Text

Southern Nuclear Operating Co - Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements
	ML20241A240
Person / Time
Site:	Hatch
Issue date:	08/28/2020
From:	Gayheart C; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-20-0785
	Download: ML20241A240 (109)
	v • d • e

Cheryl A. Gayheart 3535 Colonnade Parkway Regulatory Affairs Director Birmingham, AL 35243 205 992 5316 cagayhea@southernco.com August 28, 2020 Docket Nos.: 50-321 NL-20-0785 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) is submitting a request for amendments to the Technical Specifications (TS) for Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2.

SNC requests adoption of TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements. The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed change. Attachment 2 provides revised (clean) TS pages. Attachment 3 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

SNC requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested by December 31, 2020 to support the Unit 2 refueling outage starting in early February. Once approved, the amendment shall be implemented within 45 days.

There are no regulatory commitments made in this submittal.

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

If you should have any questions regarding this submittal, please contact Jamie Coleman at 205.992.6611.

U.S. Nuclear Regulatory Commission NL-20-0029 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of August 2020.

Respectfully submitted, C. A. Gayheart Regulatory Affairs Director Southern Nuclear Operating Company CAG/wag/scm

Enclosure:

Description and Assessment Attachments: 1. Proposed Technical Specification Changes (Mark-Up)

2. Revised Technical Specification Pages

3. Proposed Technical Specification Bases Changes (Mark-Up) - For Information Only cc: Regional Administrator, Region II NRR Project Manager - Hatch Senior Resident Inspector - Hatch Director, Environmental Protection Division - State of Georgia RType: CHA02.004

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements Enclosure Description and Assessment

Enclosure to NL-20-0785 Description and Assessment

1.0 DESCRIPTION

Southern Nuclear Operating Company (SNC) requests adoption of TSTF 582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements." The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation SNC has reviewed the safety evaluation for TSTF-582 provided to the Technical Specifications Task Force in a letter dated August 13, 2020. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-582. SNC has concluded that the justifications presented in TSTF-582 and the safety evaluation prepared by the NRC staff are applicable to Edwin I. Hatch Nuclear Plant, Units 1 and 2 (HNP) and justify this amendment for the incorporation of the changes to the HNP TS.

SNC verifies that the required ECCS injection/spray subsystem can be aligned and the pump started using relatively simple evolutions involving the manipulation of a small number of components. These actions can be performed in a short time (less than the Drain Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) from the control room following plant procedures.

2.2 Optional Changes and Variations SNC is proposing the following variations from the TS changes described in TSTF-582 or the applicable parts of the NRC staffs safety evaluation:

The HNP TS utilize different numbering than the Standard Technical Specifications (STS) on which TSTF-582 was based. Specifically:

HNP TS 3.6.1.3 Condition E. corresponds to the STS 3.6.1.3 Condition F.

HNP TS 3.8.2 Surveillance Requirement (SR) 3.8.2.1 NOTE contains changes to SR 3.8.1.9, SR 3.8.1.11, and SR 3.8.1.17 which correspond to the STS SR 3.8.2.1 changes to SR 3.8.1.11, SR 3.8.1.13, and SR 3.8.1.19, respectively.

HNP TS 3.8.2 SR 3.8.2.1 contains additions of SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.11, and SR 3.8.1.17 which correspond to the STS SR 3.8.2.1 additions of SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.19, respectively.

These differences are administrative and do not affect the applicability of TSTF-582 to the HNP TS.

SNC is proposing to identify TS SR 3.5.2.5 as Deleted in order to avoid renumbering SRs 3.5.2.6, 3.5.2.7, and 3.5.2.8. SNC considers this to be an administrative modification to the corresponding SR changes proposed in TSTF-582.

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Enclosure to NL-20-0785 Description and Assessment Changes in TSTF-582 were incorporated in the HNP TS as variations during adoption of TSTF-542. Therefore, the TSTF-582 changes are not needed. Other changes were added as variations during adoption of TSTF-542 which have been superseded by the requirements in TSTF-582. These plant-specific changes are replaced by the TSTF-582 generic requirements.

HNP does not have a Manual Initiation Function as assumed in the STS and in TSTF-542.

HNP added a footnote (c) to the Table 3.3.5.2-1 LPCI low pressure coolant injection pump discharge flow - low (bypass) Function 2.b. This footnote states Function not required to be OPERABLE while associated pump is operating in decay heat removal when minimum flow valve is closed and deactivated. Since TSTF-582 deletes the requirement for Function 2.b. this HNP footnote (c) is also being deleted.

The TSTF-582 changes pertaining to the TS 3.6.1.3 Applicability and to the deletion of Conditions G and H were incorporated as variations during HNP adoption of TSTF-542. In addition, the SR 3.6.1.3 Notes being deleted in TSTF-582 do not exist in the HNP TS.

TSTF-582 deletes NOTE 2 from SR 3.8.2.1 which states SR 3.8.1.12 and SR 3.8.1.19 are not required to be met when associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, ECCS Shutdown. This NOTE does not exist in HNP SR 3.8.2.1.

TSTF-582, "RPV WIC Enhancements," states:

The ECCS injection/spray subsystem required to be operable by LCO 3.5.2 must be capable of being manually started as defense-in-depth against an unexpected draining event. The changes in TSTF-542 did not assume automatic actuation of the ECCS subsystem. TS 3.5.2, Required Action D.1 requires an additional method of water injection and that the required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

However, LCO 3.5.2 does not assume that the onsite electrical power source will start automatically on an ECCS or loss of power signal.

