.
As described in LC0 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of the NRC Policy Statement apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs.
A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.
As described in LC0 3.0.7, compliance with this Special Operations LC0 is optional. Operation at reactor coolant temperatures > 212°F can be in accordance with Table 1.l-1 for MODE 3 operation without meeting this Special Operations LC0 or its ACTIONS. This option may be required due to PTT limits, however, which require testing at (continued)
HATCH UNIT 1 REVISION
Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LC0 (continued) temperatures > 21 2"F, while the ASME system hydrostatic test itself requires the safetylrelief valves to be gagged, preventing their OPERABILITY. -
I Insad E I
If it is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. This Special Operations LC0 allows changing Table 1.l-1 temperature limits for MODE 4 to "NA" and suspending the requirements of LC0 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown." The additional requirements for secondary containment LCOs to be met will provide sufficient protection for operations at reactor coolant temperatures of performing m n
inservice leak or This LC0 allows prim,
Jconjundion wtth an
- - ~ I V I O.
-. bak or hydmtatlc test. I unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 APPLICABILITY The MODE 4 requirements may modified for the performance inservice leak or hydrostatic these operations can be
, or RS a csmaquenw considered as in MODE 4, even though the reactor coolant temperature is > 21 2°F. The additional requirement for secondary
- 1.
containment OPERABILITY according to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur. Operations in all other MODES are unaffected by this LCO.
ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing operation. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the LC0 not met provide appropriate compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO.
(continued)
HATCH UNIT 1 B 3.10-3 REVISION 0
Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES ACTIONS (continued)
A. 1 -
If an LC0 specified in LC0 3.1 0.1 is not met, the ACTIONS applicable to the stated requirements are entered immediately and complied with.
Required Action A.l has been modified by a Note that clarifies the intent of another LCO's Required Action to be in MODE 4 includes reducing the average reactor coolant temperature to 5 212°F.
A.2.1 and A.2.2 Required Action A.2.1 and Required Action A.2.2 are alternate Required Actions that can be taken instead of Required Action A.l to restore compliance with the normal MODE 4 requirements, and thereby exit this Special Operation LCO's Applicability. Activities that could further increase reactor coolant temperature or pressure are suspended immediately, in accordance with Required Action A.2.1, and the reactor coolant temperature is reduced to establish normal MODE 4 requirements. The allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Required Action A.2.2 is based on engineering judgment and provides sufficient time to reduce the average reactor coolant temperature from the highest expected value to 5 212°F with normal cooldown procedures. The Completion Time is also consistent with the time provided in LC0 3.0.3 to reach MODE 4 from MODE 3.
SURVEILLANCE REQUIREMENTS SR 3.10.1.1 The LCOs made applicable are required to have their Surveillances met to establish that this LC0 is being met. A discussion of the applicable SRs is provided in their respective Bases.
REFERENCES
- 1.
American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI.
FSAR, Section 14.4.5.
HATCH UNIT 1 REVISION 0
lnservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.1 0 SPECIAL OPERATIONS B 3.1s.1 lnservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LC0 is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testin at temperatures > 212°F (normally corresponding to MODE 3) \\-
7 System hydrostatic testing and system leakage (same as inservice leakage tests) pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. lnservice system leakage tests are performed at the end of each refueling outage with the system set for normal power operation. Some parts of the Class 1 boundary are not pressurized during these system tests. System hydrostatic tests are required once per interval and include all the Class 1 boundary unless the test is broken into smaller portions. Recirculation pump operation and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required from the RPV (P/T) limits required by LC0 3.4.9, "Reactor and Temperature (Pm Limits."
on the fracture toughness of the vessel neutron fluence.
to approximately 1139 psig. The s y s w k a g e test requires increasing pressure to approximately 1 045 psig.
Other testing may be p e r f c w f f P e d ~ - ~ ~
theetlowanogsb-I r s a a c o r ~ a t i c
?mi axltreil rod scram tlms&m.
