Text

Sequoyah Nuclear Plants, Units 1 and 2 - Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 3. Part 5 of 9
	ML15205A409
Person / Time
Site:	Sequoyah
Issue date:	07/24/2015
From:	; Tennessee Valley Authority
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML15205A404	List: CNL-15-156, Plants, Units 1 and 2 - Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 3. Part 1 of 9; ML15205A406; ML15205A407; ML15205A408; ML15205A409; ML15205A411; ML15205A412; ML15205A413; ML15205A414; NL-15-156, Sequoyah Nuclear Plants, Units 1 and 2 - Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 3. Part 1 of 9; NL-15-156, Sequoyah Nuclear Plants, Units 1 and 2 - Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 3. Part 2 of 9; NL-15-156, Sequoyah Nuclear Plants, Units 1 and 2 - Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 3. Part 3 of 9; NL-15-156, Sequoyah Nuclear Plants, Units 1 and 2 - Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 3. Part 4 of 9; NL-15-156, Sequoyah Nuclear Plants, Units 1 and 2 - Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 3. Part 5 of 9; NL-15-156, Sequoyah Nuclear Plants, Units 1 and 2 - Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 3. Part 6 of 9; NL-15-156, Sequoyah Nuclear Plants, Units 1 and 2 - Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 3. Part 7 of 9; NL-15-156, Sequoyah Nuclear Plants, Units 1 and 2 - Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 3. Part 8 of 9;
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MFIVs and MFRVs

[and Associated Bypass Valves

] B 3.7.3 Westinghouse STS B 3.7.3-4 Rev. 4.0 2 1SEQUOYAH UNIT 1 Revision XXX MFRV BASES

ACTIONS (continued)

Inoperable MFRVs, that are closed or isolated, must be verified on a periodic basis that they are closed or isolated. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of valve status indications available in the control room, and other administrative controls to ensure that the valves are closed or isolated.

C.1 and C.2

With one associated bypass valve in one or more flow paths inoperable, action must be taken to restore the affected valves to OPERABLE status, or to close or isolate inoperable affected valves within

[72] hours. When these valves are closed or isolated, they are performing their required

safety function.

The [72] hour Completion Time takes into account the redundancy afforded by the remaining OPERABLE valves and the low probability of an event occurring during this time period that would require isolation of

the MFW flow paths. The

[72] hour Completion Time is reasonable, based on operating experience.

Inoperable associated bypass valves that are closed or isolated must be verified on a periodic basis that they are closed or isolated. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of valve status indi cations available in the control room, and other administrative controls, to ensure that these valves are closed or isolated.

D.1 With two inoperable valves in the same flow path, there may be no redundant system to operate automatically and perform the required safety function. Although the containment can be isolated with the failure of two valves in parallel in the same flow path, the double failure can be an indication of a common mode failure in the valves of this flow path, and as such, is treated the same as a loss of the isolation capability of this flow path. Under these conditions, affected valve s in each flow path must be restored to OPERABLE status, or the affected flow path isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This action returns the system to the condition where at least one valve in each flow path is performing the required safety function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable, based on operating experience, to complete the actions required to close the MFIV or MFRV, or otherwise isolate the affected flow path.

MFRV MFRV 2 2 3 2 3one or mores inoperable at least one 3

MFIVs and MFRVs

[and Associated Bypass Valves

] B 3.7.3 Westinghouse STS B 3.7.3-5 Rev. 4.0 2 1SEQUOYAH UNIT 1 Revision XXX MFRV BASES

ACTIONS (continued)

E.1 and E.2

If the MFIV(s) and MFRV(s) and the associated bypass valve(s) cannot be restored to OPERABLE status, or closed, or isolated within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

[, and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

]. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that the closure time of each MFIV, MFRV, and

[associated bypass valve

] is within the limit given in Reference 2 and is within that assumed in the accident and containment analyses. This SR also verifies the valve closure time is in accordance with the Inservice Testing Program. This SR is normally performed upon returning the unit to operation following a refueling outage. These valves should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generating power. This is consistent with the ASME Code (Ref. 3), quarterly stroke requirements during operation in MODES 1 and 2.

The Frequency for this SR is in accordance with the Inservice Testing Program.

SR 3.7.3.2 This SR verifies that each MFIV, MFRV, and

[associated bypass valves

] can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage.

[ The Frequency for this SR is every [18]

months. The [18]

month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the [18]

month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

OR MFRV MFRV 2 2 5MFRV 2 3 MFIVs and MFRVs

[and Associated Bypass Valves

] B 3.7.3 Westinghouse STS B 3.7.3-6 Rev. 4.0 2MFRV Revision XXX SEQUOYAH UNIT 1 1BASES

SURVEILLANCE REQUIREMENTS (continued)

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

REFERENCES 1. FSAR, Section

[10.4.7].

2. [Technical Requirements Manual.

]

3. ASME Code for Operation and Maintenance of Nuclear Power Plants. U 6 2 1UFSAR, Section 7.3.

2 MFIVs and MFRVs

[and Associated Bypass Valves

] B 3.7.3 Westinghouse STS B 3.7.3-1 Rev. 4.0 2 1SEQUOYAH UNIT 2 Revision XXX MFRV B 3.7 PLANT SYSTEMS

B 3.7.3 Main Feedwater Isolation Valves (MFIVs) and Main Feedwater Regulation Valves (MFRVs)

[and Associated Bypass Valves

] BASES

BACKGROUND The MFIVs isolate main feedwater (MFW) flow to the secondary side of the steam generators following a high energy line break (HELB). The safety related function of the MFRVs is to provide the second isolation of MFW flow to the secondary side of the steam generators following an

HELB. Closure of the MFIVs and associated bypass valves or MFRVs and associated bypass valves terminates flow to the steam generators, terminating the event for feedwater line breaks (FWLBs) occurring upstream of the MFIVs or MFRVs. The consequences of events occurring in the main steam lines or in the MFW lines downstream from the MFIVs will be mitigated by their closure. Closure of the MFIVs and associated bypass valves , or MFRVs and associated bypass valves, effectively terminates the addition of feedwater to an affected steam generator, limiting the mass and energy release for steam line breaks (SLBs) or FWLBs inside containment, and reducing the cooldown effects for SLBs.

The MFIVs and associated bypass valves , or MFRVs and associated bypass valves, isolate the nonsafety related portions from the safety related portions of the system. In the event of a secondary side pipe rupture inside containment, the valves limit the quantity of high energy fluid that enters containment through the break, and provide a pressure boundary for the controlled addition of auxiliary feedwater (AFW) to the intact loops.

One MFIV and associated bypass valve, and one MFRV and its associated bypass valve, are located on each MFW line, outside but close to containment. The MFIVs and MFRV s are located upstream of the AFW injection point so that AFW may be supplied to the steam generators following MFIV or MFRV closure. The piping volume from these valves to the steam generators must be accounted for in calculating mass and energy releases, and refilled prior to AFW reaching the steam generator following either an SLB or FWLB.

The MFIVs and associated bypass valves , and MFRVs and associated bypass valves, close on receipt of a Tavg - Low coincident with reactor trip (P-4) or steam generator water level

- high high signal. They may also be actuated manually. In addition to the MFIVs and associated bypass valves, and the MFRVs and associated bypass valves, a check valve inside containment is available. The check valve isolates the feedwater line, penetrating containment, and ensures that the consequences of events do not exceed the capacity of the containment heat removal systems. MFRVMFRV MFRV MFRVMFRV MFRV MFRV , 2 3 3 3 3 3 3- outside 1 1 1 Regulating 1, MFRVs, bypass valves, safety injection, ,

MFIVs and MFRVs

[and Associated Bypass Valves

] B 3.7.3 Westinghouse STS B 3.7.3-2 Rev. 4.0 2 1SEQUOYAH UNIT 2 Revision XXX MFRV BASES

BACKGROUND (continued)

A description of the MFIVs and MFRVs is found in the FSAR, Section [10.4.7] (Ref. 1).

APPLICABLE The design basis of the MFIVs and MFRVs is established by the SAFETY analyses for the large SLB. It is also influenced by the accident analysis ANALYSES for the large FWLB. Closure of the MFIVs and associated bypass valves , or MFRVs and associated bypass valves, may also be relied on to terminate an SLB for core response analysis and excess feedwater event upon the receipt of a steam generator water level

- high high signal or a feedwater isolation signal on high steam generator level.

Failure of an MFIV, MFRV, or the associated bypass valves to close following an SLB or FWLB can result in additional mass and energy being delivered to the steam generators, contributing to cooldown. This failure also results in additional mass and energy releases following an SLB or FWLB event.

The MFIVs and MFRVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO This LCO ensures that the MFIVs, MFRVs, and their associated bypass valves will isolate MFW flow to the steam generators, following an FWLB

or main steam line break. These valves will also isolate the nonsafety related portions from the safety related portions of the system.

This LCO requires that

[four] MFIVs and associated bypass valves and [four] MFRVs [and associated bypass valves

] be OPERABLE. The MFIVs and MFRVs and the associated bypass valves are considered OPERABLE when isolation times are within limits and they close on an isolation actuation signal.

Failure to meet the LCO requirements can result in additional mass and energy being released to containment following an SLB or FWLB inside containment. If a feedwater isolation signal on high steam generator level is relied on to terminate an excess feedwater flow event, failure to meet the LCO may result in the introduction of water into the main steam lines.

APPLICABILITY The MFIVs and MFRVs and the associated bypass valves must be OPERABLE whenever there is significant mass and energy in the Reactor Coolant System and steam generators. This ensures that, in the event of an HELB, a single failure cannot result in the blowdown of more than one steam generator. In MODES 1, 2, [and 3], the MFIVs and MFRVs and the associated bypass valves are required to be OPERABLE to limit the amount of available fluid that could be added to containment in the case of a secondary system pipe break inside containment. When the valves are closed and de-activated or isolated by a closed manual valve, they are already performing their safety function.

U four MFRV MFRV MFRVMFRV MFRV 3 3 2 3 3 2MFRV 3MFRV 3 2 - 3 1 1 , , , , 4 ,, and MFRV bypass valves 4

MFIVs and MFRVs

[and Associated Bypass Valves

] B 3.7.3 Westinghouse STS B 3.7.3-3 Rev. 4.0 2 1SEQUOYAH UNIT 2 Revision XXX MFRV BASES

APPLICABILITY (continued)

In MODES 4, 5, and 6, steam generator energy is low. Therefore, the MFIVs, MFRVs, and the associated bypass valves are normally closed since MFW is not required.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each valve.

A.1 and A.2

With one MFIV in one or more flow paths inoperable, action must be taken to restore the affected valves to OPERABLE status, or to close or isolate inoperable affected valves within

[72] hours. When these valves are closed or isolated, they are performing their required safety function.

The [72] hour Completion Time takes into account the redundancy afforded by the remaining OPERABLE valves and the low probability of an event occurring during this time period that would require isolation of the MFW flow paths. The

[72] hour Completion Time is reasonable, based on operating experience.

Inoperable MFIVs that are closed or isolated must be verified on a periodic basis that they are closed or isolated. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of valve status indications available in the control room, and other administrative controls, to ensure that these valves are closed or isolated.

B.1 and B.2

With one MFRV in one or more flow paths inoperable, action must be taken to restore the affected valves to OPERABLE status, or to close or isolate inoperable affected valves within

[72] hours. When these valves are closed or isolated, they are performing their required safety function.

The [72] hour Completion Time takes into account the redundancy afforded by the remaining OPERABLE valves and the low probability of an event occurring during this time period that would require isolation of the MFW flow paths. The

[72] hour Completion Time is reasonable, based on operating experience.