LCO 3.8.2, "AC Sources - Shutdown," requires one offsite circuit and one diesel generator to be operable in Modes 4 and 5. SR 3.8.2.1 lists the TS 3.8.1, "AC Sources - Operating," SRs that are applicable in Modes 4 and 5. In an oversight in TSTF-542, the TS 3.8.1 SRs that test automatic start and loading of a diesel generator on an ECCS or loss of offsite power signal were not excluded from SR 3.8.2.1.

TSTF-582 revises Technical Specification (TS) 3.8.2, "AC Sources - Shutdown,"

Surveillance Requirement (SR) 3.8.2.1, to exclude SRs that verify the ability of the diesel generators to automatically start and load on an ECCS initiation signal or loss of offsite power signal.

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Enclosure to NL-20-0785 Description and Assessment The NRC Safety Evaluation for TSTF-582 (ADAMS Accession No. ML20219A333, dated, 08/13/2020), Section 3.6, "Alternating Current Sources -

Shutdown, STS 3.8.2," states:

STS 3.5.2, Reactor Pressure Vessel Water Inventory Control (RPV WIC), does not require automatic ECCS initiation to mitigate a draining event in Modes 4 and 5, and the ECCS initiation signal related to the automatic ECCS initiation is removed from the STS. Because the automatic ECCS initiation and related ECCS initial signal in Modes 4 and 5 are eliminated, the automatic start of the DG on an ECCS initiation signal is not required in Modes 4 and 5. [T]he NRC staff finds that STS 3.5.2 provides enough time from the onset of the [loss of offsite power]

LOOP event for the operator to manually start the DG required to supply power to the water injection equipment to mitigate the draining event in Modes 4 and 5. In addition, STS 3.5.2 does not require the automatic initiation of the ECCS injection/spray subsystem or the additional method of water injection. Therefore, since STS 3.5.2 allows enough time to manually start the DG and the equipment for water injection, the NRC staff finds that the automatic start and loading of the DG are not necessary on a LOOP signal or LOOP concurrent with an ECCS initiation signal to mitigate a draining event in Modes 4 and 5.

Furthermore, the NRC staff notes that other events postulated in Modes 4 and 5 (e.g., FHA, waste gas tank rupture) and during movement of

[recently] irradiated fuel assemblies in the [primary and secondary containment] do not assume a LOOP event or an automatic ECCS initiation.

TSTF-582 did not include all of the TS changes needed to reflect that TS 3.8.2 should not require automatic start and loading of a diesel generator within 12 seconds on an ECCS initiation signal or a loss of offsite power signal.

HNP TS 3.3.8.1, "Loss of Power (LOP) Instrumentation," is applicable when the associated diesel generator is required to be operable.

TSTF-582 revised TS 3.8.2 to no longer require automatic start and loading of a diesel generator on a loss of offsite power signal.

Consequently, the LOP instrumentation that generates the loss of offsite power signal should not be required to be operable when the diesel generator is required to be operable by TS 3.8.2. The Applicability of LCO 3.3.8.1 is revised to "When associated diesel generator is required to be OPERABLE by LCO 3.8.1."

HNP TS SR 3.8.1.5 and SR 3.8.1.13 require that the DG starts from standby or hot conditions, respectively, and achieve required voltage and frequency within 12 seconds. The 12 second start requirement supports the assumptions in the design basis LOCA analysis. This capability is not required during a manual diesel generator start to respond to a draining event, which has a minimum Drain Time of one hour. Therefore, SR 3.8.1.5 and SR 3.8.1.13 are added to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.

HNP TS SR 3.8.1.16 states, "Verify interval between each sequenced load block is within +/- 10% of design interval for each load sequence E-3

Enclosure to NL-20-0785 Description and Assessment timing device." TSTF-582 retained the HNP SR 3.8.1.16 as a test that must be met but not performed. The load sequencer timing devices are only used for the automatic start and loading of the diesel generator and are not used during a manual diesel generator start. Therefore, SR 3.8.1.16 is added to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.

The TS 3.8.2 LCO Bases were not updated by TSTF-542 or TSTF-582 to reflect that automatic start and loading of a diesel generator is not required. The LCO 3.8.2 and SR 3.8.2.1 Bases are revised to reflect the TS requirements.

This variation provides consistency within the TS after incorporating the TSTF-582 changes to SR 3.8.2.1.

As an editorial improvement, SR 3.8.2.1 is revised to list the TS 3.8.1 SRs that are applicable instead of the TS 3.8.1 SRs that are not applicable. This has no effect on the requirements. The SR 3.8.2.1 Bases continue to explain why certain TS 3.8.1 SRs are omitted from the list.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Southern Nuclear Operating Company (SNC) requests adoption of TSTF 582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements.

The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." TSTF-582 includes the following changes to the technical specifications (TS):

1. The TS are revised to eliminate the requirement for a manual ECCS initiation signal to start the required ECCS injection/spray subsystem, and to instead rely on manual valve alignment and pump start.

2. The Drain Time definition is revised to move the examples of common mode failure mechanisms to the Bases and seismic events are no longer considered a common mode failure mechanism.

3. The Drain Time definition exception from considering the Drain Time for penetration flow paths isolated with manual or automatic valves that are that are "locked, sealed, or otherwise secured" is revised to apply the exception for manual or automatic valves that are "closed and administratively controlled."

