NL-15-1881, Revised Technical Specification Page for Primary Containment Isolation Instrumentation

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Revised Technical Specification Page for Primary Containment Isolation Instrumentation
ML15288A232
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 10/15/2015
From: Pierce C
Southern Co, Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-15-1881
Download: ML15288A232 (13)
v • d • e


Text

{{#Wiki_filter:Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc. 40 Inverness Center Parkway Post Office Box 1295 Binningham, AL 35242 Tel 205.992.7872 SOUTHERN << \ Fax 205.992.7601 UCLEAR A SOUTHERN COMPANY October 15, 2015 Docket Nos.: 50-321 NL-15-1881 50-366 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Unit 1 and 2 Revised Technical Specification Page for Primary Containment Isolation Instrumentation Ladies and Gentlemen: By letter dated October 10, 2014, Southern Nuclear Operating Company (SNC) submitted a request for an amendment to the Technical Specifications (TS) for Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2. The proposed amenqment adopts several previously NRC-approved Technical Specifications Task Force (TSTF) Travelers. One of the requested TSTF Travelers was TSTF-306-A, Revision 2. This Traveler adds an Action Note to TS 3.3.6.1, "Primary Containment Isolation Instrumentation," to allow penetration flow paths to be unisolated intermittently under administrative controls. TS 3.6.1.3, "Primary Containment Isolation Valves (PCIVs)," contains an allowance to open PCIVs intermittently under administrative controls. The basis for approval of TSTF-306 is that the isolation instrumentation described in TS 3.3.6.1 serves as a support system for the PCIVs. The Actions for inoperability of the instrumentation should not be more restrictive than the Actions for inoperability of the PCIVs. Therefore, the allowance to intermittently open penetrations (under administrative control) that are isolated to comply with Actions is added to the TS 3.3.6.1 Actions as Note 1. Based upon subsequent discussion between SNC and the Nuclear Regulatory Commission staff (NRC), it was requested that SNC add a clarifying statement to proposed Note 1 in TS 3.3.6.1 that 18 inch purge valve penetration flow paths cannot be unisolated intermittently under administrative controls. This clarification will make Proposed Note 1 to TS 3.3.6.1 consistent with existing Note 1 to TS 3.6.1.3, which states (with italics added for effect) "Penetration flow paths except for 18 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls." Given that this requirement for isolating the 18 inch purge valve penetration flow paths remains unchanged, adding this statement to Note 1 of TS 3.3.6.1 is strictly an editorial change. As such, the technical justification (including the Significant Hazards Consideration) provided in the October 10, 2014 letter remains valid. Enclosure 1 provides the marked-up TS 3.3.6.1 pages, and Enclosure 2 provides the corresponding clean pages. Enclosure 3 provides the marked-up TS Bases pages to reflect this change. Per the October 10, 2014 letter, this new Note in the TS Bases

U.S. Nuclear Regulatory Commission NL-15-1881 Page2 ACTIONS was provided as an INSERT ("Bases 3.3.6.1 Actions"). As such, this INSERT has been revised accordingly. The marked TS Bases page for this insert is unchanged from the original letter, and is provided for information. Additionally, this marked TS Bases page contained a separate INSERT ("Bases 3.3.6.1 ASA") that was unaffected by this letter and as such is not included. This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369. Mr. C. R. Pierce states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true. Retft"tJ::.ed, C. R. Pierce Regulatory Affairs Director CRP/RMJ J;!'~7ltd befo'L this 15 !!oday of @)cJ,~ ,2015. Notary Public~ My commission expires: /b--8 -;;LD/1

Enclosures:

1. Marked-up Pages for TS 3.3.6.1
2. Clean Pages forTS 3.3.6.1
3. Marked-up Pages for TS Bases 3.3.6.1 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President- Hatch Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. D. R. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President- Engineering Mr. G. L. Johnson, Regulatory Affairs Manager- Hatch RType: CHA02.004 U.S. Nuclear Regulatory Commission Mr. L. D. Wert, Regional Administrator (Acting)

Mr. R. E. Martin, NRR Senior Project Manager- Hatch Mr. D. H. Hardage, Senior Resident Inspector- Hatch State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Edwin I. Hatch Nuclear Plant Unit 1 and 2 Revised Technical Specification Page for Primary Containment Isolation Instrumentation Enclosure 1 Marked-up Pages for TS 3.3.6.1

Primary Containment Isolation Instrumentation 3.3.6.1 3.3 INSTRUMENTATION ITSTF-306 I 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.6.1-1.