With increased reactor vessel fluence over time, the minimum
\\
allowable vessel temperature increases at a given pressure. Periodic updates to the RCS P/T limit curves are performed as necessary, based upon the results of analyses of irradiated surveillance specimens removed from the vessel Im C I
APPLICABLE Allowin the reactor to be considered in MODE 4 SAFETY ANALYSES when the reactor coolant te effectively provides an exception to MODE OPERABILITY of primary contai redundant Emergency Core Co (continued)
HATCH UNIT 2 6 3.1 0-1 REVISION 48
Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE tests are performed nearly water solid (except for an air bubble SAFETY ANALYSES for pressure control), at low decay heat values, and near MODE 4 (continued) conditions, the stored energy in the reactor core will be very low.
Under these conditions, the potential for failed fuel and a subsequent increase in coolant activity above the LC0 3.4.6, "RCS Specific Activity," limits are minimized. In addition, the secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment.
In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LC0 3.5.2, "ECCS - Shutdown," would be more than adequate to keep the core flooded under this low decay heat load condition. Small system leaks would be detected by leakage inspections before significant inventory loss occurred.
For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to the secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.
As described in LC0 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of the NRC Policy Statement apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs.
A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.
As described in LC0 3.0.7, compliance with this Special Operations LC0 is optional. Operation at reactor coolant temperatures > 212°F can be in accordance with Table 1.l-1 for MODE 3 operation without meeting this Special Operations LC0 or its ACTIONS. This option may be required due to PTT limits, however, which require testing at HATCH UNIT 2 B 3.1 0-2 (continued)
REVISION 0
Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LC0 temperatures > 212"F, while the ASME system hydrostatic test itself (continued) requires the safetylrelief valves to be gagged, preventing their OPERABILITY-I Im E 1
I J
If it is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. This Special Operations LC0 allows changing Table 1.l-1 temperature limits for MODE 4 to "NAN and suspending the requirements of LC0 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown." The additional requirements for secondary containment LCOs to be met will provide sufficient protection for operations at reactor coolant temperatures urpose of performing Jertkerlan inservice leak or This LC0 allows primary containment to be open for frequent unobstructed access to perform inspections, and for outage activities APPLICABILITY The MODE 4 requirements may on1 modified for the performance of inservice leak or hydrostatic these operations can be as in MODE 4, even though the reactor coolant temperature is > 212°F. The additional requirement for secondary containment OPERABILITY according to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur. Operations in all other MODES are unaffected by this LCO.
ACTIONS HATCH UNIT 2 A Note has been provided to modlfy the ACTIONS related to inservice leak and hydrostatic testing operation. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the LC0 not met provide appropriate compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO.
(continued)
B 3.1 0-3 REVISION 0
Inservice Leak and Hydrostatic Testing Operation B 3.1 0.1 BASES ACTIONS A. 1 (continued)
If an LC0 specified in LC0 3.10.1 is not met, the ACTIONS applicable to the stated requirements are entered immediately and complied with.
Required Action A.l has been modified by a Note that clarifies the intent of another LCO1s Required Action to be in MODE 4 includes reducing the average reactor coolant temperature to 5 212°F.
A.2.1 and A.2.2 Required Action A.2.1 and Required Action A.2.2 are alternate Required Actions that can be taken instead of Required Action A.l to restore compliance with the normal MODE 4 requirements, and thereby exit this Special Operation LCO1s Applicability. Activities that could further increase reactor coolant temperature or pressure are suspended immediately, in accordance with Required Action A.2.1, and the reactor coolant temperature is reduced to establish normal MODE 4 requirements. The allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Required Action A.2.2 is based on engineering judgment and provides sufficient time to reduce the average reactor coolant temperature from the highest expected value to s 21 2°F with normal cooldown procedures. The Completion Time is also consistent with the time provided in LC0 3.0.3 to reach MODE 4 from MODE 3.
SU RVEl LLANCE REQUIREMENTS The LCOs made applicable are required to have their Surveillances met to establish that this LC0 is being met. A discussion of the applicable SRs is provided in their respective Bases.