4. The TS are revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.

5. A Surveillance Requirement (SR) that requires operating the required Emergency Core Cooling System (ECCS) injection/spray subsystem for at least 10 minutes through the recirculation line, is modified to permit crediting normal operation of the system to satisfy the SR and to permit operation through the test return line.

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Enclosure to NL-20-0785 Description and Assessment

6. Edwin I. Hatch Nuclear Plant, Units 1 and 2 share secondary containment structures between units. The TS Actions are revised to recognize that an operable secondary containment and operable secondary containment isolation valves satisfy the Required Actions.

7. TS 3.8.2, "AC Sources - Shutdown," SR 3.8.2.1, is revised to not require SRs that test the ability of the automatic diesel generator to start in Modes 4 and

5. Automatic ECCS initiation in Modes 4 and 5 was eliminated in TSTF-542.

This was an oversight in TSTF-542.

8. The TS are revised to use wording and to define acronyms in a manner consistent with the remainder of the TS. These changes are made for consistency and have no effect on the application of the TS.

SNC has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." Draining of RPV water inventory in Mode 4 (i.e., cold shutdown) and Mode 5 (i.e.,

refueling) is not an accident previously evaluated and, therefore, revising the existing TS controls to prevent or mitigate such an event has no effect on any accident previously evaluated. RPV water inventory control in Mode 4 or Mode 5 is not an initiator of any accident previously evaluated. The existing and revised TS controls are not mitigating actions assumed in any accident previously evaluated.

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

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." The event of concern under the current requirements and the proposed change is an unexpected draining event. The TS have contained requirements related to an unexpected draining event during shutdown for over 40 years and this event does not appear as an analyzed event in the Updated Final Safety Analysis Report (UFSAR) for any plant or in the NRC's Standard Review Plan (NUREG-0800). Therefore, an unexpected draining event is not a new or different kind of accident not considered in the design and licensing bases E-5

Enclosure to NL-20-0785 Description and Assessment that would have been considered a design basis accident in the UFSAR had it been previously identified.

None of the equipment affected by the proposed change has a design function described in the UFSAR to mitigate an unexpected draining event in Modes 4 or 5, although the equipment may be used for that purpose.

Therefore, the proposed amendment will not change the design function of the affected equipment. The proposed change will effect the operation of certain equipment, such as the manual initiation function and related instrumentation to permit initiation of the required ECCS injection/spray subsystem, and the control of valves credited for preventing a draining event.

However, these changes provide adequate protection to prevent or mitigate an unexpected draining event and do not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

The safety basis for the RPV WIC requirements is to protect Safety Limit 2.1.1.3. The proposed change does not affect any specific values that define a safety margin as established in the licensing basis. The proposed change does not affect a design basis or safety limit, or any controlling value for a parameter established in the UFSAR or the license. Therefore, the proposed change does not significantly reduce the margin of safety.

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

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

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the E-6

Enclosure to NL-20-0785 Description and Assessment issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

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Edwin I. Hatch Nuclear Plant - Units 1 and 2 Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements Attachment 1 Proposed Technical Specification Changes (Mark-Up)

Definitions 1.1 1.1 Definitions (continued)

DRAIN TIME susceptible to a common mode failure, for all penetration flow (e.g., seismic event, loss (continued) of normal power, single human error), for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c. The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;

d. No additional draining events occur; and

e. Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

HATCH UNIT 1 1.1-3 Amendment No. 303

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.2-1 for the channel.

BA. As required by Required A.1 Initiate action to place Immediately Action A.1 and referenced channel in trip.

in Table 3.3.5.2-1.One or more channels inoperable. OR BA.2.1 Declare associated penetration flow path(s) incapable of automatic Immediately isolation.

AND BA.2.2 Initiate action to Ccalculate DRAIN TIME. Immediately C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.5.2-1.

D. As required by Required D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and referenced OPERABLE status.

in Table 3.3.5.2-1.

HATCH UNIT 1 3.3-44 Amendment No. 290

RPV Water Inventory Control Instrumentation 3.3.5.2 E. Required Action and E.1 Declare associated low Immediately associated Completion pressure ECCS Time of Condition C or D injection/spray subsystem not met. inoperable.

HATCH UNIT 1 3.3-44 Amendment No. 290

RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program HATCH UNIT 1 3.3-45 Amendment No. 290

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 SURVEILLANCE VALUE REQUIREMENTS

1. Core Spray System

a. Reactor Steam Dome 4, 5 4(a) C SR 3.3.5.2.1 476 psig Pressure - Low (Injection SR 3.3.5.2.2 Permissive)

b. Core Spray Pump 4, 5 1 per D SR 3.3.5.2.1 610 gpm and Discharge Flow - Low subsystem(a) SR 3.3.5.2.2 825 gpm (Bypass)

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Steam Dome 4, 5 4(a) C SR 3.3.5.2.1 476 psig Pressure - Low (Injection SR 3.3.5.2.2 Permissive)

b. Low Pressure Coolant 4, 5 1 per D SR 3.3.5.2.1 1670 gpm Injection Pump subsystem(a), (c) SR 3.3.5.2.2 and Discharge Flow - Low 2205 gpm (Bypass)

31. RHR System Isolation

a. Reactor Vessel Water (ba) 2 in one trip B SR 3.3.5.2.1 0 inches Level - Low, Level 3 system SR 3.3.5.2.2

42. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water (ba) 2 in one trip B SR 3.3.5.2.1 -47 inches Level - Low Low, Level 2 system SR 3.3.5.2.2 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, Reactor Pressure Vessel Water Inventory Control.