INSERT 1 2 2 2 2 2 2MFRV 3 3 B 3.7.3 Insert Page B 3.7.3-3 INSERT 1 This includes separate Condition entry for two valves in the same flow path being inoperable.

This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable valve. Complying with the Required Actions may allow for continued operation, and subsequent inoperable valves are governed by subsequent Condition entry and application of associated Required Actions.

3 MFIVs and MFRVs

[and Associated Bypass Valves

] B 3.7.3 Westinghouse STS B 3.7.3-4 Rev. 4.0 2 1SEQUOYAH UNIT 2 Revision XXX MFRV BASES

ACTIONS (continued)

Inoperable MFRVs, that are closed or isolated, must be verified on a periodic basis that they are closed or isolated. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of valve status indications available in the control room, and other administrative controls to ensure that the valves are closed or isolated.

C.1 and C.2

With one associated bypass valve in one or more flow paths inoperable, action must be taken to restore the affected valves to OPERABLE status, or to close or isolate inoperable affected valves within

[72] hours. When these valves are closed or isolated, they are performing their required

safety function.

The [72] hour Completion Time takes into account the redundancy afforded by the remaining OPERABLE valves and the low probability of an event occurring during this time period that would require isolation of

the MFW flow paths. The

[72] hour Completion Time is reasonable, based on operating experience.

Inoperable associated bypass valves that are closed or isolated must be verified on a periodic basis that they are closed or isolated. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of valve status indi cations available in the control room, and other administrative controls, to ensure that these valves are closed or isolated.

D.1 With two inoperable valves in the same flow path, there may be no redundant system to operate automatically and perform the required safety function. Although the containment can be isolated with the failure of two valves in parallel in the same flow path, the double failure can be an indication of a common mode failure in the valves of this flow path, and as such, is treated the same as a loss of the isolation capability of this flow path. Under these conditions, affected valve s in each flow path must be restored to OPERABLE status, or the affected flow path isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This action returns the system to the condition where at least one valve in each flow path is performing the required safety function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable, based on operating experience, to complete the actions required to close the MFIV or MFRV, or otherwise isolate the affected flow path.

MFRV MFRV 2 2 3 2 3one or mores inoperable at least one 3

MFIVs and MFRVs

[and Associated Bypass Valves

] B 3.7.3 Westinghouse STS B 3.7.3-5 Rev. 4.0 2 1SEQUOYAH UNIT 2 Revision XXX MFRV BASES

ACTIONS (continued)

E.1 and E.2

If the MFIV(s) and MFRV(s) and the associated bypass valve(s) cannot be restored to OPERABLE status, or closed, or isolated within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

[, and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

]. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that the closure time of each MFIV, MFRV, and

[associated bypass valve

] is within the limit given in Reference 2 and is within that assumed in the accident and containment analyses. This SR also verifies the valve closure time is in accordance with the Inservice Testing Program. This SR is normally performed upon returning the unit to operation following a refueling outage. These valves should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generating power. This is consistent with the ASME Code (Ref. 3), quarterly stroke requirements during operation in MODES 1 and 2.

The Frequency for this SR is in accordance with the Inservice Testing Program.

SR 3.7.3.2 This SR verifies that each MFIV, MFRV, and

[associated bypass valves

] can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage.

[ The Frequency for this SR is every [18]

months. The [18]

month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the [18]

month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

OR MFRV MFRV 2 2 5MFRV 2 3 MFIVs and MFRVs

[and Associated Bypass Valves

] B 3.7.3 Westinghouse STS B 3.7.3-6 Rev. 4.0 2MFRV Revision XXX SEQUOYAH UNIT 2 1BASES

SURVEILLANCE REQUIREMENTS (continued)

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

REFERENCES 1. FSAR, Section

[10.4.7].

2. [Technical Requirements Manual.

]

3. ASME Code for Operation and Maintenance of Nuclear Power Plants. U 6 2 1UFSAR, Section 7.3.

2 JUSTIFICATION FOR DEVIATIONS ITS 3.7.3 BASES, MAIN FEEDWATER ISOLATION VALVES (MFIVs), MAIN FEEDWATER REGULATING VALVES (MFRVs) AND MFRV BYPASS VALVES Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The ISTS Bases contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

3. Changes are made to be consistent with changes made to the Specification.

4. Editorial changes made for enhanced clarity/consistency.

5. ISTS SR 3.7.3.2 and Bases (ITS SR 3.7.3.2) provides two options for controlling the Frequency of the Surveillance Requirement. SQN is proposing to control the Surveillance Frequency under the Surveillance Frequency Control Program. Additionally, the Frequency description which is being removed will be included in the Surveillance Frequency Control Program.

6. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.3, MAIN FEEDWATER ISOLATION VALVES (MFIVs), MAIN FEEDWATER REGULATING VALVES (MFRVs) AND MFRV BYPASS VALVES Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 4 ITS 3.7.4, ATMOSPHERIC RELIEF VALVES

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

M01Add proposed ITS 3.7.4 Page 1 of 2 SEQUOYAH - UNIT 1 M01Add proposed ITS 3.7.4 Page 2 of 2 SEQUOYAH - UNIT 2 DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC RELIEF VALVES (ARVs)

Sequoyah Unit 1 and Unit 2 Page 1 of 1 ADMINISTRATIVE CHANGES None

MORE RESTRICTIVE CHANGES

M01 The Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) do not contain a requirement for atmospheric relief valves. ITS 3.7.4 specifies the requirements for the atmospheric relief valves, consistent with the requirements of ISTS 3.7.4, "Atmospheric Dump Valves." This changes the CTS by incorporating the requirements of ITS 3.7.4, "Atmospheric Relief Valves." The purpose of ITS 3.7.4 requirements is to ensure that the atmospheric relief valves are available to establish sufficient subcooling in the RCS following a Steam Generator Tube Rupture (SGTR). This change is acceptable because the atmospheric relief valves provide a means for the operator to sufficiently subcool the RCS following a SGTR accompanied by a loss of offsite power. This change is considered more restrictive because it is adding a new requirement to the Technical Specifications.

RELOCATED SPECIFICATIONS None

REMOVED DETAIL CHANGES None

LESS RESTRICTIVE CHANGES

None Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

ADVs 3.7.4 Westinghouse STS 3.7.4-1 Rev. 4.0 1 5SEQUOYAH UNIT 1 Amendment XXX CTS ARVs3.7 PLANT SYSTEMS

3.7.4 Atmospheric Dump Valves (ADVs)

LCO 3.7.4

[Three] ADV lines shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. One required ADV line inoperable.

A.1 Restore required ADV line to OPERABLE status.

7 days B. Two or more required ADV lines inoperable.

B.1 Restore all but one ADV line to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months C. Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4 without reliance upon steam generator for heat removal.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

[24] hours

Relief 1 1 Four ARV 2 2 DOC M01 DOC M01 DOC M01 DOC M01 DOC M01 1 3 1 3 ARVsINSERT 1 ARV INSERT 2 ARV 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s s 4 4 3.7.4 Insert Page 3.7.4-1 CTS INSERT 1 One or more ARV line(s) inoperable due to one

train of Auxiliary Control Air System (ACAS) nonfunctional.

INSERT 2 One or more ARV line(s) inoperable for reasons other than Condition A.

4 4 DOC M01 DOC M01 ADVs 3.7.4 Westinghouse STS 3.7.4-2 Rev. 4.0 1 5SEQUOYAH UNIT 1 Amendment XXX CTS ARVsSURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify one complete cycle of each ADV. [ [18] months OR In accordance with the Surveillance Frequency Control Program ] SR 3.7.4.2 [ Verify one complete cycle of each ADV block valve. [ [18] months OR In accordance with the Surveillance Frequency Control Program ] ] 1 6 DOC M01 ARV 6 2Inservice Testing ADVs 3.7.4 Westinghouse STS 3.7.4-1 Rev. 4.0 1 5SEQUOYAH UNIT 2 Amendment XXX CTS ARVs3.7 PLANT SYSTEMS

3.7.4 Atmospheric Dump Valves (ADVs)

LCO 3.7.4

[Three] ADV lines shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. One required ADV line inoperable.

A.1 Restore required ADV line to OPERABLE status.

7 days B. Two or more required ADV lines inoperable.

B.1 Restore all but one ADV line to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months C. Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4 without reliance upon steam generator for heat removal.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

[24] hours

Relief 1 1 Four ARV 2 2 DOC M01 DOC M01 DOC M01 DOC M01 DOC M01 1 3 1 3 ARVsINSERT 1 ARV INSERT 2 ARV 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s s 4 4 3.7.4 Insert Page 3.7.4-1 CTS INSERT 1 One or more ARV line(s) inoperable due to one train of Auxiliary Control Air System (ACAS) nonfunctional.

INSERT 2 One or more ARV line(s) inoperable for reasons other than Condition A.

4 4 DOC M01 DOC M01 ADVs 3.7.4 Westinghouse STS 3.7.4-2 Rev. 4.0 1 5SEQUOYAH UNIT 2 Amendment XXX CTS ARVsSURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify one complete cycle of each ADV. [ [18] months OR In accordance with the Surveillance Frequency Control Program ] SR 3.7.4.2 [ Verify one complete cycle of each ADV block valve. [ [18] months OR In accordance with the Surveillance Frequency Control Program ] ] 1 6 DOC M01 ARV 6 2Inservice Testing JUSTIFICATION FOR DEVIATIONS ITS 3.7.4, ATMOSPHERIC RELIEF VALVES (ARVs)

Sequoyah Unit 1 and Unit 2 Page 1 of 2 1. ISTS 3.7.4, "Atmospheric Dump Valves" title has been changed to "Atmospheric Relief Valves" to reflect the description name used at Sequoyah Nuclear Plant. Additionally, the acronyms "ADVs" and "ADV" have been changed to "ARVs" and "ARV," respectively.

2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

3. The term "required" has been removed from ISTS 3.7.4 ACTIONS A and B since there are four atmospheric relief valves and all four valves are required per ITS LCO 3.7.4.

4. The SQN UFSAR accident analysis describes the use of ARVs in the mitigation of a Steam Generator Tube Rupture event concurrent with a loss of offsite power. The accident analysis assumes the steam generator ARVs associated with the unaffected steam generators are available to cool down the RCS and terminate the primary to secondary leak.

ISTS 3.7.4 ACTION A requires the restoration of the required ADV line to OPERABLE status in 7 days when one required ADV line is inoperable. ISTS 3.7.4 ACTION B requires the restoration of all but one ADV lines to OPERABLE status in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when two or more ADV lines are inoperable. Twenty four hours reflects a Completion Time commensurate with a loss of safety function while providing some time to effect repair and considering the low probability of an event occurring during the time that would require the ADV lines. ITS 3.7.4 ACTION A requires the restoration of the affected ARV lines to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when one or more ARV line(s) are inoperable due to one train of Auxiliary Control Air System (ACAS) being nonfunctional. ITS 3.7.4 ACTION B requires restoration of all ARV lines to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when one or more ARV lines are inoperable for reasons other than Conditon A.

The ACAS system supplies essential air to the ARVs on loss of offsite power. The ACAS system consists of two trains. Train A supplies essential air to steam generator 1 and 3 ARVs and train B supplies essential air to steam generator 2 and 4 ARVs. On a loss of one train of essential air to the ARVs, alternate means are available to operate the affected ARVs via a manual loading station and relief handwheels. The use of the alternate means for operating the ARVs allows the ARVs to be operated in the mitigation of a steam generator tube rupture event concurrent with a loss of offsite power. SQN has established station procedures and training for operation of the ARVs outside the control room. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is acceptable because alternate means to operate the ARVs are available to provide compensatory measures in response to the degraded condition in order to minimize risk associated with continued operation, while providing time to repair the nonfunctional ACAS train.

5. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

JUSTIFICATION FOR DEVIATIONS ITS 3.7.4, ATMOSPHERIC RELIEF VALVES (ARVs) Sequoyah Unit 1 and Unit 2 Page 2 of 2 6.ISTS SR 3.7.4.1 provides two options for controlling the Freq uency of the Surveillance Requirement. SQN is proposing to control the ARV Surveillance Frequency under the Inservice Testing Program. The ARVs are ASME Section X I Code Class valves at SQN and as such are tested under the SQN ASME Section XIInservice Testing Program.

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

ADVs B 3.7.4 Westinghouse STS B 3.7.4-1 Rev. 4.0 1 ARVs 2Revision XXXSEQUOYAH UNIT 1 B 3.7 PLANT SYSTEMS B 3.7.4 Atmospheric Dump Valves (ADVs) BASES BACKGROUND The ADVs provide a method for cooling the unit to residual heat removal (RHR) entry conditions should the preferred heat sink via the Steam Bypass System to the condenser not be available, as discussed in the FSAR, Section

[10.3] (Ref. 1). This is done in conjunction with the Auxiliary Feedwater System providing cooling water from the condensate storage tank (CST). The ADVs may also be required to meet the design cooldown rate during a normal cooldown when steam pressure drops too low for maintenance of a vacuum in the condenser to permit use of the Steam Dump System.

One ADV line for each of the

[four] steam generators is provided. Each ADV line consists of one ADV and an associated block valve. The ADVs are provided with upstream block valves to permit their being tested at power, and to provide an alternate means of isolation. The ADVs are equipped with pneumatic controllers to permit control of the cooldown rate.

The ADVs are usually provided with a pressurized gas supply of bottled nitrogen that, on a loss of pressure in the normal instrument air supply, automatically supplies nitrogen to operate the ADVs. The nitrogen supply is sized to provide the sufficient pressurized gas to operate the ADVs for the time required for Reactor Coolant System cooldown to RHR entry conditions.

A description of the ADVs is found in Reference 1. The ADVs are OPERABLE with only a DC power source available. In addition, handwheels are provided for local manual operation. APPLICABLE The design basis of the ADVs is established by the capability to cool the SAFETY unit to RHR entry conditions. The design rate of [75

]°F per hour is ANALYSES applicable for two steam generators, each with one ADV. This rate is adequate to cool the unit to RHR entry conditions with only one steam generator and one ADV, utilizing the cooling water supply available in the CST. In the accident analysis presented in Reference 1 , the ADVs are assumed to be used by the operator to cool down the unit to RHR entry conditions for accidents accompanied by a loss of offsite power.

Prior to operator actions to cool down the unit, the ADVs and main steam safety valves (MSSVs) are assumed to operat e automatically to relieve steam and maintain the steam generator pressure below the design value. For the recovery from a steam generator tube rupture (SGTR) event, the 1 Relief ARVs U 1 2 3 1 3 1 1 2 1 4 2 2 ARVs Dump ARVs ARV ARV ARVs ARVsand plant safety grade air supply INSERT 2INSERT 1 INSERT 3 2 2 ARVs 4INSERT 4 ARVs B 3.7.4 Insert Page B 3.7.4-1 INSERT 1 The air supplies to the ARVs are from two trains from the plant safety grade Auxiliary Control Air System (ACAS). ACAS train A supplies air to ARVs for steam generators 1 and 3 and train B supplies air to ARVs for steam generators 2 and 4. The ARVs receive the necessary electrical power from the 125 volt vital battery system.

INSERT 2 of ARVs for steam generators 1 and 4. Air cylinders connected at control stations outside containment provide an alternate means of operation of the ARVs for steam generators 2 and 3.

INSERT 3 The ARVs, since their set pressure is slightly lower than the safety valves, prevent excessive lifting of the safety valves. Only two ARVs are required for plant cool down following any credible event.

INSERT 4 In Reference 3 (SGTR), the ARVs are assumed to be available following a steam generator tube rupture accompanied by a loss of offsite power. The ARVs allow the operator to establish sufficient subcooling in the RCS so that the primary system will remain subcooled after the RCS pressure is decreased to stop primary to secondary break flow into the ruptured steam generator. Four ARVs are required to be OPERABLE to allow operators to initiate the RCS cooldown, following a steam generator tube rupture, using the ARVs on the intact steam generators. This cooldown supports the termination of break flow within the required time specified in the accident analysis to prevent steam generator overfill.

2 4 2 2 ADVs B 3.7.4 Westinghouse STS B 3.7.4-2 Rev. 4.0 1 ARVs 2Revision XXXSEQUOYAH UNIT 1 BASES APPLICABLE SAFETY ANALYSES (continued) operator is also required to perform a limited cooldown to establish adequate subcooling as a necessary step to terminate the primary to secondary break flow into the ruptured steam generator.

The time required to terminate the primary to secondary break flow for an SGTR is more critical than the time required to cool down to RHR conditions for this event and also for other accidents. Thus, the SGTR is the limiting event for the ADVs. The number of ADVs required to be OPERABLE to satisfy the SGTR accident analysis requirements depends upon the number of unit loops and consideration of any single failure assumptions regarding the failure of one ADV to open on demand.

The ADVs are equipped with block valves in the event an ADV spuriously fails to open or fails to close during use.

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

LCO [Three] ADV lines are required to be OPERABLE. One ADV line is required from each of

[three] steam generators to ensure that at least one ADV line is available to conduct a unit cooldown following an SGTR, in which one steam generator becomes unavailable

, accompanied by a single, active failure of a second ADV line on an unaffected steam generator. The block valves must be OPERABLE to isolate a failed open ADV line. A closed block valve does not render it or its ADV line inoperable if operator action time to open the blo ck valve is supported in the accident analysis. Failure to meet the LCO can result in the inability to cool the unit to RHR entry conditions following an event in which the condenser is unavailable for use with the Steam Bypass System. An ADV is considered OPERABLE when it is capable of providing controlled relief of the main steam flow and capable of fully opening and closing on demand. APPLICABILITY In MODES 1, 2, and 3, and in MODE 4, when a steam generator is being relied upon for heat removal, the ADVs are required to be OPERABLE. In MODE 5 or 6, an SGTR is not a credible event.

ACTIONS A.1 With one required ADV line inoperable, action must be taken to restore OPERABLE status within 7 days. The 7 day Completion Time allows for the redundant capability afforded by the remaining OPERABLE ADV lines, a nonsafety grade backup in the Steam Bypass System, and MSSVs. Four ARV Dumpfour 1 3 1 2 1 1 1 ARVs ARV ARV ARV ARVs 1INSERT 6 three s are 6to establish sufficient subcoolin g in the RCS from the main control roomINSERT 5 4 5 5 ARVs 1 1 B 3.7.4 Insert Page B 3.7.4-2 INSERT 5 cooldown the RCS to establish sufficient subcooling and prevent steam generator overfill following the steam generator rupture when INSERT 6 With one or more ARV lines inoperable due to one train of ACAS nonfunctional, action must be taken to restore the ACAS train to functional status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable to repair the nonfunctional ACAS train, based on the availability of the remaining OPERABLE ARV lines, the alternate means to control the inoperable ARVs and the low probability of an event occurring during the time ACAS train is nonfunctional. Alternate means of operation include valve reach rod handwheels and backup air bottles at the control stations outside containment.

6 2 ADVs B 3.7.4 Westinghouse STS B 3.7.4-3 Rev. 4.0 1 ARVs 2Revision XXXSEQUOYAH UNIT 1 BASES ACTIONS (continued)

B.1 With two or more ADV lines inoperable, action must be taken to restore all but one ADV line to OPERABLE status. Since the block valve can be closed to isolate an ADV, some repairs may be possible with the unit at power. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable to repair inoperable ADV lines, based on the availability of the Steam Bypass System and MSSVs, and the low probability of an event occurring during this period that would require the ADV lines. C.1 and C.2 If the ADV lines cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4, without reliance upon steam generator for heat removal, within

[24] hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.4.1 REQUIREMENTS To perform a controlled cooldown of the RCS, the ADVs must be able to be opened either remotely or locally and throttled through their full range. This SR ensures that the ADVs are tested through a full control cycle at least once per fuel cycle. Performance of inservice testing or use of an ADV during a unit cooldown may satisfy this requirement.

[ Operati ng experience has shown that these components usually pass the Surveillance when performed at the [18]

month Frequency. The Frequency is acceptable from a reliability standpoint.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. -----------------------------------REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] ARV 1 1 1 7 8 2 3 Dump ARV ARVs ARV ARVs one s 6 2for reasons other than Condition AInservice Testing 7 ARV ADVs B 3.7.4 Westinghouse STS B 3.7.4-4 Rev. 4.0 1 ARVsRevision XXX 2SEQUOYAH UNIT 1 BASES

SURVEILLANCE REQUIREMENTS (continued)

[ SR 3.7.4.2 The function of the block valve is to isolate a failed open ADV. Cycling the block valve both closed and open demonstrates its capability to perform this function. Performance of inservice testing or use of the block valve during unit cooldown may satisfy this requirement.

[ Operating experience has shown that these components usually pass the Surveillance when performed at the [18]

month Frequency. The Frequency is acceptable from a reliability standpoint.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. -----------------------------------REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] ]

REFERENCES 1. FSAR, Section

[10.3]. U 8 2 32. UFSAR, Chapter 15

3. UFSAR, Section 15.4.3 2 6 ADVs B 3.7.4 Westinghouse STS B 3.7.4-1 Rev. 4.0 1 ARVs 2Revision XXXSEQUOYAH UNIT 2 B 3.7 PLANT SYSTEMS

B 3.7.4 Atmospheric Dump Valves (ADVs)

BASES BACKGROUND The ADVs provide a method for cooling the unit to residual heat removal (RHR) entry conditions should the preferred heat sink via the Steam

Bypass System to the condenser not be available, as discussed in the FSAR, Section

[10.3] (Ref. 1). This is done in conjunction with the Auxiliary Feedwater System providing cooling water from the condensate storage tank (CST). The ADVs may also be required to meet the design cooldown rate during a normal cooldown when steam pressure drops too low for maintenance of a vacuum in the condenser to permit use of the Steam Dump System.

One ADV line for each of the

[four] steam generators is provided. Each ADV line consists of one ADV and an associated block valve.

The ADVs are provided with upstream block valves to permit their being tested at power, and to provide an alternate means of isolation. The ADVs are equipped with pneumatic controllers to permit control of the cooldown rate.

The ADVs are usually provided with a pressurized gas supply of bottled nitrogen that, on a loss of pressure in the normal instrument air supply, automatically supplies nitrogen to operate the ADVs. The nitrogen supply is sized to provide the sufficient pressurized gas to operate the ADVs for the time required for Reactor Coolant System cooldown to RHR entry conditions.

A description of the ADVs is found in Reference 1. The ADVs are OPERABLE with only a DC power source available. In addition, handwheels are provided for local manual operation.

APPLICABLE The design basis of the ADVs is established by the capability to cool the SAFETY unit to RHR entry conditions. The design rate of [75

]°F per hour is ANALYSES applicable for two steam generators, each with one ADV. This rate is adequate to cool the unit to RHR entry conditions with only one steam generator and one ADV, utilizing the cooling water supply available in the CST. In the accident analysis presented in Reference 1 , the ADVs are assumed to be used by the operator to cool down the unit to RHR entry conditions for accidents accompanied by a loss of offsite power.