REFERENCES American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI.
FSAR, Section 15.1.40.
HATCH UNIT 2 REVISION 0
or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures > 212°F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 212°F when the control rod scram time testing is initiated in conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordance with LC0 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown," during MODE 4 operation.
INSERT C However, hydrostatic and leak testing may still be required with minimum reactor coolant temperatures > 212°F. However, even with required minimum reactor coolant temperatures < 212"F, maintaining RCS temperatures within a small band during the test can be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.
INSERT D during, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, Additionally, even with required minimum reactor coolant temperatures 5 212"F, RCS temperatures may drift above 2 12°F during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak and hydrostatic testing. While this Special Operations LC0 is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections is not precluded.
lnservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.1 0 SPECIAL OPERATIONS B 3.10.1 lnservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LC0 is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures > 212°F (normally corresponding to MODE 3) or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures > 212°F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1 -4.1 or SR 3.1 -4.4 if reactor coolant temperatures exceed 212°F when the control rod scram time testing is initiated in conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordance with LC0 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown," during MODE 4 operation.
System hydrostatic testing and system leakage (same as inservice leakage tests) pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. lnservice system leakage tests are performed at the end of each refueling outage with the system set for normal power operation. Some parts of the Class 1 boundary are not pressurized during these system tests. System hydrostatic tests are required once per interval and include all the Class 1 boundary unless the test is broken into smaller portions. Recirculation pump operation and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The rr~inimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (PK) limits required by LC0 3.4.9, "Reactor Coolant System (RCS) Pressure and Temperature (PK) Limits."
These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.
The hydrostatic test requires increasing pressure to approximately 1 139 psig. The system leakage test requires increasing pressure to approximately 1045 psig. Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor pressures 1 800 psig.
With increased reactor vessel fluence over time, the minimum allowable vessel temperature increases at a given pressure. Periodic (continued)
HATCH UNIT 1 B 3.10-1
lnservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES BACKGROUND updates to the RCS P/T limit curves are performed as necessary, (continued) based upon the results of analyses of irradiated surveillance specimens removed from the vessel. However, hydrostatic and leak testing may still be required with minimum reactor coolant temperatures > 212°F. However, even with required minimum reactor coolant temperatures c 21 2"F, maintaining RCS temperatures within a small band during the test can be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.
Other testing may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests.
APPLICABLE Allowing the reactor to be considered in MODE 4 when the reactor SAFETY ANALYSES coolant temperature is > 21Z°F, during, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, effectively provides an exception to MODE 3 requirements, including OPERABILITY of primary containment and the full complement of redundant Emergency Core Cooling Systems.
Since the tests are performed nearly water solid (except for an air bubble for pressure control), at low decay heat values, and near I
MODE 4 conditions, the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel and a subsequent increase in coolant activity above the LC0 3.4.6, "RCS Specific Activity," limits are minimized. In addition, the secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment.
In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LC0 3.5.2, (continued)
HATCH UNIT 1 B 3.10-2
Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE "ECCS - Shutdown," would be more than adequate to keep the core SAFETY ANALYSES flooded under this low decay heat load condition. Small system leaks (continued) would be detected by leakage inspections before significant inventory loss occurred.
For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to the secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.
As described in LC0 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of the NRC Policy Statement apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs.
A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.
As described in LC0 3.0.7, compliance with this Special Operations LC0 is optional. Operation at reactor coolant temperatures > 212°F can be in accordance with Table 1.l-1 for MODE 3 operation without meeting this Special Operations LC0 or its ACTIONS. This option may be required due to P/T limits, however, which require testing at temperatures > 21 2"F, while the ASME system hydrostatic test itself requires the safetylrelief valves to be gagged, preventing their OPERABILITY. Additionally, even with required minimum reactor coolant temperatures 1 21 2"F, RCS temperatures may drift above 212°F during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak and hydrostatic testing.
While this Special Operations LC0 is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections is not precluded.