(ba) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

(c) Function not required to be OPERABLE while associated pump is operating in decay heat removal when minimum flow valve is closed and deactivated.

HATCH UNIT 1 3.3-46 Amendment No. 290

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE for each diesel generator (DG) required by LCO 3.8.1, AC Sources - Operating, and LCO 3.8.2, AC Sources - Shutdown.

APPLICABILITY: When associated DG is required to be OPERABLE by LCO 3.8.1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore channel to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months channels inoperable. OPERABLE status.

B. Required Action and B.1 Declare associated DG Immediately associated Completion inoperable.

Time not met.

HATCH UNIT 1 3.3-70 Amendment No. 302

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.3 Verify required standby gas 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months treatment (SGT) subsystem(s) are capable of being placed in operation in less than the DRAIN TIME.

D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 ------------NOTE---------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish Immediately an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to establish Immediately secondary containment boundary.

AND D.3 Initiate action to isolate Immediately each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

AND Immediately D.4 Initiate action to verify required standby gas treatmentSGT subsystem(s) are capable of being placed in operation.

HATCH UNIT 1 3.5-7 Amendment No. 290

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to 36 Time of Condition C or D hours.

not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure coolant injection In accordance with (LPCI) subsystem, the suppression pool water the Surveillance level is 146 inches. Frequency Control Program SR 3.5.2.3 Verify, for a required Core Spray (CS) subsystem, In accordance with the: the Surveillance Frequency Control

a. Suppression pool water level is Program 146 inches; or

b. Condensate storage tank water level is 13 ft.

(continued)

HATCH UNIT 1 3.5-9 Amendment No. 290

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with subsystem, locations susceptible to gas the Surveillance accumulation are sufficiently filled with water. Frequency Control Program SR 3.5.2.5 Deleted----------------------------NOTES------------------

1. A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

2. Not required to be met for system vent flowpaths opened under administrative control.

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

SR 3.5.2.6 ---------------------------NOTES------------------------------

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

In accordance with Operate the required ECCS injection/spray the Surveillance subsystem through the recirculation line for 10 Frequency Control minutes. Program SR 3.5.2.7 Verify each valve credited for automatically In accordance with isolating a penetration flow path actuates to the the Surveillance isolation position on an actual or simulated Frequency Control isolation signal. Program SR 3.5.2.8 ---------------------------NOTE--------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray In accordance with HATCH UNIT 1 3.5-10 Amendment No. 290

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. ---------------NOTE------------- C.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except for Only applicable to penetration flow path by excess flow check penetration flow paths with use of at least one valve (EFCV) line and only one PCIV. closed and de-activated penetrations with a

automatic valve, closed closed system manual valve, or blind One or more penetration flange. AND flow paths with one PCIV inoperable except due to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for leakage not within limits. AND EFCV line and penetrations with a C.2 -----------NOTES---------- closed system

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

D. One or more penetration D.1 Restore leakage to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months flow paths with leakage not within limit.

within limit.

E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, C, AND or D not met in MODE 1, 2, or 3. E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months HATCH UNIT 1 3.6-9 Amendment No. 290

AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.1 Suspend CORE Immediately DG(s) inoperable. ALTERATIONS.

AND B.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.

AND B.3 Initiate action to restore Immediately required DG(s) to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 -----------------------------NOTE------------------------------

The following SRs are not required to be performed: SR 3.8.1.2.b, SR 3.8.1.7, through SR 3.8.1.98, SR 3.8.1.112, through and SR 3.8.1.14, SR 3.8.1.16, and SR 3.8.1.17.

In accordance with The following SRs are applicable for AC sources applicable SRs required to be OPERABLE:

SR 3.8.1.1 SR 3.8.1.4 SR 3.8.1.12 SR 3.8.1.2 SR 3.8.1.7 SR 3.8.1.14 SR 3.8.1.3 SR 3.8.1.8 SR 3.8.1.19 For required Unit 1 AC sources, the SRs of LCO 3.8.1, except SR 3.8.1.6, SR 3.8.1.15, and SR 3.8.1.18, are applicable.

SR 3.8.2.2 For required Unit 2 AC sources, SR 3.8.2.1 of In accordance with Unit 2 Specification 3.8.2 is applicable. Unit 2 SR 3.8.2.1 HATCH UNIT 1 3.8-22 Amendment No. 290

Definitions 1.1 1.1 Definitions (continued)

DRAIN TIME susceptible to a common mode failure, for all penetration flow (e.g., seismic event, loss (continued) of normal power, single human error), for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c. The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;

d. No additional draining events occur; and

e. Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

HATCH UNIT 2 1.1-3 Amendment No. 248

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.2-1 for the channel.

BA. As required by Required A.1 Initiate action to place Immediately Action A.1 and referenced channel in trip.

in Table 3.3.5.2-1One or more channels inoperable. OR BA.2.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.

AND Immediately BA.2.2 Initiate action to cCalculate DRAIN TIME.

C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.5.2-1.

D. As required by Required D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and referenced OPERABLE status.

in Table 3.3.5.2-1.

E. Required Action and E.1 Declare associated low Immediately associated Completion pressure ECCS HATCH UNIT 2 3.3-44 Amendment No. 235

RPV Water Inventory Control Instrumentation 3.3.5.2 Time of Condition C or D injection/spray subsystem not met. inoperable.

