Text

J. M. Farley, Units 1 and 2 - License Amendment Request to Revise Technical Specifications Regarding Generic Letter 2008-01, Managing Gas Accumulation in Accordance with TSTF-523, Revision 2, Using the Consolidated Line Item Improvement Pro
	ML15132A722
Person / Time
Site:	Farley
Issue date:	05/12/2015
From:	Pierce C; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-08-001, NL-15-0421
	Download: ML15132A722 (59)
	v • d • e

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35201 Tel 205.992.7872 Fax 205.992.7601 MAY 1 2 201'5 Docket Nos.: 50-348 NL-15-0421 50-364 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 License Amendment Request to Revise Technical Specifications Regarding Generic Letter 2008-01, Managing Gas Accumulation in accordance with TSTF-523, Revision 2. Using the Consolidated Line Item Improvement Process (CLIIP)

Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 50.90 Southern Nuclear Operating Company (SNC) is submitting a request for an amendment to the Technical Specifications (TS) for Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2.

The proposed amendment would modify TS requirements related to Generic Letter 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." SNC committed to submit this proposed change in Joseph M. Farley Nuclear Plant Response to NRC Generic Letter 2008-1, "Response to Request for Additional Information," ML100190165.

Enclosure 1 provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the existing TS pages marked up to show the proposed changes. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides existing TS Bases pages marked up to show the proposed changes.

SNC requests approval of the proposed license amendments by May 30, 2016. The proposed changes would be implemented within 120 days of issuance of the amendment.

In accordance with 10 CFR 50.91 (b)(1}, "State Consultation," a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the designated Alabama officials.

U. S. Nuclear Regulatory Commission NL-15-0421 Page2 This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Mr. C. R. Pierce states he is Regulatory Affairs Director 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.

Respectfully submitted, a.f{fJ~ ~-~ \

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Enclosures:

1. Basis for Proposed Change

2. FNP Technical Specification Marked Up Pages

3. FNP Technical Specification Clean Typed Pages

4. FNP Technical Specification Bases Marked Up Pages (for information only) cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President - Farley Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President- Engineering Mr. D. R. Madison, Vice President- Fleet Operations Ms. B. L. Taylor, Regulatory Affairs Manager- Farley RType: CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. S. A. Williams, NRR Project Manager- Farley Mr. P. K. Niebaum, Senior Resident Inspector- Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

Joseph M. Farley Nuclear Plant License Amendment Request to Revise Technical Specifications Regarding GL 2008-01, Managing Gas Accumulation, TSTF-523 Revision 2, Using the Consolidated Line Item Improvement Process (CLIIP)

Enclosure 1 Basis for Proposed Change to NL-15-0421 Basis for Proposed Change Table of Contents 1.0 Description 2.0 Assessment 3.0 Regulatory Analysis 4.0 Environmental Evaluation E1-1

=+ . . . ..

to NL-15-0421 Basis for Proposed Change

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 Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems."

The proposed amendment is consistent with TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation." The availability of this Technical Specification (TS) improvement was published in the Federal Register on January 15, 2014 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Southern Nuclear Operating Company (SNC) has reviewed the safety evaluation dated December 23, 2013 as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-523. As described in the subsequent paragraphs, SNC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the Nuclear Regulatory Commission (NRC) staff are applicable to Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, and justify this amendment for the incorporation of the changes to the FNP Units 1 and 2 TS.

2.2 Optional Changes and Variations SNC 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 dated December 23,2013.

FNP Units 1 and 2 TS utilize different numbering than the Standard Technical Specifications on which TSTF-523 was based. Specifically, SR 3.6.6.9 was added to reflect addition of the new SR 3.6.6.4 reflected in the TSTF-523 in the Containment Spray and Cooling Systems.

By numbering this addition to the end of this section it precluded having to make administrative changes to FNP Unit 1 and 2 existing SRs. RHR and Coolant Circulation -

High Water Level is section 3.9.4 at FNP Units 1 and 2 instead of section 3.9.5 per TSTF-523. Also, RHR and Coolant Circulation- Low Water Level is section 3.9.5 at FNP Units 1 and 2 instead of section 3.9.6 per TSTF-523. These differences are administrative and do not affect the applicability of TSTF-523 to the FNP Units 1 and 2 TS.

The FNP, Units 1 and 2, TS does not have some of the existing Surveillance Requirements revised by TSTF-523. A new SR 3.5.2.8 was added to reflect the TSTF -

523 changes to SR 3.5.2.3 as required. Also, this new SR 3.5.2.8 was added to SR 3.5.3.1 to show the addition of this SR as required. This difference does not affect the applicability of TSTF-523 to the FNP Units 1 and 2 TS.

The Technical Specification Bases for the note added for SR 3.5.2.2 and SR 3.6.6.1 explaining the site process for administratively controlling opening vent flow paths is E1-2 to NL-15-0421 Basis for Proposed Change clarified. This administrative variance does not affect the applicability of TSTF-523 to the FNP Units 1 and 2 TS.

The Technical Specification Bases for RHR per SR 3.4.6.4, SR 3.4.7.4, SR 3.4.8.3, SR 3.9.4.2, and SR 3.9.5.3 clarifies that the RHR Loop is adequately filled and vented by virtue of performing the operating procedure and when the RHR Loop is in service in accordance with operating procedures. Also, the RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns, if no evolutions were performed that can introduce voids into the RHR loop.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination SNC requests adoption of TSTF-523, Rev. 2, "Generic Letter 2008-01, Managing Gas Accumulation," which is an approved change to the standard technical specifications (STS), into the Joseph M. Farley Unit 1 and 2 technical specifications (TS). 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.

SNC 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 Surveillance Requirements (SRs) that require verification that the Emergency Core Cooling System (ECCS), the Residual Heat Removal (RHR) System, and the Containment Spray (CS) 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.

The proposed change revises or adds SRs that require verification that the ECCS, the RHR System, and the CS System are not rendered inoperable due to accumulated gas E1-3 to NL-15-0421 Basis for Proposed Change 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, the RHR System, and the CS 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 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.

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

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 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 a significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed 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.

E1-4

Joseph M. Farley Nuclear Plant License Amendment Request to Revise Technical Specifications Regarding GL 2008-01, Managing Gas Accumulation, TSTF-523 Revision 2, Using the Consolidated Line Item Improvement Process (CLIIP)

Enclosure 2 FNP Technical Specification Marked Up Pages

r::::JJI,;JU::!Uftl I! lU l'IL*IO*U..t! I FNP Technical Specification Marked Up Pages RCS Loops-MODE 4 3.4.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One required RHR loop B.1 Be in MODE 5. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable.

AND Two required RCS loops inoperable.

c. Required RCS or RHR c. 1 Suspend all operations Immediately loops inoperable. involving a reduction of RCS boron concentration.

OR AND No RCS or RHR loop in operation. C.2 Initiate action to restore Immediately one loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one RHR or RCS loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.6.2 Verify SG secondary side water levels are ~ 75% (wide In accordance range) for required RCS loops. with the Surveillance Frequency Control Program SR 3.4.6.3 Verify correct breaker alignment and indicated power are In accordance available to the required pump that is not in operation. with the Surveillance 111 ! Insert SR 3.4.6.4 located on next page Frequency Control Program Farley Units 1 and 2 3.4.6-2 Amendment No. -+Sa (Unit 1)

Amendment No. +00 (Unit 2)

E2-1

t:nCIOSUre <!tO NL-lb-04<!1 FNP Technical Specification Marked Up Pages

/

Insert as SR 3.4.6.4 S R 3. 4. 6. 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 entering MODE 4.