Prior to operator actions to cool down the unit, the ADVs and main steam safety valves (MSSVs) are assumed to operat e automatically to relieve steam and maintain the steam generator pressure below the design value. For the recovery from a steam generator tube rupture (SGTR) event, the 1 Relief ARVs U 1 2 3 1 3 1 1 2 1 4 2 2 ARVs Dump ARVs ARV ARV ARVs ARVsand plant safety grade air supply INSERT 2 INSERT 1 INSERT 3 2 2 ARVs 4INSERT 4 ARVs B 3.7.4 Insert Page B 3.7.4-1 INSERT 1 The air supplies to the ARVs are from two trains from the plant safety grade Auxiliary Control Air System (ACAS). ACAS train A supplies air to ARVs for steam generators 1 and 3 and train B supplies air to ARVs for steam generators 2 and 4. The ARVs receive the necessary electrical power from the 125 volt vital battery system.

INSERT 2

of ARVs for steam generators 1 and 4. Air cylinders connected at control stations outside containment provide an alternate means of operation of the ARVs for steam generators 2 and 3.

INSERT 3

The ARVs, since their set pressure is slightly lower than the safety valves, prevent excessive lifting of the safety valves. Only two ARVs are required for plant cool down following any credible event.

INSERT 4 In Reference 3 (SGTR), the ARVs are assumed to be available following a steam generator tube rupture accompanied by a loss of offsite power. The ARVs allow the operator to establish sufficient subcooling in the RCS so that the primary system will remain subcooled after the RCS pressure is decreased to stop primary to secondary break flow into the ruptured steam generator. Four ARVs are required to be OPERABLE to allow operators to initiate the RCS cooldown, following a steam generator tube rupture, using the ARVs on the intact steam generators. This cooldown supports the termination of break flow within the required time specified in the accident analysis to prevent steam generator overfill.

2 4 2 2 ADVs B 3.7.4 Westinghouse STS B 3.7.4-2 Rev. 4.0 1 ARVs 2Revision XXXSEQUOYAH UNIT 2 BASES

APPLICABLE SAFETY ANALYSES (continued)

operator is also required to perform a limited cooldown to establish adequate subcooling as a necessary step to terminate the primary to secondary break flow into the ruptured steam generator.

The time required to terminate the primary to secondary break flow for an SGTR is

more critical than the time required to cool down to RHR conditions for this event and also for other accidents. Thus, the SGTR is the limiting event for the ADVs. The number of ADVs required to be OPERABLE to satisfy the SGTR accident analysis requirements depends upon the number of unit loops and consideration of any single failure assumptions regarding the failure of one ADV to open on demand.

The ADVs are equipped with block valves in the event an ADV spuriously fails to open or fails to close during use.

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

LCO [Three] ADV lines are required to be OPERABLE. One ADV line is required from each of

[three] steam generators to ensure that at least one ADV line is available to conduct a unit cooldown following an SGTR, in which one steam generator becomes unavailable

, accompanied by a single, active failure of a second ADV line on an unaffected steam generator. The block valves must be OPERABLE to isolate a failed open ADV line. A closed block valve does not render it or its ADV line inoperable if operator action time to open the blo ck valve is supported in the accident analysis.

Failure to meet the LCO can result in the inability to cool the unit to RHR entry conditions following an event in which the condenser is unavailable for use with the Steam Bypass System.

An ADV is considered OPERABLE when it is capable of providing controlled relief of the main steam flow and capable of fully opening and

closing on demand.

APPLICABILITY In MODES 1, 2, and 3, and in MODE 4, when a steam generator is being relied upon for heat removal, the ADVs are required to be OPERABLE.

In MODE 5 or 6, an SGTR is not a credible event.

ACTIONS A.1 With one required ADV line inoperable, action must be taken to restore OPERABLE status within 7 days. The 7 day Completion Time allows for the redundant capability afforded by the remaining OPERABLE ADV lines, a nonsafety grade backup in the Steam Bypass System, and MSSVs. Four ARV Dumpfour 1 3 1 2 1 1 1 ARVs ARV ARV ARV ARVs 1INSERT 6 three s are 6to establish sufficient subcoolin g in the RCS from the main control roomINSERT 5 4 5 5 ARVs 1 1 B 3.7.4 Insert Page B 3.7.4-2 INSERT 5

cooldown the RCS to establish sufficient subcooling and prevent steam generator overfill following the steam generator rupture when

INSERT 6 With one or more ARV lines inoperable due to one train of ACAS nonfunctional, action must be taken to restore the ACAS train to functional status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable to repair the nonfunctional ACAS train, based on the availability of the remaining OPERABLE ARV lines, the alternate means to control the inoperable ARVs and the low probability of an event occurring during the time ACAS train is nonfunctional. Alternate means of operation include valve reach rod handwheels and backup air bottles at the control stations outside containment.

6 2 ADVs B 3.7.4 Westinghouse STS B 3.7.4-3 Rev. 4.0 1 ARVs 2Revision XXXSEQUOYAH UNIT 2 BASES ACTIONS (continued)

B.1 With two or more ADV lines inoperable, action must be taken to restore all but one ADV line to OPERABLE status. Since the block valve can be closed to isolate an ADV, some repairs may be possible with the unit at power. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable to repair inoperable ADV lines, based on the availability of the Steam Bypass System and MSSVs, and the low probability of an event occurring during this period that would require the ADV lines. C.1 and C.2 If the ADV lines cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4, without reliance upon steam generator for heat removal, within

[24] hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.4.1 REQUIREMENTS To perform a controlled cooldown of the RCS, the ADVs must be able to be opened either remotely or locally and throttled through their full range. This SR ensures that the ADVs are tested through a full control cycle at least once per fuel cycle. Performance of inservice testing or use of an ADV during a unit cooldown may satisfy this requirement.

[ Operati ng experience has shown that these components usually pass the Surveillance when performed at the [18]

month Frequency. The Frequency is acceptable from a reliability standpoint.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. -----------------------------------REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] ARV 1 1 1 7 8 2 3 Dump ARV ARVs ARV ARVs one s 6 2for reasons other than Condition AInservice Testing 7 ARV ADVs B 3.7.4 Westinghouse STS B 3.7.4-4 Rev. 4.0 1 ARVsRevision XXX 2SEQUOYAH UNIT 2 BASES SURVEILLANCE REQUIREMENTS (continued)

[ SR 3.7.4.2 The function of the block valve is to isolate a failed open ADV. Cycling the block valve both closed and open demonstrates its capability to perform this function. Performance of inservice testing or use of the block valve during unit cooldown may satisfy this requirement.

[ Operating experience has shown that these components usually pass the Surveillance when performed at the [18]

month Frequency. The Frequency is acceptable from a reliability standpoint.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. -----------------------------------REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] ] REFERENCES 1.FSAR, Section

[10.3].U 8 2 32. UFSAR, Chapter 15 3. UFSAR, Section 15.4.3 2 6 JUSTIFICATION FOR DEVIATIONS ITS 3.7.4 BASES, ATMOSPHERIC RELIEF VALVES (ARVs) Sequoyah Unit 1 and Unit 2 Page 1 of 1 1.ISTS B 3.7.4, "Atmospheric Dump Valves" title has been cha nged to "Atmospheric Relief Valves" to reflect t he name used at Sequoyah Nuclear Plant. Additionally, the acronyms "ADVs" and "ADV" ha ve been chang ed to "ARVs" and "ARV", respectively.

2.Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis descriptio n.3.The ISTS contains bracketed information and/or values that ar e generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect th e current licensing basis.

4.Changes are made to be consistent with SQN UFSAR accident analysis describing the use of th e ARVs in the mitigation of the steam generator tube rupture event concurrent with a loss of offsite power. The accident analysis assumes t he steam generator ARVs associa ted with the unaffected steam generators are available to cool down the RCS and terminate the primary to secondary leak.

5.SQN Unit 1 and 2 Steam Generator Tube Rupture accident analysis do es not assume a single failure.

6.Changes are made to be consistent with changes made to the Specifica tion.7.ISTS SR 3.7.4.1 provides two options for controlling the Freq uency of the Surveillance Requirement. SQN is proposing to control the ARV Surveillance Frequency under the Inservice Testing Program. The ARVs are ASME Section X I Code Class valves at SQN and as such are tested under the SQN ASME Section XIInservice Testing Program.

8.The Reviewer's Note has been deleted. Thi s information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.4, ATMOSPHERIC RELIEF VALVES (ARVs)

Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 5 ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS A01 ITS 3.7.5 PLANT SYSTEMS AUXILIARY FEEDWATER (AFW) SYSTEM LIMITING CONDITION FOR OPERATION

3.7.1.2 Three auxiliary feedwater trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTION: a. With one AFW train inoperable in MODE 1, 2, or 3, restore the inoperable AFW train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. With two AFW trains inoperable in MODE 1, 2, or 3, be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With three AFW trains inoperable in MODE 1, 2, or 3, immediately initiate corrective action to restore at least one AFW train to OPERABLE status.

- d. With the required AFW train inoperable in MODE 4, immediately initiate action to restore the required AFW train to OPERABLE status.

e. LCO 3.0.4.b is not applicable.

SURVEILLANCE REQUIREMENTS 4.7.1.2.1 At least once per 31 days, verify each AFW manual, power operated, and automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4. ** LCO 3.0.3 and all other LCO ACTIONS requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

April 11, 2005 SEQUOYAH - UNIT 1 3/4 7-5 Amendment No. 12, 115, 206, 301 Page 1 of 4 LCO 3.7.5 Applicabilit y SR 3.7.5.1 Add proposed ACTION ALCO 3.7.5 Note ACTION Note Add proposed ACTIONS C ACTION D ACTION E Required Action E.1 Note ACTION F In accordance with the Surveillance Frequency Control Program Add proposed SR 3.7.5.1 Note L01 L01 L03 LA01 12 L02 ACTION D ACTION B ITS A01 ITS 3.7.5 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.7.1.2.2 At least once per 92 days, verify the developed head of each AFW pump at the flow test point is greater than or equal to the required developed head.

4.7.1.2.3 Once every 18 months, verify each AFW automatic valve that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

4.7.1.2.4 Once every 18 months, verify each AFW pump starts automatically on an actual or simulated actuation signal.

Not required to be completed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after steam supply pressure is greater than or equal to 842 psig.

- Not applicable in Mode 4 when steam generators are relied upon for heat removal.

- - Not required to be completed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after steam supply pressure is greater than or equal to 842 psig. Not applicable in MODE 4 when steam generator(s) are relied upon for heat removal.

August 2, 1995 SEQUOYAH - UNIT 1 3/4 7-6 Amendment No. 12, 77, 114, 206 In accordance with the Inservice Testing Program SR 3.7.5.2 SR 3.7.5.3 In accordance with the Surveillance Frequency Control ProgramSR 3.7.5.4 SR 3.7.5.2 Note SR 3.7.5.4 Note 1 SR 3.7.5.4 Note 2 SR 3.7.5.3 Note 2 Page 2 of 4 LA02 LA01 LA01 L04Add proposed SR 3.7.5.3 Note 1Add proposed SR 3.7.5.4 Note 3 L04In accordance with the Surveillance Frequency Control Program ITS A01 ITS 3.7.5 PLANT SYSTEMS AUXILIARY FEEDWATER (AFW) SYSTEM LIMITING CONDITION FOR OPERATION

3.7.1.2 Three auxiliary feedwater trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTION: a. With one AFW train inoperable in MODE 1, 2, or 3, restore the inoperable AFW train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. With two AFW trains inoperable in MODE 1, 2, or 3, be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With three AFW trains inoperable in MODE 1, 2, or 3, immediately initiate corrective action to restore at least one AFW train to OPERABLE status.

- d. With the required AFW train inoperable in MODE 4, immediately initiate action to restore the required AFW train to OPERABLE status.

e. LCO 3.0.4.b is not applicable.