HATCH UNIT 2 3.3-45 Amendment No. 235

RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program HATCH UNIT 2 3.3-46 Amendment No. 235

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Core Spray System

a. Reactor Steam Dome 4, 5 4(a) C SR 3.3.5.2.1 476 psig Pressure - Low (Injection SR 3.3.5.2.2 Permissive)

b. Core Spray Pump 4, 5 1 per D SR 3.3.5.2.1 570 gpm and Discharge Flow - Low subsystem(a) SR 3.3.5.2.2 745 gpm (Bypass)

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Steam Dome 4, 5 4(a) C SR 3.3.5.2.1 476 psig Pressure - Low (Injection SR 3.3.5.2.2 Permissive)

b. Low Pressure Coolant 4, 5 1 per D SR 3.3.5.2.1 1675 gpm and Injection Pump subsystem(a), (c) SR 3.3.5.2.2 2215 gpm Discharge Flow - Low (Bypass)

31. RHR System Isolation

a. Reactor Vessel Water (ba) 2 in one trip B SR 3.3.5.2.1 0 inches Level - Low Level 3 system SR 3.3.5.2.2

42. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water (ba) 2 in one trip B SR 3.3.5.2.1 -47 inches Level - Low Low, Level 2 system SR 3.3.5.2.2 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, Reactor Pressure Vessel Water Inventory Control.

(ba) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

(c) Function not required to be OPERABLE while associated pump is operating in decay heat removal when minimum flow valve is closed and deactivated.

HATCH UNIT 2 3.3-47 Amendment No. 235

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE for each diesel generator (DG) required by LCO 3.8.1, AC Sources - Operating, and LCO 3.8.2, AC Sources - Shutdown.

APPLICABILITY: When associated DG is required to be OPERABLE by LCO 3.8.1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore channel to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months channels inoperable. OPERABLE status.

B. Required Action and B.1 Declare associated DG Immediately associated Completion inoperable.

Time not met.

HATCH UNIT 2 3.3-70 Amendment No. 247

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) AND C.3 Verify required standby 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months gas treatment (SGT) subsystem(s) are capable of being placed in operation in less than the DRAIN TIME.

D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 ------------NOTE-----------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to Immediately establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to Immediately establish secondary containment boundary.

AND D.3 Initiate action to isolate Immediately each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

(continued)

HATCH UNIT 2 3.5-8 Amendment No. 235

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) AND D.4 Initiate action to verify Immediately required standby gas treatmentSGT subsystem(s) are capable of being placed in operation.

E. Required Action and E.1 Initiate actin to restore Immediately associated Completion DRAIN TIME to 36 Time of Condition C or D hours.

not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure coolant injection In accordance with (LPCI) subsystem, the suppression pool water the Surveillance level is 146 inches. Frequency Control Program SR 3.5.2.3 Verify, for a required Core Spray (CS) subsystem, In accordance with the: the Surveillance Frequency Control

a. Suppression pool water level is Program 146 inches; or

b. Condensate storage tank water level is 15 ft.

HATCH UNIT 2 3.5-9 Amendment No. 235

RPV Water Inventory Control 3.5.2 (continued)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with subsystem, locations susceptible to gas the Surveillance accumulation are sufficiently filled with water. Frequency Control Program SR 3.5.2.5 Deleted--------------------------NOTES--------------------

1. A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

2. Not required to be met for system vent flowpaths opened under administrative control.

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

SR 3.5.2.6 ---------------------------NOTES------------------------------

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

In accordance with Operate the required ECCS injection/spray the Surveillance subsystem through the recirculation line for 10 Frequency Control minutes. Program SR 3.5.2.7 Verify each valve credited for automatically In accordance with isolating a penetration flow path actuates to the the Surveillance isolation position on an actual or simulated Frequency Control isolation signal. Program SR 3.5.2.8 ---------------------------NOTE-------------------------------

Vessel injection/spray may be excluded.

HATCH UNIT 2 3.5-10 Amendment No. 235

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. --------------NOTE--------------- C.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except for Only applicable to penetration flow path by excess flow check penetration flow paths with use of at least one valve (EFCV) line and only one PCIV. closed and de-activated penetrations with a

automatic valve, closed closed system manual valve, or blind One or more penetration flange. AND flow paths with one PCIV inoperable except due to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for leakage not within limits. AND EFCV line and penetrations with a C.2 ----------NOTES----------- closed system

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

D. One or more penetration D.1 Restore leakage to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months flow paths with leakage not within limit.

within limit.

E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, C, AND or D not met in MODE 1, 2, or 3. E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months HATCH UNIT 2 3.6-9 Amendment No. 235

AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.1 Suspend CORE Immediately DG(s) inoperable. ALTERATIONS.

AND B.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.

AND B.3 Initiate action to restore Immediately required DG(s) to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 ---------------------------NOTE--------------------------------

The following SRs are not required to be performed: SR 3.8.1.2.b, SR 3.8.1.7, through SR 3.8.1.98, SR 3.8.1.112, through and SR 3.8.1.14, SR 3.8.1.16., and SR 3.8.1.17.