Verify required RHR loop locations susceptible to gas In accordance accumulation are sufficiently filled with water. with the Surveillance Frequency Control Program E2-2

t:ncJosure:.! to NL-1 o-U4:.!1 FNP Technical Specification Marked Up Pages RCS Loops-MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.3 Verify correct breaker alignment and indicated power In accordance with are available to the required RHR pump that is not in the Surveillance operation. Frequency Control

! Program I

SR 3.4.7.4 Verify required RHR loop locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.4.7-3 Amendment No. ~ (Unit 1)

Amendment No. +8G (Unit 2)

E2-3

t:nCIOSUf6 i! 10 NL-1 ::J*U4<!1 FNP Technical Specification Marked Up Pages RCS Loops- MODE 5, Loops Not Filled 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required RHR loops B.1 Suspend all operations Immediately inoperable. involving reduction in RCS boron concentration.

OR AND No RHR loop in operation. B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.8.2 Verify correct breaker alignment and indicated power In accordance with are available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program

~

/

SR 3.4.8.3 Verify required RHR loop locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.4.8-2 Amendment No. +Sa (Unit 1)

Amendment No. .:f-00 (Unit 2)

E2-4

t:ncJosure <! to NL-1 b-0421 FNP Technical Specification Marked Up Pages ECCS- Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 ----------------------------NC>TE---------------------------------

C>nly required to be performed for valves 8132A and 81328 when Centrifugal Charging Pump A is inoperable.

Verify the following valves are in the listed position In accordance with with power to the valve operator removed. the Surveillance Frequency Control Number Position Function Program 8884,8886 Closed Centrifugal Charging Pump to RCS Hot Leg 8132A, 81328 C>pen Centrifugal Charging Pump discharge isolation 8889 Closed RHR to RCS Hot Leg Injection SR 3.5.2.2 \ Verify each ECCS manual, power operated, and In accordance with automatic valve in the flow path, that is not locked, the Surveillance sealed, or otherwise secured in position, is in the Frequency Control correct position. Program SR 3.5.2.3 Verify each ECCS pump's developed head at the test In accordance with flow point is greater than or equal to the required the lnservice developed head. Testing Program SR 3.5.2.4 Verify each ECCS automatic valve in the flow path In accordance with that is not locked, sealed, or otherwise secured in the Surveillance position, actuates to the correct position on an actual Frequency Control or simulated actuation signal.

. Program

_\

NC>TE--------------------------------

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

Farley Units 1 and 2 3.5.2-2 Amendment No. +8a (Unit 1)

Amendment No. .:t-00 (Unit 2)

E2-5

t:.nCIOSUre <! tO NL*1 !l*U4<!1 FNP Technical Specification Marked Up Pages ECCS- Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.5 Verify each ECCS pump starts automatically on an In accordance with actual or simulated actuation signal. the Surveillance Frequency Control Program SR 3.5.2.6 Verify, for each ECCS throttle valve listed below, In accordance with each position stop is in the correct position. the Surveillance Valve Number Frequency Control Program CVC-V-8991 A/8/C CVC-V-8989 A/8/C CVC-V-8996 A/8/C CVC-V-8994 A/8/C RHR-HV 603 AlB SR 3.5.2.7 Verify, by visual inspection, each ECCS train In accordance with containment sump suction inlet is not restricted by the Surveillance debris and the suction inlet trash racks, screens, and Frequency Control inner cages are properly installed and show no Program I evidence of structural distress or abnormal corrosion.

I SR 3.5.2.8 Verify ECCS locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.5.2-3 Amendment No. +Sa (Unit 1)

Amendment No. +00 (Unit 2)

E2-6

t:nclosure 2 to NL-15-0421 FNP Technical Specification Marked Up Pages ECCS- Shutdown 3.5.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

c. Required ECCS C.1 Restore required ECCS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months centrifugal charging centrifugal charging subsystem inoperable. subsystem to OPERABLE status.

D. Required Action and D.1 Be in MODES. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months associated Completion Time of Condition B or C not met.

AND At least one RHR subsystem OPERABLE.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 The following SRs are applicable for all equipment In accordance with required to be OPERABLE: applicable SRs SR 3.5.2.2 SR 3.5.2.6 SR 3.5.2.8 SR 3.5.2.3 SR 3.5.2.7 Farley Units 1 and 2 3.5.3-2 Amendment No. +4e (Unit 1)

Amendment No. +a+ (Unit 2)

E2-7

t:nclosure <!to NL-15-0421 FNP Technical Specification Marked Up Pages Containment Spray and Cooling Systems 3.6.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. Two containment cooling D.1 Restore one containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months trains inoperable. cooling train to OPERABLE status.

E. Required Action and E.1 Be in MODE3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition C or D AND not met.

E.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two containment spray F.1 Enter LCO 3.0.3. Immediately trains inoperable.

OR Any combination of three or more trains inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR Verify each containment spray manual, power In accordance with 3.6.6.1 \

operated, and automatic valve in the flow path that is the Surveillance not locked, sealed, or otherwise secured in position is Frequency Control in the correct position. Program SR 3.6.6.2 Operate each required containment cooling train fan In accordance with unit for ~ 15 minutes. the Surveillance Frequency Control Program SR 3.6.6.3 Verify each containment cooling train cooling water In accordance with flow rate is ~ 1600 gpm. the Surveillance Frequency Control Program

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

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

Farley Umts 1 and 2 3.6.6-2 Amendment No. +Sa (Umt 1)

Amendment No. +00 (Unit 2)

E2-8

Enclosure 2 to NL-15-0421 FNP Technical Specification Marked Up Pages Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6...4 Verify each containment spray pump's developed In accordance with head at the flow test point is greater than or equal to the lnservice the required developed head. Testing Program SR 3.6.6.5 Verify each automatic containment spray valve in the In accordance with flow path that is not locked, sealed, or otherwise the Surveillance secured in position, actuates to the correct position Frequency Control on an actual or simulated actuation signal. Program SR 3.6.6.6 Verify each containment spray pump starts In accordance with automatically on an actual or simulated actuation the Surveillance signal. Frequency Control Program SR 3.6.6.7 Verify each containment cooling train starts In accordance with automatically on an actual or simulated actuation the Surveillance signal. Frequency Control Program SR 3.6.6.8 Verify each spray nozzle is unobstructed. In accordance with the Surveillance I

Frequency Control Program

/

SR 3.6.6.9 Verify containment spray locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.6.6-3 Amendment No. +sa (Unit 1)

Amendment No. .:t-8G (Unit 2)

E2-9

Enclosure 2 to NL-15-0421 FNP Technical Specification Marked Up Pages RHR and Coolant Circulation- High Water Level 3.9.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.4 Close equipment hatch 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and secure with four bolts.

AND A.5 Close one door in each 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months air lock.

A.6.1 Close each penetration 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent.

A.6.2 Verify each penetration is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months capable of being closed by an OPERABLE Containment Purge and exhaust Isolation System.

SURVEILLANCE REQUJREMENTS SURVEILLANCE FREQUENCY SR 3.9.4.1 Verify one RHR loop is in operation and circulating In accordance with reactor coolant at a flow rate of ~ 3000 gpm. the Surveillance j_

Frequency Control Program SR 3.9.4.2 Verify required RHR loop locations susceptible to In accordance with the Surveillance gas accumulation are sufficiently filled with water.