SURVEILLANCE REQUIREMENTS 4.7.1.2.1 At least once per 31 days, verify each AFW manual, power operated, and automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4. ** LCO 3.0.3 and all other LCO ACTIONS requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

April 11, 2005 SEQUOYAH - UNIT 2 3/4 7-5 Amendment No. 2, 105, 196, 290 Page 3 of 4 LCO 3.7.5 Applicabilit y SR 3.7.5.1 Add proposed Action A LCO 3.7.5 Note ACTION Note 12 ACTION D ACTION E Required Action E.1 Note ACTION F In accordance with the Surveillance Frequency Control Program Add proposed SR 3.7.5.1 Note L01 L02 L03 LA01 ACTION B ACTION D L01Add proposed ACTIONS C ITS A01 ITS 3.7.5 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.7.1.2.2 At least once per 92 days, verify the developed head of each AFW pump at the flow test point is greater than or equal to the required developed head.

4.7.1.2.3 Once every 18 months, verify each AFW automatic valve that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

4.7.1.2.4 Once every 18 months, verify each AFW pump starts automatically on an actual or simulated actuation signal.

Not required to be completed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after steam supply pressure is greater than or equal to 842 psig.

- Not applicable in Mode 4 when steam generators are relied upon for heat removal.

- - Not required to be completed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after steam supply pressure is greater than or equal to 842 psig. Not applicable in MODE 4 when steam generator(s) are relied upon for heat removal.

August 2, 1995 SEQUOYAH - UNIT 2 3/4 7-6 Amendment No. 68, 104, 196 In accordance with the Inservice Testing Program SR 3.7.5.2 In accordance with the Surveillance Frequency Control ProgramSR 3.7.5.3 SR 3.7.5.4 SR 3.7.5.2 Note SR 3.7.5.4 Note 1 SR 3.7.5.4 Note 2 SR 3.7.5.3 Note 2 Page 4 of 4 LA02 LA01 LA01 L04In accordance with the Surveillance Frequency Control ProgramAdd proposed SR 3.7.5.3 Note 1Add proposed SR 3.7.5.4 Note 3 L04 DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM Sequoyah Unit 1 and Unit 2 Page 1 of 5 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this

submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None

RELOCATED SPECIFICATIONS

None REMOVED DETAIL CHANGES

LA01 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program). CTS 4.7.1.2.1 requires verification that each AFW manual, power operated, and automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position at least once per 31 days.

CTS 4.7.1.2.3 requires verification that each AFW automatic valve that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal once every 18 months. CTS 4.7.1.2.4 requires verification that each AFW pump starts automatically on an actual or simulated actuation signal once every 18 months. ITS SR 3.7.5.1, SR 3.7.5.3, and SR 3.7.5.4 require similar Surveillances but specify the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for these SRs and associated Bases to the Surveillance Frequency Control Program.

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM Sequoyah Unit 1 and Unit 2 Page 2 of 5 Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

LA02 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program). CTS 4.7.1.2.2 states, "At least once per 92 days, verify the developed head of each AFW pump at the flow test point is greater than or equal to the required developed head." ITS SR 3.7.5.2 states, "Verify the developed head of each AFW pump at the flow test point is greater than or equal to the required developed head," with a Frequency stated as, "In accordance with the Inservice Testing Program." This changes the CTS by relocating the Surveillance Frequency from the technical specification to the Inservice Testing Program. This change will result in the Technical Specification surveillance test referencing the IST for performance of pump testing. This will eliminate any potential ambiguity associated with AFW pump testing, because of ASME changes, and results in consistent presentation of pump testing throughout the Technical Specifications. This frequency for testing AFW pumps is consistent with the ASME Code requirements and consistent with other similar pump testing frequencies important to safety. Such inservice tests confirm component operability, trend performance, and detect incipient failures by indicating abnormal performance. This change is acceptable because these types of details are adequately controlled in the IST Program, which is controlled by 10 CFR 50.55a, and the Frequency for the verification has not changed (IST Program frequency states in part, "- quarterly (at least once every 92 days)."

Therefore, this type of information is not necessary to be in the Technical Specifications in order to provide adequate protection of the public health and safety. This change is designated as a less restrictive removal of detail change because details for meeting Technical Specification requirements are being removed from the Technical Specifications. LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.7.1.2.a states that with one AFW train inoperable in MODE 1, 2, or 3, restore the inoperable AFW train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . CTS 3.7.1.2.b states, "With two AFW trains inoperable in MODE 1, 2, or 3, be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ." ITS 3.7.5 ACTION B requires the restoration of one inoperable AFW train in MODES 1, 2, or 3 in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when the AFW train is inoperable for reasons other than Condition A. ITS LCO 3.7.3 ACTION A states that with the turbine driven AFW train inoperable because of one inoperable steam supply or, if MODE 2 has not been entered following refueling, one turbine driven AFW pump inoperable in MODE 3 following refueling, to restore affected equipment to OPERABLE status within 7 DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM Sequoyah Unit 1 and Unit 2 Page 3 of 5 days. ITS LCO 3.7.5 ACTION C states that with the turbine driven AFW train inoperable due to one inoperable steam supply and one motor driven AFW train inoperable either 1) restore the steam supply to the turbine driven train to OPERABLE status or 2) restore the motor driven AFW train to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . ITS 3.7.5 ACTION D requires a plant shutdown when two AFW trains are inoperable in MODES 1, 2, or 3 for reasons other than Condition C. ITS LCO 3.7.5, ACTION D requires a plant shutdown when the Required Actions and associated Completion Times of Conditions A, B, or C are not met.

This changes the CTS by allowing a longer Completion Time if the inoperable AFW train is the turbine driven AFW train and the inoperability is due to an inoperable steam supply or the plant condition is following the refueling prior to entering MODE 2.

The purpose of CTS 3.7.1.2, AFW system, is to provide redundant, independent, and diverse means of supplying feedwater to the SGs for cooling the RCS under emergency conditions. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features, the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. For ACTION C, one steam supply for the turbine driven AFW pump remains OPERABLE, which will provide the required steam flow for the pump to produce the design flow rate and therefore, the capability to mitigate analyzed accidents is preserved (i.e., the pump remains capable of performing its safety function). For ACTION A, an inoperable turbine driven AFW pump in MODE 3 following a refueling is acceptable because the remaining motor driven AFW trains remain capable of supplying additional redundant trains of AFW and the decay heat in the Reactor Coolant System is low. The probability of an event occurring during the extended outage time that would require the inoperable steam supply or turbine driven AFW pump to function is low. The ACTION provides adequate assurance that the AFW System will continue to meet the assumptions stated in the safety analyses for the AFW system to mitigate postulated accidents. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category 3 - Relaxation of Completion Time) CTS 3.7.1.2.b requires that with two AFW trains inoperable, the unit is to be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ITS 3.7.5 ACTION D requires the unit to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . This changes the CTS by allowing 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months instead of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to be in MODE 4.

This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features, the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. The allowance to place the plant in MODE 4 in 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months allows the unit to reach the DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM Sequoyah Unit 1 and Unit 2 Page 4 of 5 required conditions from full power conditions in an orderly manner and without challenging plant systems. The period of 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months to require the plant to move from 100% power to MODE 4 is consistent with CTS 3.7.1.2.a, where two AFW pumps are available for cooldown instead of one, and ITS requirements when the heat removal capability of the unit is degraded. This change is designated as less restrictive because additional time is allowed to exit the Modes of Applicability than was allowed in CTS.

L03 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.7.1.2.1 states in part, verify each AFW manual, power operated, and automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position. ITS SR 3.7.5.1 states in part, "Verify each AFW manual, power operated, and automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position. Additionally, ITS SR 3.7.5.1 contains a Note that states, "AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation." This changes the CTS by allowing the AFW train to be considered OPERABLE during alignment and operation for steam generator level control as long as it is capable of being manually realigned to the AFW mode of operation.

The purpose of CTS 4.7.1.2.1 is to ensure the AFW System valves can operate automatically to perform their safety function. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This change allows these automatic features to not be OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation. This exception allows the system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable. Since AFW may be used during startup, shutdown, and hot standby operations for steam generator level control, and these manual operations are an accepted function of the AFW System, OPERABILITY (i.e., the intended safety function) continues to be maintained.

This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L04 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria). CTS 4.7.1.2.3 requires verification that each AFW automatic valve that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal once every 18 months. CTS 4.7.1.2.4 requires verification that each AFW pump starts automatically on an actual or simulated actuation signal once every 18 months. ITS SR 3.7.5 3 and ITS SR 3.7.5.4 require the same verifications for the AFW valves and pumps, respectively with a Note that states, "AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation." This changes the CTS by allowing the AFW trains to be considered OPERABLE during alignment and operation for steam generator level control, if it is capable DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM Sequoyah Unit 1 and Unit 2 Page 5 of 5 of being manually realigned to the AFW mode of operation in any Mode the LCO is applicable.

The purpose of CTS 4.7.1.2.3 and CTS 4.7.1.2.4 is to ensure the AFW System

valves and pumps, respectively, can operate automatically to perform their safety function. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This change allows these automatic features to not be OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation. This exception allows the system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable. Since AFW may be used during startup, shutdown, and hot standby operations for steam generator level control, and these manual operations are an accepted function of the AFW System, OPERABILITY (i.e., the intended safety function) continues to be maintained. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

AFW System 3.7.5 Westinghouse STS 3.7.5-1 Rev. 4.0 CTS Amendment XXXSEQUOYAH UNIT 1 33.7 PLANT SYSTEMS

3.7.5 Auxiliary Feedwater (AFW) System

LCO 3.7.5

[Three] AFW trains shall be OPERABLE.

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

[ Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

] --------------------------------------------------------------------------------------------------

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS

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

LCO 3.0.4.b is not applicable

[when entering MODE 1.] -------------------------------------------------------------------------------------------------------------------------------

CONDITION REQUIRED ACTION COMPLETION TIME

A. [ Turbine driven AFW train inoperable due to one inoperable steam

supply.

OR ------------NOTE------------ Only applicable if MODE 2 has not been entered following refueling. ---------------------------------

One turbine driven AFW pump inoperable in

MODE 3 following refueling.

A.1 Restore affected equipment to OPERABLE status.

7 days ] 3.7.1.2 Applicabilit y 3.7.1.2

Note ACTION e 1 1 2 1 DOC L01 AFW System 3.7.5 Westinghouse STS 3.7.5-2 Rev. 4.0 CTS Amendment XXXSEQUOYAH UNIT 1 3ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFW train inoperable in MODE 1, 2, or 3 [for reasons other than Condition A

].

B.1 Restore AFW train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

C. Turbine driven AFW train inoperable due to one inoperable steam

supply.

AND One motor driven AFW train inoperable.

C.1 Restore the steam supply to the turbine driven train to OPERABLE status.

OR C.2 Restore the motor driven AFW train to OPERABLE status.

[24 or 48] hours

[24 or 48] hours D. Required Action and associated Completion

Time of Condition A

[, B, or C] not met.

[ OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other

than Condition C.

]

D.1 Be in MODE 3.

AND D.2 [ Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

[18] hours ] E. [ Three] AFW trains inoperable in MODE 1, 2, or 3. E.1 --------------NOTE-------------- LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status. -------------------------------------

Initiate action to restore one AFW train to OPERABLE status.

Immediately

] ACTION a ACTION b ACTION c 4 1 1 1 DOC L01 DOC L01 1 AFW System 3.7.5 Westinghouse STS 3.7.5-3 Rev. 4.0 CTS Amendment XXXSEQUOYAH UNIT 1 3ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required AFW train inoperable in MODE 4.