1. Penetration flow paths except for 18 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls .

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Place channel in trip. 12 hours for channels inoperable. Functions 2.a, 2.b, 

                                                                         ~ 6 *b ~-{ 7.a, and 7.b AND 24 hours for Functions other than Functions 2.a, 2.b,
                                                                         ~ 6 *b~
  • 7.a , and 7.b I B. ------NOTE------- B.1 Restore isolation 1 hour Not applicable for capability.

Function S.c. One or more automatic Functions with isolation capability not maintained.

c. Required Action and C.1 Enter the Condition Immediately associated Completion referenced in Time of Condition A or B Table 3.3.6.1-1 for the not met. channel.

(contmued) HATCH UNIT 1 3.3-48 Amendment No. ~ I

Primary Containment Isolation Instrumentation 3.3.6.1 ITSTF-306 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.6.1-1.

1. Penetration flow paths except for 18 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls.
                 - - - - - - - - - - - - - - - .tNOTE~-                             I -------------

r;::;"'l _;:r Separate Condition entry is allowed for each channel. NOTES ~ CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Place channel in trip. 12 hours for channels inoperable. Functions 2.a, 2.b, 

                                                                                       ~.b "--1
  • 7.a, and 7.b I AND 24 hours for Functions other than Functions 2.a, 2.b,
                                                                                       ~ 6 .b "--1
  • 7.a, and 7.b I B. -------NOTE------ B.1 Restore isolation 1 hour Not applicable for capability.

Function S.c. One or more automatic Functions with isolation capability not maintained.

c. Required Action and C.1 Enter the Condition Immediately associated Completion referenced in Time of Condition A or 8 Table 3.3.6.1-1 for the not met. channel.

(continued) HATCH UNIT2 3.3-48 Amendment No.m I

Edwin I. Hatch Nuclear Plant Unit 1 and 2 Revised Technical Specification Page for Primary Containment Isolation Instrumentation Enclosure 2 Clean Pages for TS 3.3.6.1

Primary Containment Isolation Instrumentation 3.3.6.1 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.6.1-1. ACTIONS

NOTES-- ----------------------------

1. Penetration flow paths except for 18 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls.
2. Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Place channel in trip. 12 hours for channels inoperable. Functions 2.a, 2.b, 6.b, 7.a, and 7.b AND 24 hours for Functions other than Functions 2.a, 2.b, 6.b, 7.a, and 7.b B. ------NOTE------- 8.1 Restore isolation 1 hour Not applicable for capability. Function 5.c. One or more automatic Functions with isolation capability not maintained.

c. Required Action and C.1 Enter the Condition Immediately associated Completion referenced in Time of Condition A or B Table 3.3.6.1-1 for the not met. channel.

(contmued) HATCH UNIT 1 3.3-48 Amendment No.

Primary Containment Isolation Instrumentation 3.3.6.1 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.6.1-1. ACTIONS NOTES-

1. Penetration flow paths except for 18 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls
2. Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Place channel in trip. 12 hours for channels inoperable. Functions 2.a, 2.b, 6.b, 7.a, and 7.b AND 24 hours for Functions other than Functions 2.a, 2.b, 6.b, 7.a, and 7.b B. ------NOTE- ------ B.1 Restore isolation 1 hour Not applicable for capability. Function S.c. One or more automatic Functions with isolation capability not maintained.

c. Required Action and C.1 Enter the Condition Immediately associated Completion referenced in Time of Condition A or B Table 3.3.6.1-1 for the not met. channel.

(continued) HATCH UNIT2 3.3-48 Amendment No.