Frequency Control Program Farley Units 1 and 2 3.9.4-2 Amendment No. +Sa (Unit 1)

Amendment No. +00 (Unit 2)

E2-10 to NL-15-0421 FNP Technical Specification Marked Up Pages RHR and Coolant Circulation- Low Water Level 3.9.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and circulating In accordance with reactor coolant at a flow rate of~ 3000 gpm. the Surveillance Frequency Control Program SR 3.9.5.2 Verify correct breaker alignment and indicated power In accordance with available to the required RHR pump that is not in the Surveillance operation.

Frequency Control Program I

SR 3.9.5.3 Verify required RHR loop locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.9.5-3 Amendment No. ~ (Unit 1)

Amendment No. .:t-00 (Unit 2)

E2-11

Joseph M. Farley Nuclear Plant License Amendment Request to Revise Technical Specifications Regarding GL 2008-01, Managing Gas Accumulation, TSTF-523 Revision 2, Using the Consolidated Line Item Improvement Process (CLIIP)

Enclosure 3 FNP Technical Specification Clean Typed Pages

RCS loops-MOD E 4 3.4.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4. 6.4 -----------------------------NOTE--------------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4.

Verify required RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.4.6-3 Amendment No. (Unit 1}

Amendment No. (Unit 2}

RCS Loops- MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.3 Verify correct breaker alignment and indicated power In accordance with are available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program SR 3.4.7.4 Verify required RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.4.7-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RCS Loops- MODE 5, Loops Not Filled 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required AHA loops B.1 Suspend all operations Immediately inoperable. involving reductioh in RCS boron concentration.

OR AND No AHA loop in operation. 8.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SA 3.4.8.1 Verify one AHA loop is in operation. In accordance with the Surveillance Frequency Control Program SA 3.4.8.2 Verify correct breaker alignment and indicated power In accordance with are available to the required AHA pump that is not in the Surveillance operation. Frequency Control Program SA 3.4.8.3 Verify required AHA loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.4.8-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

ECCS- Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 ----------------------------NOTE---------------------------------

Only required to be performed for valves 8132A and 81328 when Centrifugal Charging Pump A is inoperable.

Verify the following valves are in the listed position In accordance with with power to the valve operator removed. the Surveillance Frequency Control Number Position Function Program 8884,8886 Closed Centrifugal Charging Pump to RCS Hot Leg 8132A, 81328 Open Centrifugal Charging Pump discharge isolation 8889 Closed RHR to RCS Hot Leg Injection SR 3.5.2.2 ---------------------------NOTE-------------------------------

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

Verify each ECCS manual, power operated, and In accordance with automatic valve in the flow path, that is not locked, the Surveillance sealed, or otherwise secured in position, is in the Frequency Control correct position. Program SR 3.5.2.3 Verify each ECCS pump's developed head at the test In accordance with flow point is greater than or equal to the required the lnservice developed head. Testing Program SR 3.5.2.4 Verify each ECCS automatic valve in the flow path In accordance with that is not locked, sealed, or otherwise secured in the Surveillance position, actuates to the correct position on an actual Frequency Control or simulated actuation signal. Program Farley Units 1 and 2 3.5.2-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

ECCS- Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.5 Verify each ECCS pump starts automatically on an In accordance with actual or simulated actuation signal. the Surveillance Frequency Control Program SR 3.5.2.6 Verify, for each ECCS throttle valve listed below, In accordance with each position stop is in the correct position. the Surveillance Valve Number Frequency Control Program CVC-V-8991 A/8/C CVC-V-8989 A/8/C CVC-V-8996 A/8/C CVC-V-8994 A/8/C RHR-HV 603 A/8 SR 3.5.2.7 Verify, by visual inspection, each ECCS train In accordance with containment sump suction inlet is not restricted by the Surveillance debris and the suction inlet trash racks, screens, and Frequency Control inner cages are properly installed and show no Program evidence of structural distress or abnormal corrosion.

SR 3.5.2.8 Verify ECCS locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.5.2-3 Amendment No. 185 (Unit 1)

Amendment No. 180 (Unit 2)

ECCS- Shutdown 3.5.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

c. Required ECCS C.1 Restore required ECCS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months centrifugal charging centrifugal charging subsystem inoperable. subsystem to OPERABLE status.

D. Required Action and D.1 Be in MODES. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months associated Completion Time of Condition B or C not met.

AND At least one RHR subsystem OPERABLE.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 The following SRs are applicable for all equipment In accordance with required to be OPERABLE: applicable SRs SR 3.5.2.2 SR 3.5.2.6 SR 3.5.2.8 SR 3.5.2.3 SR 3.5.2.7 Farley Units 1 and 2 3.5.3-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Containment Spray and Cooling Systems 3.6.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. Two containment cooling D.1 Restore one containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months trains inoperable. cooling train to OPERABLE status.

E. Required Action and E.1 Be in MODE3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition C or D AND not met.

E.2 Be in MODES. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two containment spray F.1 Enter LCO 3.0.3. Immediately trains inoperable.

OR Any combination of three or more trains inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 -----------------------------NOTE----------------------------------

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

Verify each containment spray manual, power In accordance with operated, and automatic valve in the flow path that is the Surveillance not locked, sealed, or otherwise secured in position is Frequency Control in the correct position. Program SR 3.6.6.2 Operate each required containment cooling train fan In accordance with unit for ;::: 15 minutes. the Surveillance Frequency Control Program SR 3.6.6.3 Verify each containment cooling train cooling water In accordance with flow rate is ;::: 1600 gpm. the Surveillance Frequency Control Program Farley Units 1 and 2 3.6.6-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.4 Verify each containment spray pump's developed In accordance with head at the flow test point is greater than or equal to the lnservice the required developed head. Testing Program SR 3.6."6.5 Verify each automatic containment spray valve in the In accordance with flow path that is not locked, sealed, or otherwise the Surveillance secured in position, actuates to the correct position Frequency Control on an actual or simulated actuation signal.

I Program SR 3.6.6.6 Verify each containment spray pump starts In accordance with automatically on an actual or simulated actuation the Surveillance signal. Frequency Control Program SR 3.6.6.7 Verify each containment cooling train starts In accordance with automatically on an actual or simulated actuation the Surveillance signal. Frequency Control Program SR 3.6.6.8 Verify each spray nozzle is unobstructed. In accordance with the Surveillance Frequency Control Program SR 3.6.6.9 Verify containment spray locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.6.6-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RHR and Coolant Circulation- High Water Level 3.9.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.4.2 Verify required RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.9.4-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RHR and Coolant Circulation- Low Water Level 3.9.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and circulating In accordance with reactor coolant at a flow rate of<:: 3000 gpm. the Surveillance Frequency Control Program SR 3.9.5.2 Verify correct breaker alignment and indicated power In accordance with available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program SR 3.9.5.3 Verify required RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.9.5-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Joseph M. Farley Nuclear Plant License Amendment Request to Revise Technical Specifications Regarding GL 2008-01, Managing Gas .Accumulation, TSTF-523 Revision 2, Using the Consolidated Line Item Improvement Process (CLIIP)

Enclosure 4 FNP Technical Specification Bases Marked Up Pages (for information only) to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops - tvODE 4 B 3.4.6 BASES LCO An OPERABLE RCS loop comprises an OPERABLE RCP and an (continued) OPERABLE SG, W"lich has the minimum V\ater level specified in SR 3.4.6.2. This assumes steam removal capability and the availability a a makeup Vlater source (W necessary for extended use a the SG) as required to remove decay heat.