F.1 Initiate action to restore AFW train to OPERABLE status.

Immediately

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.7.5.1 -------------------------------NOTE------------------------------

[ AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

] ---------------------------------------------------------------------

Verify each AFW manual, power operated, and automatic valve in each water flow path, [and in both steam supply flow paths to the steam turbine driven

pump,] that is not locked, sealed, or otherwise secured in position, is in the correct position.

[ 31 days OR In accordance

with the Surveillance

Frequency

Control Program

]

SR 3.7.5.2 -------------------------------NOTE------------------------------

[ Not required to be performed for the turbine driven AFW pump until

[24 hours] after [1000] psig in the steam generator.

] ---------------------------------------------------------------------

Verify the developed head of each AFW pump at the flow test point is greater than or equal to the required developed head.

In accordance

with the Inservice Testing Program 8424.7.1.2.1 4.7.1.2.2 ACTION d 1 5 1 DOC L04 4.7.1.2.4 Note*

AFW System 3.7.5 Westinghouse STS 3.7.5-4 Rev. 4.0 CTS Amendment XXXSEQUOYAH UNIT 1 3SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.3 -------------------------------NOTE------------------------------

[ AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

] ---------------------------------------------------------------------

Verify each AFW automatic valve that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

[ [18] months OR In accordance

with the Surveillance

Frequency Control Program

] SR 3.7.5.4 ------------------------------NOTES-----------------------------

1. [ Not required to be performed for the turbine driven AFW pump until

[24 hours] after [1000] psig in the steam generator.

]

2. [ AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of

operation.

] ---------------------------------------------------------------------

Verify each AFW pump starts automatically on an actual or simulated actuation signal.

[ [18] months OR In accordance with the Surveillance

Frequency

Control Program

] 4.7.1.2.3 4.7.1.2.4 842 5 5 1 1 DOC L04 4.7.1.2.4 Note ***

DOC L04 4.7.1.2.4 Note ***

1. S 62. Only required to be met in MODES 1, 2, and 3. 3. Only required to be met in MODES 1, 2, and 3.

6 64.7.1.2.3 Note **

AFW System 3.7.5 Westinghouse STS 3.7.5-5 Rev. 4.0 CTS Amendment XXXSEQUOYAH UNIT 1 3SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.5 [ Verify proper alignment of the required AFW flow paths by verifying flow from the condensate storage tank to each steam generator.

Prior to entering MODE 2 whenever unit has been in MODE 5, MODE 6, or defueled for a cumulative period of > 30 days ] 7 AFW System 3.7.5 Westinghouse STS 3.7.5-1 Rev. 4.0 CTS Amendment XXXSEQUOYAH UNIT 2 33.7 PLANT SYSTEMS

3.7.5 Auxiliary Feedwater (AFW) System

LCO 3.7.5

[Three] AFW trains shall be OPERABLE.

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

[ Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

] --------------------------------------------------------------------------------------------------

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS

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

LCO 3.0.4.b is not applicable

[when entering MODE 1.] -------------------------------------------------------------------------------------------------------------------------------

CONDITION REQUIRED ACTION COMPLETION TIME

A. [ Turbine driven AFW train inoperable due to one inoperable steam

supply.

OR ------------NOTE------------ Only applicable if MODE 2 has not been entered following refueling. ---------------------------------

One turbine driven AFW pump inoperable in

MODE 3 following refueling.

A.1 Restore affected equipment to OPERABLE status.

7 days ] 3.7.1.2 Applicabilit y 3.7.1.2

Note ACTION e 1 1 2 1 DOC L01 AFW System 3.7.5 Westinghouse STS 3.7.5-2 Rev. 4.0 CTS Amendment XXXSEQUOYAH UNIT 2 3ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFW train inoperable in MODE 1, 2, or 3 [for reasons other than Condition A

].

B.1 Restore AFW train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

C. Turbine driven AFW train inoperable due to one inoperable steam

supply.

AND One motor driven AFW train inoperable.

C.1 Restore the steam supply to the turbine driven train to OPERABLE status.

OR C.2 Restore the motor driven AFW train to OPERABLE status.

[24 or 48] hours

[24 or 48] hours D. Required Action and associated Completion

Time of Condition A

[, B, or C] not met.

[ OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other

than Condition C.

]

D.1 Be in MODE 3.

AND D.2 [ Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

[18] hours ] E. [ Three] AFW trains inoperable in MODE 1, 2, or 3. E.1 --------------NOTE-------------- LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status. -------------------------------------

Initiate action to restore one AFW train to OPERABLE status.

Immediately

] ACTION a ACTION b ACTION c 4 1 1 1 DOC L01 DOC L01 1 AFW System 3.7.5 Westinghouse STS 3.7.5-3 Rev. 4.0 CTS Amendment XXXSEQUOYAH UNIT 2 3ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required AFW train inoperable in MODE 4.

F.1 Initiate action to restore AFW train to OPERABLE status.

Immediately

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.7.5.1 -------------------------------NOTE------------------------------

[ AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

] ---------------------------------------------------------------------

Verify each AFW manual, power operated, and automatic valve in each water flow path, [and in both steam supply flow paths to the steam turbine driven

pump,] that is not locked, sealed, or otherwise secured in position, is in the correct position.

[ 31 days OR In accordance

with the Surveillance

Frequency

Control Program

]

SR 3.7.5.2 -------------------------------NOTE------------------------------

[ Not required to be performed for the turbine driven AFW pump until

[24 hours] after [1000] psig in the steam generator.

] ---------------------------------------------------------------------

Verify the developed head of each AFW pump at the flow test point is greater than or equal to the required developed head.

In accordance

with the Inservice Testing Program 8424.7.1.2.1 4.7.1.2.2 ACTION d 1 5 1 DOC L04 4.7.1.2.4 Note*

AFW System 3.7.5 Westinghouse STS 3.7.5-4 Rev. 4.0 CTS Amendment XXXSEQUOYAH UNIT 2 3SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.3 -------------------------------NOTE------------------------------

[ AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

] ---------------------------------------------------------------------

Verify each AFW automatic valve that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

[ [18] months OR In accordance

with the Surveillance

Frequency Control Program

] SR 3.7.5.4 ------------------------------NOTES-----------------------------

1. [ Not required to be performed for the turbine driven AFW pump until

[24 hours] after [1000] psig in the steam generator.

]

2. [ AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of

operation.

] ---------------------------------------------------------------------

Verify each AFW pump starts automatically on an actual or simulated actuation signal.

[ [18] months OR In accordance with the Surveillance

Frequency

Control Program

] 4.7.1.2.3 4.7.1.2.4 842 5 5 1 1 DOC L04 4.7.1.2.4 Note ***

DOC L04 4.7.1.2.4 Note ***

1. S 62. Only required to be met in MODES 1, 2, and 3. 3. Only required to be met in MODES 1, 2, and 3.

6 64.7.1.2.3 Note **

AFW System 3.7.5 Westinghouse STS 3.7.5-5 Rev. 4.0 CTS Amendment XXXSEQUOYAH UNIT 2 3SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.5 [ Verify proper alignment of the required AFW flow paths by verifying flow from the condensate storage tank to each steam generator.

Prior to entering MODE 2 whenever unit has been in MODE 5, MODE 6, or defueled for a cumulative period of > 30 days ] 7 JUSTIFICATION FOR DEVIATIONS ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

2. ISTS bases for ISTS 3.7.5 contains a "Reviewers Note" that states in part, "If the plant does depend on AFW for startup, the Note should state, "LCO 3.0.4.b is not applicable."" Since Sequoyah Nuclear Plant (SQN) Unit 1 and Unit 2 depend on AFW for startup the bracketed information is deleted.

3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.

4. ISTS bases for ISTS 3.7.5 contains a "Reviewers Note" that states, "Licensees should adopt the appropriate Completion Time based on their plant design. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is applicable to plants that can no longer meet the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure and a Feedwater Line Break (FWLB) or Main Steam Line Break (MSLB) resulting in the loss of the remaining steam supply to the turbine driven AFW pump.

The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time is applicable to plants that can still meet the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting in the loss of the remaining steam supply to the turbine driven AFW pump." Based on this reviewers note SQN determined 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is the appropriate value.

5. ISTS SR 3.7.5.1, ISTS SR 3.7.5.3, and ISTS SR 3.7.5.4 (ITS SR 3.7.5.1, ITS SR 3.7.5.3, and ITS SR 3.7.5.4) provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.

6. ISTS LCO 3.7.5 Note states that only one AFW train is required to be OPERABLE in MODE 4. In addition, the Applicability states that the MODE 4 requirement is applicable only when the steam generator (SG) is relied upon for heat removal. The ISTS 3.7.5 Bases state that the purpose of the AFW train is only to remove decay heat from the SG in MODE 4. Thus, automatic operation of the AFW train is not required in MODE 4. Therefore, a Note has been added to ISTS SR 3.7.5.3 and SR 3.7.5.4 (Note 2 to SR 3.7.5.3 and Note 3 to SR 3.7.5.4) stating that the SRs are only required to be met in MODES 1, 2, and 3 (i.e., they are not required to be met in MODE 4). This is also consistent with the current licensing basis.

7. ISTS SR 3.7.5.5 Bases includes a Reviewers Note that states the SR is not required by those units that use AFW for normal startup and shutdown. Since SQN uses the AFW system during these conditions this SR has not been included.

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

AFW System B 3.7.5 Westinghouse STS B 3.7.5-1 Rev. 4.0 Revision XXXSEQUOYAH UNIT 1 1B 3.7 PLANT SYSTEMS

B 3.7.5 Auxiliary Feedwater (AFW) System

BASES BACKGROUND The AFW System automatically supplies feedwater to the steam generators to remove decay heat from the Reactor Coolant System upon the loss of normal feedwater supply.

The AFW pumps take suction through separate and independent suction lines from the condensate storage tank (CST) (LCO 3.7.6, "Condensate Storage Tank (CST)") and pump to the steam generator secondary side via separate and independent connections to the main feedwater (MFW) piping outside containment. The steam generators function as a heat sink for core decay heat. The heat load is dissipated by releasing steam to the atmosphere from the steam generators via the main steam safety valves (MSSVs) (LCO 3.7.1, "Main Steam Safety Valves (MSSVs)") or

atmospheric dump valves (LCO 3.7.4, "Atmospheric Dump Valves (ADVs)"). If the main condenser is available, steam may be released via the steam bypass valves and recirculated to the CST.

The AFW System consists of

[two] motor driven AFW pumps and one steam turbine driven pump configured into

[three] trains. Each motor driven pump provides

[100]% of AFW flow capacity, and the turbine driven pump provides

[200]% of the required capacity to the steam generators, as assumed in the accident analysis. The pumps are

equipped with independent recirculation lines to prevent pump operation against a closed system. Each moto r driven AFW pump is powered from an independent Class 1E power supply and feeds

[two] steam generators, although each pump has the capability to be realigned from the control room to feed other steam generators. The steam turbine driven AFW pump receives steam from two main steam lines upstream of the main steam isolation valves. Each of the steam feed lines will supply 100% of the requirements of the turbine driven AFW pump.

The AFW System is capable of supplying feedwater to the steam generators during normal unit startup, shutdown, and hot standby conditions.

The turbine driven AFW pump supplies a common header capable of feeding all steam generators with DC powered control valves actuated to the appropriate steam generator by the Engineered Safety Feature Actuation System (ESFAS). One pump at full flow is sufficient to remove decay heat and cool the unit to residual heat removal (RHR) entry conditions. Thus, the requirement for diversity in motive power sources for the AFW System is met.