Edwin I. Hatch Nuclear Plant Unit 1 and 2 Revised Technical Specification Page for Primary Containment Isolation Instrumentation Enclosure 3 Marked-up Pages for TS Bases 3.3.6.1

Primary Containment Isolation Instrumentation B 3.3.6.1 ITSTF-306 BASES APPLICABLE 6.b. Reactor Vessel Water Level - Low. Level 3 (continued) SAFETY ANALYSES, LCO, and RHR Shutdown Cooling System isolation on Level 3 supports actions APPLICABILITY to ensure that the RPV water level does not drop below the top of the aptive fuel during a vessel draindown event caused by a leak (e.g., pipe break or inadvertent valve opening) in the RHR Shutdown Cooling System. The top of active fuel is defined in "Applicable Safety Analyses" for Safety Limit 2.1.1.3, "Reactor Vessel Water Level," found in the Bases for Safety Limit 2.1.1, "Reactor Core SLs." Reactor Vessel Water Level - Low, Level 3 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant columri of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. Four channels of the Reactor Vessel Water Level - Low, Level 3 Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. As noted [footnote (d) to Table 3.3.6.1-1], only two channels of the Reactor Vessel Water Level- Low, Level3 Function are required to be OPERABLE in MODES 4 and 5 (and must input into the same trip system), provided the RHR Shutdown Cooling System integrity is maintained. System integrity is maintained provided the piping is intact and no maintenance is being performed that has the potential for draining the reactor vessel through the system. The Reactor Vessel Water Level- Low, Level3 Allowable Value was chosen to be the same as the RPS Reactor Vessel Water Level - Low, Level 3 Allowable Value (LCO 3.3.1.1 ), since the capability to cool the fuel may be threatened. The Reactor Vessel Water Level - Low, Level 3 Function is only required to be OPERABLE in MODES 3, 4, and 5 to prevent this potential flow path from lowering the reactor vessel level to the top of the fuel. In MODES 1 and 2, another isolation (i.e., Reactor Steam Dome Pressure - High) and administrative controls ensure that this flow path remains isolated to prevent unexpected loss of inventory via this flow path. ACTIONS A Note has been provided to modify the ACTIONS related to primary con amment isolation instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, INSERT- Bases 3.3.6.1 Actions (continued) HATCH UNIT 1 B 3.3-153 REVISION 1m

INSERT - Bases 3.3.6.1 Actions ITSTF-306 I The ACTIONS are modified by two Notes. Note 1 allows penetration flow path(s) except for the 18 inch purge valve penetration flow paths to be unisolated intermittently under administrative controls. These controls consistent of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

Primary Containment Isolation Instrumentation B 3.3.6.1 ITSTF-306 BASES APPLICABLE 6.b. Reactor Vessel Water Level - Low. Level 3 (continued) SAFETY ANALYSES, LCO, and System is bounded by breaks of the recirculation and MSL. The APPLICABILITY RHR Shutdown Cooling System isolation on Level 3 supports actions to ensure that the RPV water level does not drop below the top of the active fuel during a vessel draindown event caused by a leak (e.g., pipe break or inadvertent valve opening) in the RHR Shutdown Cooling System. The top of active fuel is defined in "Applicable Safety Analyses" for Safety Limit 2.1 .1.3, "Reactor Vessel Water Level," found in the Bases for Safety Limit 2.1.1, "Reactor Core SLs." Reactor Vessel Water Level - Low, Level 3 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. Four channels of the Reactor Vessel Water Level - Low, Level 3 Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. As noted (footnote (d) to Table 3.3.6.1-1), only two channels of the Reactor Vessel Water Level- Low, Level3 Function are required to be OPERABLE in MODES 4 and 5 (and must input into the same trip system), provided the RHR Shutdown Cooling System integrity is maintained. System integrity is maintained provided the piping is intact and no maintenance is being performed that has the potential for draining the reactor vessel through the system. The Reactor Vessel Water Level - Low, Level 3 Allowable Value was chosen to be the same as the RPS Reactor Vessel Water Level - Low, Level 3 Allowable Value (LCO 3.3.1.1), since the capability to cool the fuel may be threatened. The Reactor Vessel Water Level - Low, Level 3 Function is only required to be OPERABLE in MODES 3, 4, and 5 to prevent this potential flow path from lowering the reactor vessel level to the top of the fuel. In MODES 1 and 2, another isolation (i.e., Reactor Steam Dome Pressure - High) and administrative controls ensure that this flow path remains isolated to prevent unexpected loss of inventory via this flow path. !iNSERT- Bases 3.3.6.1 ASA h This Function isolates the Group 6 valves (and 2E11-F009). Note 2 ACTIONS A Note as been provided to modify the ACTIONS related to primary con amment isolation instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, INSERT- Bases 3.3.6.1 Actions (continued) HATCH UNIT2 B 3.3-153 REVISION ~