Similarly for the RHR System, an OPERABLE RHR loop comprises an OPERABLE RHR pump capable ci providing forced flow to an OPERABLE RHR heat exchanger. RCPs and RHR pumps are OPERABLE f they are capable ci being po'Aered and are able to provide forced flow if required. 1\tbnagement of gas voids is important to RHR System OPERABILITY.

APPLICABIUTY In M)DE 4, this LCO ensures forced circulation a the reactor coolant to remove decay heat from the core and to provide proper boron mi:xing. One loop ci either RCS or RHR provides sufficient circulation for these purposes. Hovvever, tw::> loops consisting a any combination aRCS and RHR loops are required to be OPERABLE to meet single failure considerations.

Operation in other tvODES is covered by:

LCO 3.4.4, "RCS Loops- tvODES 1 and 2";

LCO 3.4.5, "RCS Loops- tvODE 3";

LCO 3.4.7, "RCS Loops- tvODE 5, Loops Filled"; LCO 3.4.8, "RCS Loops- tvODE 5, Loops Not Filled"; LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (tvODE 6); and LCO 3.9.5, "Residual Heat Removal (RHR) and O>olant Circulation- Low Water Level" (tvODE 6).

ACTIONS If one required RCS loop is inoperable and tw::> RHR loops are inoperable, redundancy for heat removal is lost. Action must be initiated to restore a second RCS or RHR loop to OPERABLE status.

Tte immediate Completion Time reflects the importance a maintaining the availability a tw::> paths for heat removal.

(continued)

Farley Units 1 and 2 B 3.4.6-3 Revision I E4-1 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only) Page 13 of 49 RCS Loops - fvODE 4 B 3.4.6 BASES SURVEILLANCE SR 3.4.6.2 REQUIREtvENTS (continued) SR 3.4.6.2 rE~:tuires verWication ci SG OPERABIUTY. SG OPERABIUTY is verified by ensurirg that the secondary side wde range IJiater level is ~ 75%. If the SG secondary side wde range water level is < 75%, the tubes may become uncovered and the associated loop may not be capable ci providing the heat sirk necessaryfor removal of decay heat. Tte Surveillance Fra::tuency is controlled under the Surveillance Frequency Control Program.

SR 3.4.6.3 Veriication that the ra::tuired pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation.

Veriication is performed by verifying proper breaker alignment and poV\er available to the required pump. Tte Surveillance Fra::tuency is controlled under the Surveillance Frequency Control Program.

SR 3.4.6.4 RHR 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 required RHR loop(s) and may also prevent IJiater hammer. pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information. including piping and instrumentation drawngs, isometric drawngs, plan and elevation drawng s. and calculations. The design review is supplemented by system V\alk do1M1s to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could other.Msecause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR 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 (continued)

Farley Units 1 and 2 B3.4.6-5 Revision E4-2 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops - l'vODE 4 8 3.4.6 BASES SURVEILLANCE SR 3.4.6.4 (continued)

REQUIREM:NTS at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR 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. When the RHR System is restored to service, the surveillance is met by virtue of the performance of operating procedures that ensure the RHR Loop is adequately filled and vented. The performance of these manual actions ensures that the surveillance is met.

RHR Svstem locations susceptible togas 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 'Ahich are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

IVbnitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the 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 'Ahere the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERA81UTY. 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 SR may be met for a RHR Loop by virtue of having a loop in service in accordance with operating procedures.

The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns.

if no evolutions were performed that can introduce voids into the RHR loop.

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 entering MODE 4. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering MODE 4.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Prooram. The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES None.

Farley Units 1 and 2 8 3.4.6-6 Revision I E4-3 to-NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops - l'vODE 5, loops Filled 8 3.4.7 BASES LCO distribution throughout the RCS cannot be ensured Vlklen in (continued} natural circulation; and

b. Core outlet temperature is maintained at least 1ooF below saturation temperature, s:> that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

Note 2 alloVIS one RHR loop to be inoperable for a period ci up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other RHR loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time Vlklen such testing is safe and possible.

Note 3 r~uires that the secondary side v.ater temperature ct each SG be< 50°F above each ci the RCS cold leg temperatures or that the pressurizer v.ater '\tUiume is less than 770 cubic feet (24% ct wde range, cold, pressurizer level indication} before the start ct a reactor coolant pump (RCP} wth an RCS cold leg temperature ~the Low Temperature Overpressure Protection (LTOP} System applicability temperature specified in the PTLR. This restriction is to prevent a low temperature overpressure event due to a thermal transient VIAl en an RCP is started.

Note 4 provides for an orderly transition from I\IODE 5 to I\IODE 4 during a planned heatup by permitting removal ct RHR loops f10m operation Vlklen at least one RCS loop is in operation. This Note provides for the transition to l'vODE 4 Vlklere an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.

Note 5 restricts the number ci operating reactor coolant pumps at RCS temperatures less than 11 0°F. Only one reactor coolant pump is allo\1\ed to be in operation below 11 oo F (except during pump sv.ap operations} consistent wth the assumptions ct the Pff Lillits Curve.

RHR pumps are OPERABLE if they are capable ct being po\1\ered and are able to providefbwif r~uired. A SG can perform as a heat sink via natural circulation Vlklen it has an ad~ uate v.ater level and is OPERABLE. Management of gas '\tUids is important to RHR System OPERABIUTY.

(continued}

Farley Units 1 and 2 8 3.4.7-3 Revision I E4-4 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for infonnation only)

RCS Loops - fvODE 5, loops Filled B 3.4.7 BASES SURVEILLANCE SR 3.4.7.1 REQUIREI\IENTS Ttis SR requires verification that the required loop is in operation.

Verification includes flow rate, temperature, or pump status monitorirg, 'Ahich help ensure that forced flow is providing heat removal.

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

SR 3.4.7.2 Verf~ng that at least mo SGs are OPERABLE by ensurirg their secondary side wde range VIBter levels are ~ 75% ensures an alternate decay heat removal method via natural circulation in the event that the second RHR loop is not OPERABLE. If both RHR loops are OPERABLE, this Surveillance is not needed. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.7.3 Verification that a second RHR pump is OPERABLE ensures that an additional pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verfication is performed by verif~ng proper breaker algnment and po~~~er available to the RHR pump. If seoondary side V\ater level is ~ 75% (wde range) in at least mo SGs, this Surveillance is not needed. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.7.4 RHR Svstem pipirg 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 required RHR loop(s) and may also prevent V\ater hammer. pump cavitation. and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Svstem locations susceptible to gas accumulation is based on a review of system design information. including piping and instrumentation drawngs. isometric drawng s. plan and elevation drawngs, and calculations. The design review is supplemented by system V\alk do\Mls to validate the system high points and to confirm the location and orientation of important components that can become (continued)

Farley Units 1 and 2 B 3.4.7-5 Revision I E4-5 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops - l\tODE 5, loops Filled B 3.4.7 BASES SURVEILLANCE SR 3.4.7.4 (continued)

REQUIREtv£NTS sources of gas or could otherwse cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system confburation, such as stand-by versus operating conditions.

The RHR 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 System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with V\B.ter). the Surveillance may be declared met.

Accumulated gas should be eliminated or brought wthin the acceptance criteria limits. When the RHR System is restored to service. the surveillance is met by virtue of the performance of operating procedures that ensure the RHR Loop is adequately filled and vented. The performance of these manual actions ensures that the surveillance is met.

RHR 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 11\hich are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the 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 \/\here 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 SR may be met for a RHR Loop by virtue of having a loop in service in accordance wth operating procedures.