If it is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. This Special Operations LC0 allows changing Table 1.1 -1 temperature limits for MODE 4 to "NA" and suspending the requirements of LC0 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown." The additional requirements for secondary containment LCOs to be met will provide (continued)
HATCH UNIT 1 B 3.10-3
Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LC0 sufficient protection for operations at reactor coolant temperatures (continued)
> 212°F for the purpose of performing an inservice leak or hydrostatic test, and for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.
This LC0 allows primary containment to be open for frequent unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable requirements.
I APPLICABII-ITY The MODE 4 requirements may only be modified for the performance of, or as a consequence of, inservice leak or hydrostatic tests, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, so that these operations can be considered as in MODE 4, even though the reactor coolant temperature is > 212°F. The additional requirement for secondary containment OPERABILITY according to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur. Operations in all other MODES are unaffected by this LCO.
ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing operation. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the LC0 not met provide appropriate compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO.
If an LC0 specified in LC0 3.10.1 is not met, the ACTIONS applicable to the stated requirements are entered immediately and complied with.
Required Action A.l has been modified by a Note that clarifies the intent of another LCO's Required Action to be in MODE 4 includes reducing the average reactor coolant temperature to I 21 2°F.
(continued)
HATCH UNIT 1 B 3.10-4
Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES ACTIONS A.2.1 and A.2.2 (continued)
Required Action A.2.1 and Required Action A.2.2 are alternate Required Actions that can be taken instead of Required Action A.l to restore compliance with the normal MODE 4 requirements, and thereby exit this Special Operation LCO's Applicability. Activities that could further increase reactor coolant temperature or pressure are suspended immediately, in accordance with Required Action A.2.1, and the reactor coolant temperature is reduced to establish normal MODE 4 requirements. The allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Required Action A.2.2 is based on engineering judgment and provides sufficient time to reduce the average reactor coolant terr~perature from the highest expected value to 1 21 2°F with normal cooldown procedures. The Completion Time is also consistent with the time provided in LC0 3.0.3 to reach MODE 4 from MODE 3.
SURVEI LLANCE SR 3.10.1.1 REQUIREMENTS The LCOs made applicable are required to have their Surveillances met to establish that this LC0 is being met. A discussion of the applicable SRs is provided in their respective Bases.
REFERENCES
- 1.
American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI.
- 2.
FSAR, Section 14.4.5.
HATCH UNIT 1
lnservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.10 S P E C ~ ~ L OPERATIONS B 3.10.1 lnservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LC0 is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures > 212°F (normally corresponding to MODE 3) or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures > 21 2°F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 212°F when the control rod scram time testing is initiated in conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordance with LC0 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown," during MODE 4 operation.
System hydrostatic testing and system leakage (same as inservice leakage tests) pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. lnservice system leakage tests are performed at the end of each refueling outage with the system set for normal power operation. Some parts of the Class 1 boundary are not pressurized during these system tests. System hydrostatic tests are required once per interval and include all the Class 1 boundary unless the test is broken into smaller portions. Recirculation pump operation and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits required by LC0 3.4.9, "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits."
These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.
The hydrostatic test requires increasing pressure to approximately 1 139 psig. The system leakage test requires increasing pressure to approximately 1045 psig. Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor pressures 2 800 psig.
With increased reactor vessel fluence over time, the minimum allowable vessel temperature increases at a given pressure. Periodic (continued)
HATCH UNIT 2 B 3.10-1
lnservice Leak and Hydrostatic Testing Operation B 3.1 0.1 BASES BACKGROUND updates to the RCS P/T limit curves are performed as necessary, (continued) based upon the results of analyses of irradiated surveillance specimens removed from the vessel. However, hydrostatic and leak testing may still be required with minimum reactor coolant temperatures > 212°F. However, even with required minimum reactor coolant temperatures < 212"F, maintaining RCS temperatures within a small band during the test can be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.
Other testing may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests.
APPLICABLE Allowing the reactor to be considered in MODE 4 when the reactor SAFETY ANALYSES coolant temperature is > 212"F, during, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, effectively provides an exception to MODE 3 requirements, including OPERABILITY of primary containment and the full complement of redundant Emergency Core Cooling Systems.