INSERT - Bases 3.3.6.1 Actions jTSTF-306 I The ACTIONS are modified by two Notes. Note 1 allows penetration flow path(s) except for the 18 inch purge valve penetration flow paths to be unisolated intermittently under administrative controls. These controls consistent of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc. 40 Inverness Center Parkway Post Office Box 1295 Binningham, AL 35242 Tel 205.992.7872 SOUTHERN << \ Fax 205.992.7601 UCLEAR A SOUTHERN COMPANY October 15, 2015 Docket Nos.: 50-321 NL-15-1881 50-366 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Unit 1 and 2 Revised Technical Specification Page for Primary Containment Isolation Instrumentation Ladies and Gentlemen: By letter dated October 10, 2014, Southern Nuclear Operating Company (SNC) submitted a request for an amendment to the Technical Specifications (TS) for Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2. The proposed amenqment adopts several previously NRC-approved Technical Specifications Task Force (TSTF) Travelers. One of the requested TSTF Travelers was TSTF-306-A, Revision 2. This Traveler adds an Action Note to TS 3.3.6.1, "Primary Containment Isolation Instrumentation," to allow penetration flow paths to be unisolated intermittently under administrative controls. TS 3.6.1.3, "Primary Containment Isolation Valves (PCIVs)," contains an allowance to open PCIVs intermittently under administrative controls. The basis for approval of TSTF-306 is that the isolation instrumentation described in TS 3.3.6.1 serves as a support system for the PCIVs. The Actions for inoperability of the instrumentation should not be more restrictive than the Actions for inoperability of the PCIVs. Therefore, the allowance to intermittently open penetrations (under administrative control) that are isolated to comply with Actions is added to the TS 3.3.6.1 Actions as Note 1. Based upon subsequent discussion between SNC and the Nuclear Regulatory Commission staff (NRC), it was requested that SNC add a clarifying statement to proposed Note 1 in TS 3.3.6.1 that 18 inch purge valve penetration flow paths cannot be unisolated intermittently under administrative controls. This clarification will make Proposed Note 1 to TS 3.3.6.1 consistent with existing Note 1 to TS 3.6.1.3, which states (with italics added for effect) "Penetration flow paths except for 18 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls." Given that this requirement for isolating the 18 inch purge valve penetration flow paths remains unchanged, adding this statement to Note 1 of TS 3.3.6.1 is strictly an editorial change. As such, the technical justification (including the Significant Hazards Consideration) provided in the October 10, 2014 letter remains valid. Enclosure 1 provides the marked-up TS 3.3.6.1 pages, and Enclosure 2 provides the corresponding clean pages. Enclosure 3 provides the marked-up TS Bases pages to reflect this change. Per the October 10, 2014 letter, this new Note in the TS Bases

U.S. Nuclear Regulatory Commission NL-15-1881 Page2 ACTIONS was provided as an INSERT ("Bases 3.3.6.1 Actions"). As such, this INSERT has been revised accordingly. The marked TS Bases page for this insert is unchanged from the original letter, and is provided for information. Additionally, this marked TS Bases page contained a separate INSERT ("Bases 3.3.6.1 ASA") that was unaffected by this letter and as such is not included. This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369. Mr. C. R. Pierce states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true. Retft"tJ::.ed, C. R. Pierce Regulatory Affairs Director CRP/RMJ J;!'~7ltd befo'L this 15 !!oday of @)cJ,~ ,2015. Notary Public~ My commission expires: /b--8 -;;LD/1

Enclosures:

1. Marked-up Pages for TS 3.3.6.1
2. Clean Pages forTS 3.3.6.1
3. Marked-up Pages for TS Bases 3.3.6.1 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President- Hatch Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. D. R. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President- Engineering Mr. G. L. Johnson, Regulatory Affairs Manager- Hatch RType: CHA02.004 U.S. Nuclear Regulatory Commission Mr. L. D. Wert, Regional Administrator (Acting)

Mr. R. E. Martin, NRR Senior Project Manager- Hatch Mr. D. H. Hardage, Senior Resident Inspector- Hatch State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Edwin I. Hatch Nuclear Plant Unit 1 and 2 Revised Technical Specification Page for Primary Containment Isolation Instrumentation Enclosure 1 Marked-up Pages for TS 3.3.6.1

Primary Containment Isolation Instrumentation 3.3.6.1 3.3 INSTRUMENTATION ITSTF-306 I 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.6.1-1.