(continued)

Farley Units 1 and 2 B 3.4.7-6 Revision E4-6

Enclosure 4 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops - fvODE 5, Loops Filled B 3.4.7 BASES SURVEILLANCE SR 3.4.7.4 (continued)

REQUI REf\..£ NT S The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns, if no evolutions were performed that can introduce voids into the RHR loop.

The SuNeillance Freo uency is controlled under the Surveillance Frequency Control Prooram. The SuNeillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES 1. NRC Information Notice 95-35, "Degraded Ability cl Steam Generators to Remove Decay Heat by Natural Circulation."

Farley Units 1 and 2 B 3.4.7-7 Revision I E4-7

Enclosure 4 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops, - fvODE 5, Loops Not Filled B 3.4.8 BASES LCO Note 1 permit.s all RHR pumps to not be in operatk::m for s 15 minutes (continued) Vlklen swtching from one loop to another. The circumstances for stopping both RHR pumps are to be limited to situations W"len the outage time is short and core outlet temperature is maintained > 1ooF below saturation temperature. The Note prohibits boron dilution or draining operations W"len RHR forced flow is stopped.

Note 2 allo\1\S one RHR loop to be inoperable for a period of s 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time W"len these tests are safe and possible.

An OPERABLE RHR loq> is comprised of an OPERABLE RHR pump capable of providing forced flow to an 0 PERABLE RH R heat exchanger. RHR pumps are OPERABLE f they are capable of being po~J~.ered and are able to provide flow if required. Management of gas voids is important to RHR Svstem OPERABIUTY.

APPLICABIUTY In fvODE 5 wth loops not filled, this LCO requires core heat removal and coolant circulation by the RHR System.

Operation in other fvODES is covered by:

LCO 3.4.4, "RCS Loops- fvODES 1 and 2";

LCO 3.4.5, "RCS Loops- fvODE 3";

LCO 3.4.6, "RCS Loops- fvODE 4";

LCO 3.4.7, "RCS Loops- fvODE 5, Loops Filled";

LCO 3.9.4, "Residual Heat Removal (RHR) and OJolant Circulation- HghWater Level" (fvODE 6); and LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (fvODE 6).

ACTIONS If only one RHR loop is OPERABLE and in operation, redundancy for RHR is lost. Action must be initiated to restore a second loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of tw:> paths for heat removal.

(continued)

Farley Units 1 and 2 B 3.4.8-2 Revision I E4-8

Enclosure 4 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops, - fvODE 5, Loops Not Filled B.3.4.8 BASES ACTIONS B.1 and B.2 (continued)

If no required RHR loops are OPERABLE or in operation, e)(Cept during conditions permitted by Note 1, all operations in~lving a reduction ct RCS boron concentration must be suspended and action must be initiated inmediatel y to restore an RHR loop to OPERABLE status and q>eration. Boron dilution requires forced circulation for uniform dik.Jtion, and the margin to criticality must not be reduced in this twe of operation. The immediate Completion Time reflects the importance ct maintaining operation for heat removal. Tte action to restore must continue untH one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.8.1 REQUIREI\t£NTS This SR requires verification that one loop is in operation. Verification includes flow rate, temperature, or pump status monitoring, W"lich help ensure that forced flow is providing heat removal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.8.2 Verrication that the required number cl pumps are OPERABLE ensures that additional pumps can be placed in q>eration, W needed, to maintain decay heat removal and reactor coolant circulation.

Verrication is performed by verif~ng proper breaker algnment and poVIer available to the required pumps. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.8.3 RHR System piping and components have the potential to develop

~ids and pockets of entrained gases. Preventing and managing gas intrusion and accumulatbn is necessarvfor proper operation of the RHR loops and may also prevent ~Aater hammer. pump cavitation, and pumping of noncondensable gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system desgn information, including pipirg and instrumentation draiMng s. isometric drawng s.

plan and elevation drawngs, and calculations. The design review (continued)

Farley Units 1 and 2 B 3.4.8-3 Revision I E4-9 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops,- l\tODE 5, Loops Not Filled B 3.4.8 BASES SURVEILLANCE SR 3.4.8.3 (continued)

REQUIRErvENTS is supplemented by S'x§tem ~lk doWls to validate the S'x§tem hgh points and to confirm the location and orientation of important components that can beoome sources of gas or could otherwse cause gas to be trapped or difficult to remove during S'x§tem maintenance or restoration. Susceptible locations depend on plant and S'x§tem confburation. such as stand-by versus operating conditions.

The RHR System is OPERABLE IAhen it is sufficientlyfilled wth ~Aater.

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 System is not rendered inoperable by the accumulated gas (i.e .. the system is sufficiently filled wth 'AElter), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

When the RHR System is restored to service. the surveillance is met by virtue of the performance of operating procedures that ensure the RHR Loop is adequately filled and vented. The performance of these manual actions ensures that the surveillance is met.

RHR 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 sub-set of susceptible locations. M:mitoring may not be practicalfor locations that are inaccessible due to radiological or environmental oonditions.

the plant configuration. or personnel safety. For these locations alternative methods (e.g., operating parameters. remote monitoring) may be used to monitcr the susceptible location. fvbnitoring is not required for susceptible locations \Mlere the maximum potential accumulated gas 'vOid 'vOlume has been evaluated and determined to not challenge system OPERABIUTY. The accuracy of the method used for monitorirq the susceptible locations and trendirq of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The SR may be met for a RHR Loop by virtue of having a loop in service in accordance with operating procedures.

(continued)

Farley Units 1 and 2 B 3.4.8-4 Re\Asion I E4-10

Enclosure 4 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops, - l'vODE 5, Loops Not Filled B3.4.8 BASES SURVEILLANCE SR 3.4.8.3 (continued)

REQUIRErvENTS The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns.

if no evolutions were performed that can introduce voids into the RHR loop.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

Farley Units 1 and 2 B 3.4.8-5 Re\Asion I E4-11 to NL-15*0421 FNP Technical Specification Bases Marked Up Pages (for information only)

ECCS - Operating B 3.5.2 BASES APPLICABLE pump delivers sufficient fluid to maintain RCS inventory. For a small SAFETY ANALYSES break LOCA, the steam generators continue to serve as the (continued) heat sink, providing part of the required core cooling.

The ECCS trains satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO In !\!ODES 1, 2, and 3, two independent (and redundant) ECCS trains are required to ensure that sufficient ECCS flow is available, assuming a single failure affecting either train. Additionally, individual components wthin the ECCS trains may be called upon to mitigate the consequences of other transients and accidents.

In tv'ODES 1, 2, and 3, an ECCS train consists of a centr~ugal charging subsystem and an RHR subsystem. Each train includes the piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the RVVST upon an Sl signal and transferring suction to the containment sump.

During an event requiring ECCS actuation, a flow path is required to provide an abundant supply of vvater from the RVVSf to the RCS via the ECCS pumps and their respective supply headers to each of the three cold leg injection nozzles. Each centr~ugal charging pump must inject 2: 495.6 gpm and each RHR pump must inject 2: 3402 gpm at 40 psig RCS pressure. These flo'AS, in conjunction wth the RVVSf minimum boron concentration, provide sufficient cooling 'Miter and negative reactivity to ensure that the ECCS acceptance criteria are satisfied. In the long term, this flow path may be swtched to take its supply from the containment sump and to supply its flow to the RCS hot and cold legs. rvbnaqement of gas voids is important to ECCS OPERABILITY.

The flow path for each train must maintain its designed independence to ensure that no single failure can disable both ECCS trains.