In accordance with The following SRs are applicable for AC sources applicable SRs required to be OPERABLE:

SR 3.8.1.1 SR 3.8.1.4 SR 3.8.1.12 SR 3.8.1.2 SR 3.8.1.7 SR 3.8.1.14 SR 3.8.1.3 SR 3.8.1.8 SR 3.8.1.19 For required Unit 2 AC sources, the SRs of LCO 3.8.1, except SR 3.8.1.6, SR 3.8.1.15, and SR 3.8.1.18, are applicable.

SR 3.8.2.2 For required Unit 1 AC sources, SR 3.8.2.1 of In accordance with Unit 1 Specification 3.8.2 is applicable. Unit 1 SR 3.8.2.1 HATCH UNIT 2 3.8-22 Amendment No. 235

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements Attachment 2 Revised Technical Specification Pages

Definitions 1.1 1.1 Definitions (continued)

DRAIN TIME susceptible to a common mode failure, for all penetration flow (continued) paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c. The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;

d. No additional draining events occur; and

e. Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

(continued)

HATCH UNIT 1 1.1-3 Amendment No.

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Initiate action to place Immediately inoperable. channel in trip.

OR A.2.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.

AND A.2.2 Initiate action to Immediately calculate DRAIN TIME.

HATCH UNIT 1 3.3-44 Amendment No.

RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Table 3.3.5.2-1.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program HATCH UNIT 1 3.3-45 Amendment No.

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE MODES OR OTHER REQUIRED SPECIFIED CHANNELS ALLOWABLE FUNCTION CONDITIONS PER FUNCTION VALUE

1. RHR System Isolation

a. Reactor Vessel Water (a) 2 in one trip system 0 inches Level - Low, Level 3

2. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water (a) 2 in one trip system -47 inches Level - Low Low, Level 2 (a) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

HATCH UNIT 1 3.3-46 Amendment No.

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE for each diesel generator (DG) required by LCO 3.8.1, AC Sources - Operating.

APPLICABILITY: When associated DG is required to be OPERABLE by LCO 3.8.1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore channel to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months channels inoperable. OPERABLE status.

B. Required Action and B.1 Declare associated DG Immediately associated Completion inoperable.

Time not met.

HATCH UNIT 1 3.3-70 Amendment No.

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.3 Verify required standby gas 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months treatment (SGT) subsystem(s) are capable of being placed in operation in less than the DRAIN TIME.

D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 ------------NOTE---------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish Immediately an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to establish Immediately secondary containment boundary.

AND D.3 Initiate action to isolate Immediately each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

AND D.4 Initiate action to verify Immediately required SGT subsystem(s) are capable of being placed in operation.

(continued)

HATCH UNIT 1 3.5-7 Amendment No.

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to 36 Time of Condition C or D hours.

not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required LPCI subsystem, the In accordance with suppression pool water level is 146 inches. the Surveillance Frequency Control Program SR 3.5.2.3 Verify, for a required Core Cpray (CS) subsystem, In accordance with the: the Surveillance Frequency Control

a. Suppression pool water level is Program 146 inches; or

b. Condensate storage tank water level is 13 ft.

(continued)

HATCH UNIT 1 3.5-8 Amendment No.

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with subsystem, locations susceptible to gas the Surveillance accumulation are sufficiently filled with water. Frequency Control Program SR 3.5.2.5 Deleted SR 3.5.2.6 ---------------------------NOTES------------------------------

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray In accordance with subsystem for 10 minutes. the Surveillance Frequency Control Program SR 3.5.2.7 Verify each valve credited for automatically In accordance with isolating a penetration flow path actuates to the the Surveillance isolation position on an actual or simulated Frequency Control isolation signal. Program SR 3.5.2.8 ---------------------------NOTE--------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray In accordance with subsystem can be manually operated. the Surveillance Frequency Control Program HATCH UNIT 1 3.5-9 Amendment No.

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. ---------------NOTE------------- C.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except for Only applicable to penetration flow path by excess flow check penetration flow paths with use of at least one valve (EFCV) line and only one PCIV. closed and de-activated penetrations with a

automatic valve, closed closed system manual valve, or blind One or more penetration flange. AND flow paths with one PCIV inoperable except due to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for leakage not within limits. AND EFCV line and penetrations with a C.2 -----------NOTES---------- closed system

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

D. One or more penetration D.1 Restore leakage to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months flow paths with leakage not within limit.

within limit.

E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, C, AND or D not met.

E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months HATCH UNIT 1 3.6-9 Amendment No.

AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.1 Suspend CORE Immediately DG(s) inoperable. ALTERATIONS.

AND B.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.

AND B.3 Initiate action to restore Immediately required DG(s) to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 -----------------------------NOTE------------------------------

The following SRs are not required to be performed: SR 3.8.1.2.b, SR 3.8.1.7, SR 3.8.1.8, SR 3.8.1.12, and SR 3.8.1.14.

The following SRs are applicable for AC sources In accordance with required to be OPERABLE: applicable SRs SR 3.8.1.1 SR 3.8.1.4 SR 3.8.1.12 SR 3.8.1.2 SR 3.8.1.7 SR 3.8.1.14 SR 3.8.1.3 SR 3.8.1.8 SR 3.8.1.19 SR 3.8.2.2 For required Unit 2 AC sources, SR 3.8.2.1 of In accordance with Unit 2 Specification 3.8.2 is applicable. Unit 2 SR 3.8.2.1 HATCH UNIT 1 3.8-22 Amendment No.

Definitions 1.1 1.1 Definitions (continued)

DRAIN TIME susceptible to a common mode failure, for all penetration flow (continued) paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c. The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;

d. No additional draining events occur; and

e. Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

(continued)

HATCH UNIT 2 1.1-3 Amendment No.