1. Penetration flow paths except for 18 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls .

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Place channel in trip. 12 hours for channels inoperable. Functions 2.a, 2.b, 

                                                                         ~ 6 *b ~-{ 7.a, and 7.b AND 24 hours for Functions other than Functions 2.a, 2.b,
                                                                         ~ 6 *b~
  • 7.a , and 7.b I B. ------NOTE------- B.1 Restore isolation 1 hour Not applicable for capability.

Function S.c. One or more automatic Functions with isolation capability not maintained.

c. Required Action and C.1 Enter the Condition Immediately associated Completion referenced in Time of Condition A or B Table 3.3.6.1-1 for the not met. channel.

(contmued) HATCH UNIT 1 3.3-48 Amendment No. ~ I

Primary Containment Isolation Instrumentation 3.3.6.1 ITSTF-306 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.6.1-1.

1. Penetration flow paths except for 18 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls.
                 - - - - - - - - - - - - - - - .tNOTE~-                             I -------------

r;::;"'l _;:r Separate Condition entry is allowed for each channel. NOTES ~ CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Place channel in trip. 12 hours for channels inoperable. Functions 2.a, 2.b, 

                                                                                       ~.b "--1
  • 7.a, and 7.b I AND 24 hours for Functions other than Functions 2.a, 2.b,
                                                                                       ~ 6 .b "--1
  • 7.a, and 7.b I B. -------NOTE------ B.1 Restore isolation 1 hour Not applicable for capability.

Function S.c. One or more automatic Functions with isolation capability not maintained.

c. Required Action and C.1 Enter the Condition Immediately associated Completion referenced in Time of Condition A or 8 Table 3.3.6.1-1 for the not met. channel.

(continued) HATCH UNIT2 3.3-48 Amendment No.m I

Edwin I. Hatch Nuclear Plant Unit 1 and 2 Revised Technical Specification Page for Primary Containment Isolation Instrumentation Enclosure 2 Clean Pages for TS 3.3.6.1

Primary Containment Isolation Instrumentation 3.3.6.1 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.6.1-1. ACTIONS

NOTES-- ----------------------------

1. Penetration flow paths except for 18 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls.
2. Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Place channel in trip. 12 hours for channels inoperable. Functions 2.a, 2.b, 6.b, 7.a, and 7.b AND 24 hours for Functions other than Functions 2.a, 2.b, 6.b, 7.a, and 7.b B. ------NOTE------- 8.1 Restore isolation 1 hour Not applicable for capability. Function 5.c. One or more automatic Functions with isolation capability not maintained.

c. Required Action and C.1 Enter the Condition Immediately associated Completion referenced in Time of Condition A or B Table 3.3.6.1-1 for the not met. channel.

(contmued) HATCH UNIT 1 3.3-48 Amendment No.

Primary Containment Isolation Instrumentation 3.3.6.1 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.6.1-1. ACTIONS NOTES-

1. Penetration flow paths except for 18 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls
2. Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Place channel in trip. 12 hours for channels inoperable. Functions 2.a, 2.b, 6.b, 7.a, and 7.b AND 24 hours for Functions other than Functions 2.a, 2.b, 6.b, 7.a, and 7.b B. ------NOTE- ------ B.1 Restore isolation 1 hour Not applicable for capability. Function S.c. One or more automatic Functions with isolation capability not maintained.

c. Required Action and C.1 Enter the Condition Immediately associated Completion referenced in Time of Condition A or B Table 3.3.6.1-1 for the not met. channel.

(continued) HATCH UNIT2 3.3-48 Amendment No.

Edwin I. Hatch Nuclear Plant Unit 1 and 2 Revised Technical Specification Page for Primary Containment Isolation Instrumentation Enclosure 3 Marked-up Pages for TS Bases 3.3.6.1