The LCO is mod~ied by two notes. Note 1 provides an exception to the LCO W"lich allo'AS the centr~ugal charging subsystem floV~~path or the RHR subsystem floV~~path to be isolated. Both the centrifugal charging and the RHR subsystems may be isolated but not at the same time. Each ECCS subsystem flow path may be isolated for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in tv'ODE 3, under controlled conditions, to perform pressure isolation valve testing per SR 3.4.14.1. The flow path is readily restorable.

(continued)

Farley Units 1 and 2 B 3.5.2-5 Revision E4*12

Enclosure 4 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for Information only)

ECCS - Operating BASES 83.5.21 SURVEILLANCE SA 3.5.2.2 (continued)

REQUI REI\t£NT S The Surveillance is modfied by a Note 'v\tlich exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing an individual vJlo can rapidly close the system vent flow path ff directed.

SA 3.5.2.3 Periodic surveillance testing ct ECCS pumps to detect gross degradation caused by impeller structural damage or other h~raulic component problems is required by Section XI ct the ASI\t£ Code.

Ttis t}'pe of testing may be accomplished by measuring the pump developed head at only one point ct the pump characteristic curve.

For example, f measured on recirculation flow, the centrWugal charging pumps should develop a differential pressure ct 2:. 2323 psid and the residual heat removal pumps should develop a dWferential pressure ct 2:. 145 psid. This verifies both that the measured performance is wthin an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the plant safety analysis. Testing is performed in accordance wth the lnservice Testing Program, \\hich encompassesSection XI of the ASI\t£ Code.

Section XI of the ASI\t£ Code provides the activities and Frequencies necessary to satisfy the requirements.

Any change in the components being tested by this SR wll require reevaluation of STI Evaluation Number 558904 in accordanc e wth the Surveillance Frequency Control Program.

SR 3.5.2.4 and SR 3.5.2.5 These Surveillances demonstrate that each automatic ECCS valve actuates to the required position on an actual or simulated Sl signal and that each ECCS pllTlp (centrWugal charging and RHR) starts on receipt of an actual or smulated Sl signal. This Surveillance is not required for valves that are locked, sealed, or other\\4se secured in the required position under administrative controls. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

Farley Units 1 and 2 8 3.5.2-9 Revision E4-13 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

ECCS - Operating 83.5.2 BASES SURVEILLANCE SR 3.5.2.6 REQUIREI\IENTS (continued) Realignment of valves in theflowpath on an Sl signal is necessary for proper ECCS performance. These valves have stops (RHR valves) or locking devices (other ECCS valves) to allow proper positioning for limiting total pump flow and/or restrict flow to a ruptured cold leg, ensuring that the other cold legs receive at least the required minimum flow. The required verification for the RHR valves, 603 A/8, assures that the associated pump wll not be run out. For other ECCS valves, the bcking device is verified i1 the correct position. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.7 Periodic inspections of the containment sump suction inlet ensure that it is unrestricted and sta~ in proper operating condition. The inlet screens consist of perforated plates arranged such that their outer edges form a trash rack to reduce clogging of the screen surf ace by large debris. Each plate is covered by wre mesh to further protect against clegg ing by smaller debris. Separation bemeen plates is maintained by spacers and each plate is joined to a central perforated cylinder, or inner cage, W"lich collects the flow through each plate.

Inspection d the screen plate structure, wre mesh screen, perforated plates and inner cage for evidence of structural distress or abnormal corrosion ensures that the inlet trash racks, screens and inner cages are properly installed and wll perform their intended function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.8 ECCS piping and components have the potential to develop '.tUids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessarvfor proper operation of the ECCS and may also prevent V\Elter hammer. pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of ECCS locations susceptible to accumulation is based on a review of system design information. including piping and instrumentation drawngs, isometric drawngs. plan and elevation drawngs, and calculations. The design review is supplemented by system VIEllk doVIIfls to validate the system high points and to confirm the location and orienta ton 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 (continued)

Farley Units 1 and 2 8 3.5.2-10 Revision E4-14 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for Information only)

ECCS - Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.6 REQUI REI'v£NT S (continued) locations depend on plant and system configuration, such as stand-by versus operating conditions.

The ECCS is OPERABLE W'len it is sufficientlyfilled wth \1\ater.

Acceptance criteria are established for the \Oiume d accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the

\Oiume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas \Oiume at the suction or discharged a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled wth \1\ater).

the Surveillance may be declared met. Accumulated gas should be eliminated or brol.flht wthin the acceptance criteria limits.

ECCS 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 sub-set of susceptible locations. Monitoring may not be practical f or locations that are inaccessible due to radiolog ical or environmental conditions. the 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 the 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.

Farley Units 1 and 2 B 3.5.2-11 Re\1sion I E4-15 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

ECCS - ShutdoWl B3.5.3 BASES LCO and controls to ensure an OPERABLE flow path capable of taking (continued) suction from the RN sr and transferring suction to the containment sump.

During an event requiring ECCS actuation, a flow path is required to pro\1de an abundant supply of Vlater from the RN ST to the RCS \1a the ECCS pumps and their respective supply headers to each of the three cold leg injection noz21es. In the long term, this flow path may be swtched to take its supply from the containment sump and to deliver its flow to the RCS hot and cold legs. IVanagement of gas voids is important to ECCS OPERABIUTY.

This LCO is modfied by t\\o notes. Note 1 alloll\6 a RHR train to be considered OPERABLE during alignment and operation for decay heat removal, f capable of being manually realigned (remote or locaQ to the ECCS mode of operation and not other'JI.4se inoperable. This alloll\6 operation in the RHR mode during l\tODE 4.

Note 2 pro\1des an alloVIance d up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to reposition the state of the poVI.er supplies for the RHR discharge to centrifugal charging pump suction valves 8706A and 8706B W'len transitioning from l\tODE 3 into l\tODE 4. This alloV\Snce is necessary since the required state of the poVI.er supplies for these tv.o valves in l\tODE 3 is opposite the required state in l\tODE 4 and time is necessary to remove poVI.er from the valves W'len entering l\tODE 4 from l\tODE 3.

APPLICABIUTY In l\tODES 1, 2, and 3, the OPERABIUTY requirements for ECCS are covered by LCO 3.5.2.

In l\tODE 4 wth RCS temperature below 350°F, one OPERABLE ECCS train is acceptable wthout single failure consideration, on the basis d the stable reactivity of the reactor and the limited core cooling requirements.

In l\tODES 5 and 6, plant conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in l\tODE 5 are addressed by LCO 3.4.7, "RCS Loops

-l\tODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops -l\tODE 5, Loops Not Filled." l\tODE 6 core cooling requirements are addressed by LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation- High Water Level," and LCO 3.9.5, "Residual Heat Removal (RHR) and Codant Circulation-Low Water Level."

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Containment Spray and Cooling Systems B 3.6.6 BASES APPLICABLE Containment cooling trail performance for post accident conditions is SAFETY ANALYSES given in Reference 3. The result of the analysis is that each train (continued) having at least one OPERABLE fan untt wth at least 600 g pm SN flow can provide 100% d the required peak cooling capacity during the post accident conditbn. The train post accident cooling capacity under varying containment ambient conditions, required to perform the accident analyses, is also shaWl in Reference 5.

Tl"e modeled Containment Cooling System actuation from the containment analysis is based upon a response time associated wth exceeding the containment High-1 pressure setpoint to achieving full Containment Cooling System air and safety grade cooling VIBter flow.