1 1 2 2 1 1 1 relief ARVs Dump11/2 inch 1 INSERT 1INSERT 2 pneumatic open Relief 3.7.5 Insert Page B 3.7.5-1 INSERT 1 Except for the common miniflow line to and supply line from the condensate storage tanks and some shared support facilities such as the condensate storage tanks and parts of the Control Air System, the two reactor units have separate AFW Systems. The normal suction for both units AFW pumps is through a common header connected to two condensate storage tanks (CSTs) (LCO 3.7.6, "Condensate Storage Tank (CST)"). The pumps are grouped into unit specific systems with each systems' pumps aligned to their respective units steam generators secondary side via connections to the main feedwater piping between the main feedwater isolation check valve and the steam generator. The nonessential condensate supply is isolated from the essential portion of the AFW System by check valves. A low AFW pump suction pressure automatically actuates valves from ERCW on a two-out-of three signal to align the AFW pump suction to ERCW to ensure the AFW pumps have an adequate water supply.

INSERT 2 , except for the Feedwater line Break (FWLB) and Small Break Loss-of-Coolant accident (SBLOCA) 1 1 AFW System B 3.7.5 Westinghouse STS B 3.7.5-2 Rev. 4.0 Revision XXXSEQUOYAH UNIT 1 1BASES

BACKGROUND (continued)

The AFW System is designed to supply sufficient water to the steam generator(s) to remove decay heat with steam generator pressure at the setpoint of the MSSVs. Subsequently, the AFW System supplies sufficient water to cool the unit to RHR entry conditions, with steam released through the ADVs. The AFW System actuates automatically on steam generator water level low-low by the ESFAS (LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation"). The system also actuates on loss of offsite power, safety injection, and trip of all MFW pumps.

The AFW System is discussed in the FSAR, Section

[10.4.9] (Ref. 1).

APPLICABLE The AFW System mitigates the consequences of any event with loss of SAFETY normal feedwater.

ANALYSES The design basis of the AFW System is to supply water to the steam generator to remove decay heat and other residual heat by delivering at least the minimum required flow rate to the steam generators at pressures corresponding to the lowest steam generator safety valve set pressure plus 3%.

In addition, the AFW System must supply enough makeup water to replace steam generator secondary inventory lost as the unit cools to MODE 4 conditions. Sufficient AFW flow must also be available to account for flow losses such as pump recirculation and line breaks.

The limiting Design Basis Accidents (DBAs) and transients for the AFW System are as follows:

a. Feedwater Line Break (FWLB) and

b. Loss of MFW.

In addition, the minimum available AFW flow and system characteristics are serious considerations in the analysis of a small break loss of coolant accident (LOCA).

The AFW System design is such that it can perform its function following an FWLB between the MFW isolation valves and containment, combined with a loss of offsite power following turbine trip, and a single active failure of the steam turbine driven AFW pump. In such a case, the 7.2 1 2 U s 1 ARVs 1 INSERT 3 INSERT 4 1 3.7.5 Insert Page B 3.7.5-2 INSERT 3 initiation of Anticipated Transient Without Scram (ATWS) Mitigation Actuation Circuitry (AMSAC), trip of one MFW pump with turbine load above 76.6% Unit 1,

INSERT 4

The AFW System actuations on an AMSAC signal and on a MFW pump trip/power coincident signal are not required as part of this LCO.

1 1 AFW System B 3.7.5 Westinghouse STS B 3.7.5-3 Rev. 4.0 Revision XXXSEQUOYAH UNIT 1 1BASES

APPLICABLE SAFETY ANALYSES (continued)

ESFAS logic may not detect the affected steam generator if the backflow check valve to the affected MFW header worked properly. One motor driven AFW pump would deliver to the broken MFW header at the pump runout flow until the problem was detected, and flow terminated by the operator. Sufficient flow would be delivered to the intact steam generator by the redundant AFW pump.

The ESFAS automatically actuates the AFW turbine driven pump and associated power operated valves and controls when required to ensure an adequate feedwater supply to the steam generators during loss of

power. DC power operated valves are provided for each AFW line to control the AFW flow to each steam generator.

The AFW System satisfies the requirements of Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO This LCO provides assurance that the AFW System will perform its design safety function to mitigate the consequences of accidents that could result in overpressurization of the reactor coolant pressure

boundary.

[Three] independent AFW pumps in

[three] diverse trains are required to be OPERABLE to ensure the availability of RHR capability for all events accompanied by a loss of offsite power and a single failure. This is accomplished by powering two of the pumps from independent emergency buses. The third AFW pump is powered by a different means, a steam driven turbine supplied with steam from a source that is not isolated by closure of the MSIVs.

The AFW System is configured into

[three] trains. The AFW System is considered OPERABLE when the components and flow paths required to provide redundant AFW flow to the steam generators are OPERABLE.

This requires that the two motor driven AFW pumps be OPERABLE in

[two] diverse paths, each supplying AFW to separate steam generators. The turbine driven AFW pump is required to be OPERABLE with redundant steam supplies from each of

[two] main steam lines upstream of the MSIVs, and shall be capable of supplying AFW to any of the steam generators. The piping, valves, instrumentation, and controls in the required flow paths also are required to be OPERABLE.

The LCO is modified by a Note indicating that one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4. This is because of the reduced heat removal requirements and short period of time in MODE 4 during which the AFW is required and the insufficient steam available in MODE 4 to power the turbine driven AFW pump. 2 2 2 2 3 Air 1In such a case, one 1decay heat removal 1

AFW System B 3.7.5 Westinghouse STS B 3.7.5-4 Rev. 4.0 Revision XXXSEQUOYAH UNIT 1 1BASES

APPLICABILITY In MODES 1, 2, and 3, the AFW System is required to be OPERABLE in the event that it is called upon to function when the MFW is lost. In addition, the AFW System is required to supply enough makeup water to replace the steam generator secondary inventory, lost as the unit cools to MODE 4 conditions.

In MODE 4 the AFW System may be used for heat removal via the steam generators.

In MODE 5 or 6, the steam generators are not normally used for heat removal, and the AFW System is not required.

ACTIONS -----------------------------------REVIEWER'S NOTE-----------------------------------

The LCO 3.0.4.b Note prohibits application of the LCO 3.0.4.b exception when entering MODE 1 if the plant does not depend on AFW for startup.

If the plant does depend on AFW for startup, the Note should state, "LCO 3.0.4.b is not applicable."

A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train [when entering MODE 1]. There is an increased risk associated with

[entering a MODE or other specified condition in the Applicability

] [entering MODE 1] with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

[ A.1 If the turbine driven AFW train is inoperable due to one inoperable steam supply, or if a turbine driven pump is inoperable for any reason while in MODE 3 immediately following refueling, action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable, based on the following reasons:

a. For the inoperability of the turbine driven AFW pump due to one inoperable steam supply, the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump and the turbine driven train is still capable of performing its specified function for most postulated events.

b. For the inoperability of a turbine driven AFW pump while in MODE 3 immediately subsequent to a refueling, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation.

4 5 2 1 AFW System B 3.7.5 Westinghouse STS B 3.7.5-5 Rev. 4.0 Revision XXXSEQUOYAH UNIT 1 1BASES

ACTIONS (continued)

c. For both the inoperability of the turbine driven pump due to one inoperable steam supply and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling outage, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps, and due to the low probability of an event requiring the use of the turbine driven AFW pump.

Condition A is modified by a Note which limits the applicability of the Condition for an inoperable turbine driven AFW pump in MODE 3 to when the unit has not entered MODE 2 following a refueling. Condition A allows one AFW train to be inoperable for 7 days vice the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor

being critical.

]

B.1 With one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2, or 3

[for reasons other than Condition A

], action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This Condition includes the loss of two steam supply lines to the turbine driven AFW pump. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable, based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a DBA occurring during this time period.

C.1 and C.2

With one of the required motor driven AFW trains (pump or flow path) inoperable and the turbine driven AFW train inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within

[24] [48] hours. Assuming no single active failures when in this condition, the accident (a feedline break (FLB) or main steam line break (MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump due to the faulted steam generator (SG). In this condition, the AFW System may no longer be able to meet the required flow to the SGs assumed in the safety analysis, [either due to the analysis requiring flow from two AFW pumps or due to the remaining AFW pump having to feed a faulted SG

]. 2 2 2 1 1)3 AFW System B 3.7.5 Westinghouse STS B 3.7.5-6 Rev. 4.0 Revision XXXSEQUOYAH UNIT 1 1BASES

ACTIONS (continued)

REVIEWER'S NOTE----------------------------------

Licensees should adopt the appropriate Completion Time based on their plant design. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is applicable to plants that can no longer meet the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting in the loss of the remaining steam supply to the turbine driven AFW pump. The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time is applicable to plants that can still meet the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting in the loss of the remaining steam supply to the turbine driven AFW pump

. --------------------------------------------------------------------------------------------------

[ The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the remaining OPERABLE steam supply to the turbine driven AFW pump, the availability of the remaining OPERABLE motor driven AFW pump, and the low probability of an event occurring that would require the inoperable steam supply to be available for the turbine driven AFW pump

. ] [ The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time is reasonable based on the fact that the remaining motor driven AFW train is capable of providing 100% of the AFW flow requirements, and the low probability of an event occurring that would challenge the AFW system.

D.1 and D.2

When Required Action A.1

[B.1, C.1, or C.2

] cannot be completed within the required Completion Time, or if two AFW trains are inoperable in MODE 1, 2, or 3 for reasons other than Condition C, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within

[18] hours.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 4 with two AFW trains inoperable, operation is allowed to continue because only one motor driven pump AFW train is required in accordance with the Note that modifies the LCO. Although not required, the unit may continue to cool down and initiate RHR.

4 2 2 2 , 3 AFW System B 3.7.5 Westinghouse STS B 3.7.5-7 Rev. 4.0 Revision XXXSEQUOYAH UNIT 1 1BASES

ACTIONS (continued)

E.1 If all [three] AFW trains are inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status.

Required Action E.1 is modified by a Note indicating that all required MODE changes are suspended until one AFW train is restored to OPERABLE status. In this case, LCO 3.0.3 is not applicable because it could force the unit into a less safe condition.

F.1 In MODE 4, either the reactor coolant pumps or the RHR loops can be used to provide forced circulation. This is addressed in LCO 3.4.6, "RCS

Loops - MODE 4." With one required AFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status. The immediate Completion Time is consistent with LCO 3.4.6.

SURVEILLANCE SR 3.7.5.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the AFW System water and steam supply flow paths provides assurance that the proper flow paths will exist for AFW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

[ The SR is modified by a Note that states one or more AFW trains may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually (i.e., remotely or locally, as appropriate) realigned to the AFW mode of operation, provided it is not otherwise inoperable. This exception allows the system to be out

of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable. Since AFW may be 2 2 6the AFW System B 3.7.5 Westinghouse STS B 3.7.5-8 Rev. 4.0 Revision XXXSEQUOYAH UNIT 1 1BASES

SURVEILLANCE REQUIREMENTS (continued)

used during startup, shutdown, hot standby operations, and hot shutdown operations for steam generator level control, and these manual operations are an accepted function of the AFW System, OPERABILITY (i.e., the intended safety function) continues to be maintained.

] [ The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.7.5.2 Verifying that each AFW pump's developed head at the flow test point is greater than or equal to the required developed head ensures that AFW pump performance has not degraded during the cycle. Flow and differential head are normal tests of centrifugal pump performance required by the ASME Code (Ref 2). Because it is undesirable to introduce cold AFW into the steam generators while they are operating, this testing is performed on recirculation flow. This test confirms one point on the pump design curve and is i ndicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. Performance of inservice testing discussed in the ASME Code (Ref. 2) (only required at 3-month intervals) satisfies this

requirement.