Primary Containment Isolation Instrumentation B 3.3.6.1 ITSTF-306 BASES APPLICABLE 6.b. Reactor Vessel Water Level - Low. Level 3 (continued) SAFETY ANALYSES, LCO, and RHR Shutdown Cooling System isolation on Level 3 supports actions APPLICABILITY to ensure that the RPV water level does not drop below the top of the aptive fuel during a vessel draindown event caused by a leak (e.g., pipe break or inadvertent valve opening) in the RHR Shutdown Cooling System. The top of active fuel is defined in "Applicable Safety Analyses" for Safety Limit 2.1.1.3, "Reactor Vessel Water Level," found in the Bases for Safety Limit 2.1.1, "Reactor Core SLs." Reactor Vessel Water Level - Low, Level 3 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant columri of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. Four channels of the Reactor Vessel Water Level - Low, Level 3 Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. As noted [footnote (d) to Table 3.3.6.1-1], only two channels of the Reactor Vessel Water Level- Low, Level3 Function are required to be OPERABLE in MODES 4 and 5 (and must input into the same trip system), provided the RHR Shutdown Cooling System integrity is maintained. System integrity is maintained provided the piping is intact and no maintenance is being performed that has the potential for draining the reactor vessel through the system. The Reactor Vessel Water Level- Low, Level3 Allowable Value was chosen to be the same as the RPS Reactor Vessel Water Level - Low, Level 3 Allowable Value (LCO 3.3.1.1 ), since the capability to cool the fuel may be threatened. The Reactor Vessel Water Level - Low, Level 3 Function is only required to be OPERABLE in MODES 3, 4, and 5 to prevent this potential flow path from lowering the reactor vessel level to the top of the fuel. In MODES 1 and 2, another isolation (i.e., Reactor Steam Dome Pressure - High) and administrative controls ensure that this flow path remains isolated to prevent unexpected loss of inventory via this flow path. ACTIONS A Note has been provided to modify the ACTIONS related to primary con amment isolation instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, INSERT- Bases 3.3.6.1 Actions (continued) HATCH UNIT 1 B 3.3-153 REVISION 1m

INSERT - Bases 3.3.6.1 Actions ITSTF-306 I The ACTIONS are modified by two Notes. Note 1 allows penetration flow path(s) except for the 18 inch purge valve penetration flow paths to be unisolated intermittently under administrative controls. These controls consistent of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

Primary Containment Isolation Instrumentation B 3.3.6.1 ITSTF-306 BASES APPLICABLE 6.b. Reactor Vessel Water Level - Low. Level 3 (continued) SAFETY ANALYSES, LCO, and System is bounded by breaks of the recirculation and MSL. The APPLICABILITY RHR Shutdown Cooling System isolation on Level 3 supports actions to ensure that the RPV water level does not drop below the top of the active fuel during a vessel draindown event caused by a leak (e.g., pipe break or inadvertent valve opening) in the RHR Shutdown Cooling System. The top of active fuel is defined in "Applicable Safety Analyses" for Safety Limit 2.1 .1.3, "Reactor Vessel Water Level," found in the Bases for Safety Limit 2.1.1, "Reactor Core SLs." Reactor Vessel Water Level - Low, Level 3 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. Four channels of the Reactor Vessel Water Level - Low, Level 3 Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. As noted (footnote (d) to Table 3.3.6.1-1), only two channels of the Reactor Vessel Water Level- Low, Level3 Function are required to be OPERABLE in MODES 4 and 5 (and must input into the same trip system), provided the RHR Shutdown Cooling System integrity is maintained. System integrity is maintained provided the piping is intact and no maintenance is being performed that has the potential for draining the reactor vessel through the system. The Reactor Vessel Water Level - Low, Level 3 Allowable Value was chosen to be the same as the RPS Reactor Vessel Water Level - Low, Level 3 Allowable Value (LCO 3.3.1.1), since the capability to cool the fuel may be threatened. The Reactor Vessel Water Level - Low, Level 3 Function is only required to be OPERABLE in MODES 3, 4, and 5 to prevent this potential flow path from lowering the reactor vessel level to the top of the fuel. In MODES 1 and 2, another isolation (i.e., Reactor Steam Dome Pressure - High) and administrative controls ensure that this flow path remains isolated to prevent unexpected loss of inventory via this flow path. !iNSERT- Bases 3.3.6.1 ASA h This Function isolates the Group 6 valves (and 2E11-F009). Note 2 ACTIONS A Note as been provided to modify the ACTIONS related to primary con amment isolation instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, INSERT- Bases 3.3.6.1 Actions (continued) HATCH UNIT2 B 3.3-153 REVISION ~

INSERT - Bases 3.3.6.1 Actions jTSTF-306 I The ACTIONS are modified by two Notes. Note 1 allows penetration flow path(s) except for the 18 inch purge valve penetration flow paths to be unisolated intermittently under administrative controls. These controls consistent of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.}}

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