Tl"e Containment Cooling System total response time of 87 seconds, includes signal delay, DG startup (for loss of offsite po\M9r), and service VIBter pump startup times (Ref. 4).

Tl"e Containment Spray System and the Containment Cooling System satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO During a DBA, a minimum of one containment cooling train wth a sing le OPERABLE fan unit and one containment spray train are required to maintain the containment peak pressure and temperature below the design limits (Ref. 3). Additionally, one containment spray train is also required to remove iodine from the containment atmosphere and maintain concentrations below those assumed in the safety analysis.

To ensure that these requirements are met, tV\0 containment spray trains and tV\0 containment cooling trains wth a single OPERABLE f an unit per cooling train wth at least 600 g pm SN flow must be OPERABLE. Therefore, in the event of an accident, at least one train in each system operates, assuming the V\Orst case single active failure occurs.

Each Containment Spray System t}.pically includes a spray pump, spray headers, nozzles, valves, piping, instruments, and controls to ensure an OPERABLEfbwpath capable d taking suction from the RN ST upon an ESF actuation signal and manually transferring suction to the containment sump. Management of gas voids is important to Containment Spray Svstem OPERABILITY.

Each Containment Cooling System twically includes cooling coils, dampers, fans, instruments, and controls to ensure an OPERABLE flow path.

Farley Units 1 and 2 B3.6.6-5 Revision I E4-17 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

Containment Spray and Cooling Systems 8 3.6.6 BASES ACTIONS E.1 and E.2 (continued)

If the Required Action and associated Completion Time of Condition CorD of this LCO are not met, the plant must be brought to a l'vODE in W'lich the LCO does not apply. To achieve this status, the plant must be brought to at least l'vODE 3 wthin 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to l'vODE 5 wthin 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allo~~~oed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full po~~~oer conditions in an orderly manner and

~thout challenging plant systems.

W lh tv.o containment spray trains or any combination of three or more containment spray and cooling trains inoperable, the unit is in a condition outside the accident analysis. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.6.6.1 REQUIREI'v£NTS VerWying the correct alignment for manual, po~~~oer operated, and automatic valves in the containment spray flow path provides assurance that the proper flow paths wll exist for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or othei"Wse secured in position, since these ~~~oere verified to be in the correct position prior to locking, sealing, or securing. This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system ~AalkdoWl, that those valves outside containment (only check valves are inside containment) and capable of potentially beilg mispositioned are in the correct position.

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

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing an individual ooo can rapidly close the system vent flow path Wdirected.

(continued}

Farley Units 1 and 2 8 3.6.6-8 Revision E4-18 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for infonnation only)

Containment Spray and Cooling Systems 83.6.6 BASES SURVEILLANCE SR 3.6.6.4 (continued)

REQUIREM:NTS Any change in the components being tested by this SR wll require reevaluation of STI Evaluation Number 558904 in accordance wth the Surveillance Frequency Control Program.

SR 3.6.6.5 and SR 3.6.6.6 These SRs require ver~ication that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation of a containment High-3 pressure signal. This Surveillance is not required for valves that are locked, sealed, or otherWse secured in the required position under administrative controls. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The surveillance of containment sump isolation valves is also required by SR 3.5.2.5. A single surveillance may be used to satisfy both requirements.

SR 3.6.6.7 This SR requires ver~ication that each containment cooling train actuates upon receipt of an actual or simulated safety injection signal.

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

SR 3.6.6.8 Wlh the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be bloWl through test connections. This SR ensures that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degraded. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.6.9 Containment 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 containment spray trains and may also prevent v.a.ter hammer and pump cavitation.

(continued)

Farley Units 1 and 2 8 3.6.6-10 Revision E4-19 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

Containment Spray and Cooling Systems B3.6.6 BASES SURVEILLANCE SR 3.6.6.9 (continued)

REQUIREfvENTS Selection of Containment Spray System locations susceptible to gas accumulation is based on a review of system desgn information, including piping and instrumentation drawngs, isometric drawngs, plan and elevation drawngs, and calculations. The design review is supplemented by system vvalk doW1s to validate the system hgh points and to confirm the location and orientation of important components that can become sources of gas or could otheriMse cause gas to be trapped or dlficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system confguration, such as stand-by versus operating conditions.

The Containment Spray System is OPERABLE Vvhen it is sufficiently filled wth mter. 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 acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If tt is determined by subsequent evaluation that the Containment Spray System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled wth mter), the Surveillance may be declared met.

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

Containment Spray 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 W'lich are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. rvbnitoring may not be practical for locations that are inaccessible due to radiolooical or environmental conditions, the plant confguration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. 1\tbnitoring is not required for susceptible bcations W'lere 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 OPERABIUTY during the Surveillance interval.

(continued)

Farley Units 1 and 2 B3.6.6-11 Revision I E4-20 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

Containment Spray and Cooling Systems 8 3.6.6 BASES SURVEILLANCE SR 3.6.6.9 (continued)

REQUIRErvENTS The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 38, G DC 39, GDC 40, GDC 41, GDC 42, and GDC 43.

2. 10 CFR 50, Appendix K

3. FSAR, Section 6.2.

4. FSAR, Section 7.3.

5. FSAR, Section 15.

6. ASM:: Code for Operation and Mlintenance of Nuclear PoVI.er Plants.

Farley Units 1 and 2 8 3.6.6-12 Revision I E4-21 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

AHA and Coolant Circulation- High Water Level B 3.9.4 BASES LCO Only one RHR loop is required for decay heat removal in fvODE 6, wth the \/later level ~ 23 ft above the top of the reactor vessel flange.

Only one RHR loop is required to be OPERABLE, because the volume of \/later above the reactor vessel flange provides back up decay heat removal capability. At least one RHR loop must be OPERABLE and in op13ration to provide:

a. Removal of decay heat;

b. M>Cing of borated coolant to minimize the possibility of criticality; and

c. Indication of reactor coolant temperature.

An OPERABLE RHR loqJ includes an RHR pump, a heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path and to determine the low end temperature. The flow path starts in one of the RCS hot legs and is returned to the RCS cold legs.

fvlanagement of gas voids is important to RHR System OPERABILITY.

The LCO is modWied by a Note that alloV\5 the required operating RHR loop to not be in operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, provided no operations are permitted that oould cause a reduction of the RCS boron concentration. Boron concentration reduction is prohibited because unform concentration distribution cannot be ensured wthout forced circulation. This permits operations such as core mapping or alterations in the vicinity of the reactor vessel hot leg nozzles and RCS to RHR isolation valve testing. During this 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, decay heat is removed by natural convection to the large mass of \/later in the refueling cavity.

APPLICABIUTY One RHR loop must be OPERABLE and in operation in fvODE 6, wth the \/later level ~ 23ft above the top of the reactor vessel flange, to provide decay heat removal. The 23ft \/later level VIaS selected because tt corresponds to the 23ft requirement established for fuel movement in LCO 3.9.6, "Refueling CavityWater Level."

Requirements for the AHA System in other fvODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS), and Section 3.5, Emergency Core Cooling Systems (ECCS). AHA loop requirements in fvODE 6 wth the \/later level < 23ft are located in LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level."

Farley Units 1 and 2 B 3.9.4-2 Revision I E4-22 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RHR and Coolant Circulation- High Water Level 8 3.9.4 BASES ACTIONS A.4. A.S. A.6.1. and A.6.2 (continued)

Wlh RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the oontainment atmosphere. Performing the actions described above ensures that all containment penetrations are either closed or can be closed so that the dose linits are not exceeded.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months allo~~.S fixing of most RHR problems and is reasonable, based on the low probability of the coolant boiling in that time.