[ This SR is modified by a Note indicating that the SR should be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.

]

2 7 4 2 AFW System B 3.7.5 Westinghouse STS B 3.7.5-9 Rev. 4.0 Revision XXXSEQUOYAH UNIT 1 1BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.5.3

This SR verifies that AFW can be delivered to the appropriate steam generator in the event of any accident or transient that generates an ESFAS, by demonstrating that each automatic valve in the flow path actuates to its correct position on an actual or simulated actuation signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls.

[ The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The [18]

month Frequency is acceptable based on operating experience and the design reliability of the equipment.

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] [ The SR is modified by a Note that states one or more AFW trains may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually (i.e., remotely or locally, as appropriate) realigned to the AFW mode of operation, provided it is not otherwise inoperable. This exception allows the system to be out

of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable. Since AFW may be used during startup, shutdown, hot standby operations, and hot shutdown operations for steam generator level control, and these manual operations are an accepted function of the AFW System, OPERABILITY (i.e., the intended safety function) continues to be maintained.

]

2 7 4or in the event the CSTs become depleted, 1 8INSERT 5 8two Notes. Note 1 states that 2

3.7.5 Insert Page B 3.7.5-9 INSERT 5 Note 2 states that the SR is only required to be met in MODES 1, 2, and 3. It is not required to be met in MODE 4, since the AFW train is only required for the purposes of removing decay heat when the SG is relied upon for heat removal. The operation of the AFW train is by manual means and automatic startup of the AFW train is not required.

8 AFW System B 3.7.5 Westinghouse STS B 3.7.5-10 Rev. 4.0 Revision XXXSEQUOYAH UNIT 1 1BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.5.4

This SR verifies that the AFW pumps will start in the event of any accident or transient that generates an ESFAS by demonstrating that

each AFW pump starts automatically on an actual or simulated actuation

signal in MODES 1, 2, and 3. In MODE 4, the required pump is already operating and the autostart function is not required.

[ The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] This SR is modified by

[a] [two] Note[s]. [Note 1 indicates that the SR be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.

] [The Note [2] states that one or more AFW trains may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually (i.e., remotely or locally, as appropriate) realigned to the AFW mode of operation, provided it is not otherwise inoperable. This exception allows the system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable. Since AFW may be used during startup, shutdown, hot standby operations, and hot shutdown operations for steam generator level control, and these manual operations are an accepted function of the AFW System. OPERABILITY (i.e., the intended safety function) continues to be maintained.

] 7 4 2 2 threeINSERT 6 8 8 may 3 3.7.5 Insert Page B 3.7.5-10 INSERT 6 Note 3 states that the SR is only required to be met in MODES 1, 2, and 3. It is not required to be met in MODE 4, since the AFW train is only required for the purposes of removing decay heat when the SG is relied upon for heat removal. The operation of the AFW train is by manual means and automatic startup of the AFW train is not required.

8 AFW System B 3.7.5 Westinghouse STS B 3.7.5-11 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES

SURVEILLANCE REQUIREMENTS (continued)

[ SR 3.7.5.5 This SR verifies that the AFW is properly aligned by verifying the flow paths from the CST to each steam generator prior to entering MODE 2 after more than 30 days in any combination of MODE 5 or 6 or defueled. OPERABILITY of AFW flow paths must be verified before sufficient core heat is generated that would require the operation of the AFW System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgement and other administrative controls that ensure that flow paths remain OPERABLE. To further ensure AFW System alignment, flow path OPERABILITY is verified following extended outages to determine no misalignment of valves has occurred. This SR ensures that the flow path from the CST to the steam generators is properly aligned. ] -----------------------------------REVIEWER'S NOTE-----------------------------------

This SR is not required by those units that use AFW for normal startup and shutdown.

REFERENCES 1. FSAR, Section

[10.4.9]. 2. ASME Code for Operation and Maintenance of Nuclear Power Plants. 7.2 3 2 2 U AFW System B 3.7.5 Westinghouse STS B 3.7.5-1 Rev. 4.0 Revision XXXSEQUOYAH UNIT 2 1B 3.7 PLANT SYSTEMS

B 3.7.5 Auxiliary Feedwater (AFW) System

BASES BACKGROUND The AFW System automatically supplies feedwater to the steam generators to remove decay heat from the Reactor Coolant System upon the loss of normal feedwater supply.

The AFW pumps take suction through separate and independent suction lines from the condensate storage tank (CST) (LCO 3.7.6, "Condensate Storage Tank (CST)") and pump to the steam generator secondary side via separate and independent connections to the main feedwater (MFW) piping outside containment. The steam generators function as a heat sink for core decay heat. The heat load is dissipated by releasing steam to the atmosphere from the steam generators via the main steam safety valves (MSSVs) (LCO 3.7.1, "Main Steam Safety Valves (MSSVs)") or

atmospheric dump valves (LCO 3.7.4, "Atmospheric Dump Valves (ADVs)"). If the main condenser is available, steam may be released via the steam bypass valves and recirculated to the CST.

The AFW System consists of

[two] motor driven AFW pumps and one steam turbine driven pump configured into

[three] trains. Each motor driven pump provides

[100]% of AFW flow capacity, and the turbine driven pump provides

[200]% of the required capacity to the steam generators, as assumed in the accident analysis. The pumps are

equipped with independent recirculation lines to prevent pump operation against a closed system. Each moto r driven AFW pump is powered from an independent Class 1E power supply and feeds

[two] steam generators, although each pump has the capability to be realigned from the control room to feed other steam generators. The steam turbine driven AFW pump receives steam from two main steam lines upstream of the main steam isolation valves. Each of the steam feed lines will supply 100% of the requirements of the turbine driven AFW pump.

The AFW System is capable of supplying feedwater to the steam generators during normal unit startup, shutdown, and hot standby conditions.

The turbine driven AFW pump supplies a common header capable of feeding all steam generators with DC powered control valves actuated to the appropriate steam generator by the Engineered Safety Feature Actuation System (ESFAS). One pump at full flow is sufficient to remove decay heat and cool the unit to residual heat removal (RHR) entry conditions. Thus, the requirement for diversity in motive power sources for the AFW System is met.

1 1 2 2 1 1 1 relief ARVs Dump11/2 inch 1 INSERT 1INSERT 2 pneumatic open Relief 3.7.5 Insert Page B 3.7.5-1 INSERT 1 Except for the common miniflow line to and supply line from the condensate storage tanks and some shared support facilities such as the condensate storage tanks and parts of the Control Air System, the two reactor units have separate AFW Systems. The normal suction for both units AFW pumps is through a common header connected to two condensate storage tanks (CSTs) (LCO 3.7.6, "Condensate Storage Tank (CST)"). The pumps are grouped into unit specific systems with each systems' pumps aligned to their respective units steam generators secondary side via connections to the main feedwater piping between the main feedwater isolation check valve and the steam generator. The nonessential condensate supply is isolated from the essential portion of the AFW System by check valves. A low AFW pump suction pressure automatically actuates valves from ERCW on a two-out-of three signal to align the AFW pump suction to ERCW to ensure the AFW pumps have an adequate water supply.

INSERT 2 , except for the Feedwater line Break (FWLB) and Small Break Loss-of-Coolant accident (SBLOCA) 1 1 AFW System B 3.7.5 Westinghouse STS B 3.7.5-2 Rev. 4.0 Revision XXXSEQUOYAH UNIT 2 1BASES

BACKGROUND (continued)

The AFW System is designed to supply sufficient water to the steam generator(s) to remove decay heat with steam generator pressure at the setpoint of the MSSVs. Subsequently, the AFW System supplies sufficient water to cool the unit to RHR entry conditions, with steam released through the ADVs. The AFW System actuates automatically on steam generator water level low-low by the ESFAS (LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation"). The system also actuates on loss of offsite power, safety injection, and trip of all MFW pumps.

The AFW System is discussed in the FSAR, Section

[10.4.9] (Ref. 1).

APPLICABLE The AFW System mitigates the consequences of any event with loss of SAFETY normal feedwater.

ANALYSES The design basis of the AFW System is to supply water to the steam generator to remove decay heat and other residual heat by delivering at least the minimum required flow rate to the steam generators at pressures corresponding to the lowest steam generator safety valve set pressure plus 3%.

In addition, the AFW System must supply enough makeup water to replace steam generator secondary inventory lost as the unit cools to MODE 4 conditions. Sufficient AFW flow must also be available to account for flow losses such as pump recirculation and line breaks.

The limiting Design Basis Accidents (DBAs) and transients for the AFW System are as follows:

a. Feedwater Line Break (FWLB) and

b. Loss of MFW.

In addition, the minimum available AFW flow and system characteristics are serious considerations in the analysis of a small break loss of coolant accident (LOCA).

The AFW System design is such that it can perform its function following an FWLB between the MFW isolation valves and containment, combined with a loss of offsite power following turbine trip, and a single active failure of the steam turbine driven AFW pump. In such a case, the 7.2 1 2 U s 1 ARVs 1 INSERT 3 INSERT 4 1 3.7.5 Insert Page B 3.7.5-2 INSERT 3 initiation of Anticipated Transient Without Scram (ATWS) Mitigation Actuation Circuitry (AMSAC), trip of one MFW pump with turbine load above 77% Unit 2,

INSERT 4

The AFW System actuations on an AMSAC signal and on a MFW pump trip/power coincident signal are not required as part of this LCO.

1 1 AFW System B 3.7.5 Westinghouse STS B 3.7.5-3 Rev. 4.0 Revision XXXSEQUOYAH UNIT 2 1BASES

APPLICABLE SAFETY ANALYSES (continued)

ESFAS logic may not detect the affected steam generator if the backflow check valve to the affected MFW header worked properly. One motor driven AFW pump would deliver to the broken MFW header at the pump runout flow until the problem was detected, and flow terminated by the operator. Sufficient flow would be delivered to the intact steam generator by the redundant AFW pump.

The ESFAS automatically actuates the AFW turbine driven pump and associated power operated valves and controls when required to ensure an adequate feedwater supply to the steam generators during loss of

power. DC power operated valves are provided for each AFW line to control the AFW flow to each steam generator.

The AFW System satisfies the requirements of Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO This LCO provides assurance that the AFW System will perform its design safety function to mitigate the consequences of accidents that could result in overpressurization of the reactor coolant pressure

boundary.

[Three] independent AFW pumps in

[three] diverse trains are required to be OPERABLE to ensure the availability of RHR capability for all events accompanied by a loss of offsite power and a single failure. This is accomplished by powering two of the pumps from independent emergency buses. The third AFW pump is powered by a different means, a steam driven turbine supplied with steam from a source that is not isolated by closure of the MSIVs.

The AFW System is configured into

[three] trains. The AFW System is considered OPERABLE when the components and flow paths required to provide redundant AFW flow to the steam generators are OPERABLE.

This requires that the two motor driven AFW pumps be OPERABLE in

[two] diverse paths, each supplying AFW to separate steam generators. The turbine driven AFW pump is required to be OPERABLE with redundant steam supplies from each of

[two] main steam lines upstream of the MSIVs, and shall be capable of supplying AFW to any of the steam generators. The piping, valves, instrumentation, and controls in the required flow paths also are required to be OPERABLE.

The LCO is modified by a Note indicating that one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4. This is because of the reduced heat removal requirements and short period of time in MODE 4 during which the AFW is required and the insufficient steam available in MODE 4 to power the turbine driven AFW pump. 2 2 2 2 3 Air 1In such a case, one 1decay heat removal 1

AFW System B 3.7.5 Westinghouse STS B 3.7.5-4 Rev. 4.0 Revision XXXSEQUOYAH UNIT 2 1BASES