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Initiate action to place Immediately inoperable. channel in trip.

OR A.2.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.

AND A.2.2 Initiate action to calculate Immediately DRAIN TIME.

HATCH UNIT 2 3.3-44 Amendment No.

RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Table 3.3.5.2-1.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program HATCH UNIT 2 3.3-45 Amendment No.

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE MODES OR OTHER REQUIRED SPECIFIED CHANNELS ALLOWABLE FUNCTION CONDITIONS PER FUNCTION VALUE

1. RHR System Isolation

a. Reactor Vessel Water (a) 2 in one trip system 0 inches Level - Low Level 3

2. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water (a) 2 in one trip system -47 inches Level - Low Low, Level 2 (a) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

HATCH UNIT 2 3.3-46 Amendment No.

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE for each diesel generator (DG) required by LCO 3.8.1, AC Sources - Operating.

APPLICABILITY: When associated DG is required to be OPERABLE by LCO 3.8.1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore channel to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months channels inoperable. OPERABLE status.

B. Required Action and B.1 Declare associated DG Immediately associated Completion inoperable.

Time not met.

HATCH UNIT 2 3.3-70 Amendment No.

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) AND C.3 Verify required standby 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months gas treatment (SGT) subsystem(s) are capable of being placed in operation in less than the DRAIN TIME.

D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 ------------NOTE-----------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to Immediately establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to Immediately establish secondary containment boundary.

AND D.3 Initiate action to isolate Immediately each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

(continued)

HATCH UNIT 2 3.5-8 Amendment No.

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) AND D.4 Initiate action to verify Immediately required SGT subsystem(s) are capable of being placed in operation.

E. Required Action and E.1 Initiate actin to restore Immediately associated Completion DRAIN TIME to 36 Time of Condition C or D hours.

not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required LPCI subsystem, the In accordance with suppression pool water level is 146 inches. the Surveillance Frequency Control Program SR 3.5.2.3 Verify, for a required Core Spray (CS) subsystem, In accordance with the: the Surveillance Frequency Control

a. Suppression pool water level is Program 146 inches; or

b. Condensate storage tank water level is 15 ft.

(continued)

HATCH UNIT 2 3.5-9 Amendment No.

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with subsystem, locations susceptible to gas the Surveillance accumulation are sufficiently filled with water. Frequency Control Program SR 3.5.2.5 Deleted.

SR 3.5.2.6 ---------------------------NOTES------------------------------

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray In accordance with subsystem for 10 minutes. the Surveillance Frequency Control Program SR 3.5.2.7 Verify each valve credited for automatically In accordance with isolating a penetration flow path actuates to the the Surveillance isolation position on an actual or simulated Frequency Control isolation signal. Program SR 3.5.2.8 ---------------------------NOTE-------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray In accordance with subsystem can be manually operated. the Surveillance Frequency Control Program HATCH UNIT 2 3.5-10 Amendment No.

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. --------------NOTE--------------- C.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except for Only applicable to penetration flow path by excess flow check penetration flow paths with use of at least one valve (EFCV) line and only one PCIV. closed and de-activated penetrations with a

automatic valve, closed closed system manual valve, or blind One or more penetration flange. AND flow paths with one PCIV inoperable except due to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for leakage not within limits. AND EFCV line and penetrations with a C.2 ----------NOTES----------- closed system

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

D. One or more penetration D.1 Restore leakage to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months flow paths with leakage not within limit.

within limit.

E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, C, AND or D not met.

E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months HATCH UNIT 2 3.6-9 Amendment No.

AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.1 Suspend CORE Immediately DG(s) inoperable. ALTERATIONS.

AND B.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.

AND B.3 Initiate action to restore Immediately required DG(s) to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 ---------------------------NOTE--------------------------------

The following SRs are not required to be performed: SR 3.8.1.2.b, SR 3.8.1.7, SR 3.8.1.8, SR 3.8.1.12, and SR 3.8.1.14.

The following SRs are applicable for AC sources In accordance with required to be OPERABLE: applicable SRs SR 3.8.1.1 SR 3.8.1.4 SR 3.8.1.12 SR 3.8.1.2 SR 3.8.1.7 SR 3.8.1.14 SR 3.8.1.3 SR 3.8.1.8 SR 3.8.1.19 SR 3.8.2.2 For required Unit 1 AC sources, SR 3.8.2.1 of In accordance with Unit 1 Specification 3.8.2 is applicable. Unit 1 SR 3.8.2.1 HATCH UNIT 2 3.8-22 Amendment No.

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements Attachment 3 Proposed Technical Specification Bases Changes (Mark-Up) - For Information Only

RPV Water Inventory Control Instrumentation B 3.3.5.2 B 3.3 INSTRUMENTATION B 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSS) for variables that have significant safety functions. LSSS are defined by the regulation as Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded. The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is not exceeded.

Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The actual settings for the automatic isolation channels are the same as those established for the same functions in MODES 1, 2, and 3 in LCO 3.3.5.1, Emergency Core Cooling System (ECCS) Instrumentation, or LCO 3.3.6.1, Primary Containment Isolation Instrumentation.

With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur.

Under the definition of DRAIN TIME, some penetration flow paths may be excluded from the DRAIN TIME calculation if they will be isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation.