Since the tests are performed nearly water solid (except for an air bubble for pressure control), at low decay heat values, and near I
MODE 4 conditions, the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel and a subsequent increase in coolant activity above the LC0 3.4.6, "RCS Specific Activity," limits are minimized. In addition, the secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment.
In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LC0 3.5.2, (continued)
HATCH UNIT 2 B 3.1 0-2
Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE "ECCS - Shutdown," would be more than adequate to keep the core SAFETY ANALYSES flooded under this low decay heat load condition. Small system leaks (continued) would be detected by leakage inspections before significant inventory loss occurred.
For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to the secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.
As described in LC0 3.0.7, corr~pliance with Special Operations LCOs is optional, and therefore, no criteria of the NRC Policy Statement apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs.
A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.
As described in LC0 3.0.7, compliance with this Special Operations LC0 is optional. Operation at reactor coolant temperatures > 212°F can be in accordance with Table 1.1 -1 for MODE 3 operation without meeting this Special Operations LC0 or its ACTIONS. This option may be required due to P/T limits, however, which require testing at temperatures > 212"F, while the ASME system hydrostatic test itself requires the safetylrelief valves to be gagged, preventing their OPERABILITY. Additionally, even with required minimum reactor coolant temperatures I 212"F, RCS temperatures may drift above 212°F during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak and hydrostatic testing.
While this Special Operations LC0 is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections is not precluded.
If it is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. This Special Operations LC0 allows changing Table 1.l-1 temperature limits for MODE 4 to "NA" and suspending the requirements of LC0 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown." The additional requirements for secondary containment LCOs to be met will provide (continued)
HATCH UNIT 2 B 3.10-3
lnservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LC0 sufficient protection for operations at reactor coolant temperatures (continued)
> 21 2°F for the purpose of performing an inservice leak or hydrostatic test, and for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.
This LC0 allows primary containment to be open for frequent unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable requirements.
I APPLlCABlI-ITY The MODE 4 requirements may only be modified for the performance of, or as a consequence of, inservice leak or hydrostatic tests, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, so that these operations can be considered as in MODE 4, even though the reactor coolant temperature is > 212°F. The additional requirement for secondary containment OPERABILITY according to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur. Operations in all other MODES are unaffected by this LCO.
ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing operation. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the LC0 not met provide appropriate compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO.
If an LC0 specified in LC0 3.10.1 is not met, the AC-TIONS applicable to the stated requirements are entered immediately and complied with.
Required Action A.l has been modified by a Note that clarifies the intent of another LCO's Required Action to be in MODE 4 includes reducing the average reactor coolant temperature to 5 21 2°F.
(continued)
HATCH UNIT 2 B 3.10-4
Inservice Leak and Hydrostatic Testing Operation B 3.1 0.1 BASES ACTIONS A.2.1 and A.2.2 (continued)
Required Action A.2.1 and Required Action A.2.2 are alternate Required Actions that can be taken instead of Required Action A.l to restore compliance with the normal MODE 4 requirements, and thereby exit this Special Operation LCO's Applicability. Activities that could further increase reactor coolant temperature or pressure are suspended immediately, in accordance with Required Action A.2.1, and the reactor coolant temperature is reduced to establish normal MODE 4 requirements. The allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Required Action A.2.2 is based on engineering judgment and provides sufficient time to reduce the average reactor coolant temperature from the highest expected value to 5 21 2°F with normal cooldown procedures. The Completion Time is also consistent with the time provided in LC0 3.0.3 to reach MODE 4 from MODE 3.
SLIRVEILLANCE SR 3.10.1.1 REQUIREMENTS The LCOs made applicable are required to have their Surveillances met to establish that this LC0 is being met. A discussion of the applicable SRs is provided in their respective Bases.
REFERENCES
- 1.
American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI.
- 2.
FSAR, Section 15.1.40.
HATCH LlNlT 2