SURVEILLANCE SR 3.9.4.1 REQUIREI\IENTS This Surveillance demonstrates that the RHR loop is in operation and circulating reactor coolant. The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability and to prevent thermal and boron stratification in the oore. The Surveillance Frequency is controlled under the Surveillance Frequency Control Proram.

SR 3.9.4.2 RHR S'x§tem piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessaryfor proper operation of the RHR loops and may also prevent v..ater hammer. pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR S'x§tem locations susceptible to gas accumulation is based on a review of s'x§tem desgn information, including piping and instrumentation drawngs, isometric drawngs. plan and elevation drawngs, and calculations. The design review is supplemented by S'x§tem v..alk doWls to validate the S'x§tem high points and to confirm the location and orientation of important components that can become sources of gas or could otherv.ise cause gas to be trapped or difficu~

to remove during S'x§tem maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

(continued)

Farley Units 1 and 2 8 3.9.4-4 Revision I E4-23 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for infonnation only)

RHR and Coolant Circulation- High Water Level B 3.9.4 BASES SURVEILLANCE SR 3.9.4.2 (continued)

REQUIREI\IENTS The RHR System is OPERABLE W1en it is sufficientlyfilled wth ~Jater.

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 tt is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficientlyfilled wth ~Jater), the Surveillance may be declared met. Accumulated gas should be eliminated or brought wthin the acceptance criteria limits.

When the RHR System is restored to service, the surveillance is met by virtue of the performance of operating procedures that ensure the RHR Loop is adequately filled and vented. The performance of these manual actions ensures that the surveillance is met.

RHR System locations susceptible togas 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 W1ich are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. fvbnitoring may not be practical for locations that are inaccessible due to radiobgical or environmental ronditions, the plant confguration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monttoring) may be used to monitor the susceptible location. fvbnitoring is not required for susceptible locations W1ere the maximum potential accumulated gas

\!Qid \!Qiume has been evaluated and determinedto not challenge system OPERABIUTY. 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 SR may be met for a RHR Loop by virtue of having a loop in service in accordance with operating procedures.

The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns, if no evolutions were performed that can introduce voids ihto the RHR loop.

Farley Units 1 and 2 B 3.9.4-5 Revision E4-24

Enclosure 4 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RHR and Coolant Circulation- High Water Level B 3.9.4 BASES SURVEILLANCE SR 3.9.4.2 (continued)

REQUIRErvENTS The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary Q.y location susceptible to gas accumulation.

REFERENCES 1. FSAR, Section 5.5.7.

Farley Units 1 and 2 B 3.9.4-6 Re~sion I E4-25 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for Information only)

RHR and Coolant Circulation- Low Water Level B3.9.5 BASES LCO An OPERABLE RHR loq::> consists of an RHR pLmp, a heat (continued) exchanger, valves, piping, instruments and controls to ensure an OPERABLE flow path and to determine the low end temperature.

Tteflow path starts in one of the RCS hot legs and is returned to the RCS cold legs. Mmagement of gas voids is imoortant to RHR System OPERABIUTY.

Tte LCO requirements are modWied by a Note Vlhich provides an exception to the requirements for one RHR loop to be OPERABLE and one RHR loop to be in operation. This exception is necessary to ensure the RHR System may be realigned as neressaryfor up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to perform the required surveillance testing necessary to verify the RHR System performance in the ECCS injection mode of operation.

APPLICABIUTY TIJ\0 RHR loops are required to be OPERABLE, and one RHR loop must be in operation in MJDE 6, wth the Vloater level < 23 f t above the top of the reactor vessel flange, to provide decay heat removal.

Requirements for the RHR System in other MJDES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS}, and Section 3.5, Emergency Core Cooling Systems (ECCS). RHR loop requirements in MJDE 6 wth the VIBter level ~ 23 ft are located in LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level."

ACTIONS A.1 and A.2 If less than the required number cl RHR loops are OPERABLE, action shall be immediately initiated and continued until the RHR loop is restored to OPERABLE status and to operation or until ~ 23 ft of water level is established above the reactor vessel flange. When the water level is ~ 23 ft abCM3 the reactor vessel flange, the Applicability changes to that of LCO 3.9.4, and only one RHR loop is required to be OPERABLE and in q::>eration. An immediate Completion Time is necessary for an operator to initiate corrective actions.

If no RHR loop is in operation, there wll be no forced circulation to provide mixing to establish unWorm boron concentrations. Reduced boron concentrations can occur by the addition of Vloater wth a lov.er boron concentration than the required boron conrentration specfied in the COLR Therefore, actions that could result in the addition of water to the RCS wth a boron concentration less than the required boron concentration specified in the COLA must be suspended immediately. *

(continued)

Farley Units 1 and 2 B 3.9.5-2 Revision I E4*26 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for infonnatlon only)

RHR and Coolant Circulation- Low Water Level B 3.9.5 BASES SURVEILLANCE SR 3.9.5.2 REQUIREI'vENTS (continued) VerWication that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation, W needed, to maintain decay heat removal and reactor coolant circulation.

VerWication is performed by verifying proper breaker algnment and poVIoer available to the required pump. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.9.5.3 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulatbn is necessary for proper operation of the RHR loops and may also prevent ~Aater hammer. pump cavitation. and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information. including piping and instrumentation drawngs. isometric drawngs, plan and elevation drawngs, and calculations. The design review is supplemented by system \o\alk downs to validate the system high points and to confirm the location and orientatbn of important components that can become sources of gas or could otherwse cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

ne RHR System is OPERABLE 'Ahen it is sufficiently filled wth \o\ater.

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 System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled

\!lAth ~Aater), the Surveillance may be declared met. Accumulated gas should be eliminated or brought wthin the acceptance criteria limits.

When the RHR System is restored to serv;ce, the SUI\eillance is met by virtue of the performance d operatirn procedures ttat ensure the RHR Loop is adoo uatelyf illed and ..ented. The performance d these manual actions ensures that the sul\eillance is met.

(continued)

Farley Units 1 and 2 B 3.9.5-4 Revision I E4-27

t::nclosure 4 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RHR and Coolant Circulation- Low Water Level 8 3.9.5 BASES SURVEILLANCE SR 3.9.5.3 (continued)

REQUIRErvENTS RHR S¥?tem locations susceptible to gas accumulation are monitored and. if gas is found, the gas \.Oiume is compared to the acceptance criteria for the location. Susceptible locations in the same S¥?tem flow path W'lich are subject to the same gas intrusion mechanisms may be verified by monitorioo a representative sub-set d susceptible locations. l'v1::mitoring may not be practical for locations that are inaccessible due to radiobg ical or environmental ronditions. the plant conf g uration. or personnel safety. For these locations alternative methods (e.g., operatioo parameters. remote mon~oring) may be used to monitor the susceptible location. M:>nitoring is not roo uiredfor susceptible locations W'lere the maximum potential accumulated gas

\.Oid \.Oiume has been evaluated and determined to not challerge system OPERABIUTY. The accuracyd the method used for monitorirg the susceptible locations and trendirg d the results should be suffcient to assure S'§tem OPERABIUTYduring the Surveillance interval.

The SR may be met for a RHR Loop by virtue of having a loop in service in accordance with operating procedures.

The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns, if no evolutions were performed that can introduce voids into the RHR loop.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES 1. FSAR, Section 5.5. 7.

Farley Units 1 and 2 83.9.5-5 Revision I E4-28