(continued)

HATCH UNIT 1 B 3.3-125 REVISION 98

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES BACKGROUND The purpose of the RPV Water Inventory Control Instrumentation is to (continued) support the requirements of LCO 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control, and the definition of DRAIN TIME.

There are functions that are required for manual initiation or operation of the ECCS injection/spray subsystem required to be OPERABLE by LCO 3.5.2 and other functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

The RPV Water Inventory Control Instrumentation supports operation of core spray (CS) and low pressure coolant injection (LPCI). The equipment involved with each of these systems is described in the Bases for LCO 3.5.2.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not SAFETY ANALYSES, required to mitigate any events or accidents evaluated in the safety LCO, and analyses. RPV water inventory control is required in MODES 4 and 5 APPLICABILITY to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulated considered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems.

Instead, an event is postulated considered in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety. Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy.

(continued)

HATCH UNIT 1 B 3.3-126 REVISION 98

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE The specific Applicable Safety Analyses, LCO, and Applicability SAFETY ANALYSES, discussions are listed below on a Function by Function basis.

LCO, and APPLICABILITY Core Spray and Low Pressure Coolant Injection Systems (continued) 1.a, 2.a Reactor Steam Dome Pressure - Low (Injection Permissive)

Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions. This function ensures that, prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems maximum design pressure. While it is assured during MODES 4 and 5 that the reactor steam dome pressure will be below the ECCS maximum design pressure, the Reactor Steam Dome Pressure - Low signals are assumed to be OPERABLE and capable of permitting initiation of the ECCS.

The Reactor Steam Dome Pressure - Low signals are initiated from four pressure transmitters that sense the reactor dome pressure. The transmitters are connected to four trip units. The outputs of the trip units are connected to relays whose contacts are arranged in a one-out-of-two taken twice logic.

The Allowable Value is low enough to prevent overpressuring the equipment in the low pressure ECCS.

The four channels of Reactor Steam Dome Pressure - Low Function are required to be OPERABLE in MODES 4 and 5 when ECCS manual initiation is required to be OPERABLE by LCO 3.5.2.

1.b, 2.b Core Spray and Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass)

The minimum flow instruments are provided to protect the associated low pressure ECCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump.

One flow transmitter per ECCS subsystem is used to detect the associated subsystems flow rates. The logic is arranged such that each transmitter causes its associated minimum flow valve to open.

The logic will close the minimum flow valve once the closure setpoint is exceeded. The LPCI minimum flow valves are time delayed such that the valves will not open for 10 seconds after the switches detect low flow. The time delay is provided to limit reactor vessel inventory loss during the startup of the Residual Heat Removal (RHR) shutdown cooling mode.

(continued)

HATCH UNIT 1 B 3.3-127 REVISION 98

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE 1.b, 2.b Core Spray and Low Pressure Coolant Injection Pump SAFETY ANALYSES, Discharge Flow - Low (Bypass) (continued)

LCO, and APPLICABILITY The Pump Discharge Flow - Low Allowable Values are high enough to ensure that the pump flow rate is sufficient to protect the pump, yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core.

One channel of the Pump Discharge Flow - Low Function is required to be OPERABLE in MODES 4 and 5 when the associated Core Spray or LPCI pump is required to be OPERABLE by LCO 3.5.2 to ensure the pumps are capable of injecting into the Reactor Pressure Vessel when manually initiated.

A note is added to TS Table 3.3.5.2-1 for Function 2.b to clarify the intent of allowing credit for an OPERABLE Low Pressure Coolant Injection subsystem when it is aligned and operating in the decay heat removal mode of RHR. This note is appropriate since the associated RHR pump minimum flow valve (while operating in the decay heat removal mode) is closed and deactivated to prevent inadvertent vessel drain down events.

RHR System Isolation 31.a - Reactor Vessel Water Level - Low, Level 3 The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low, Level 3 Function associated with RHR System isolation may be credited for automatic isolation of penetration flow paths associated with the RHR System.

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. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low, Level 3 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low, Level 3 Allowable Value was chosen to be the same as the Primary Containment Isolation Instrumentation Reactor Vessel Water Level - Low, Level 3 Allowable Value (LCO 3.3.6.1), since the capability to cool the fuel may be threatened.

(continued)

HATCH UNIT 1 B 3.3-128 REVISION 98

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE 31.a - Reactor Vessel Water Level - Low, Level 3 (continued)

SAFETY ANALYSES, LCO, and The Reactor Vessel Water Level - Low, Level 3 Function is only APPLICABILITY required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

This Function isolates the Group 11 valves.

Reactor Water Cleanup (RWCU) System Isolation 42.a - Reactor Vessel Water Level - Low Low, Level 2 The definition of Drain Time allows crediting the closing penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low Low, Level 2 Function associated with RWCU System isolation may be credited for automatic isolation of penetration flow paths associated with the RWCU System.

Reactor Vessel Water Level - Low Low, Level 2 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.

While four channels (two channels per trip system) of the Reactor Vessel Water Level -- Low Low, Level 2 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low Low, Level 2 Allowable Value was chosen to be that same as the ECCS Reactor Vessel Water Level - Low Low, Level 2 Allowable Value (LCO 3.3.5.1), since the capability to cool the fuel may be threatened.

The Reactor Vessel Water Level - Low Low, Level 2 Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

This Function isolates the Group 5 valves.

(continued)

HATCH UNIT 1 B 3.3-129 REVISION 98

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES (continued)

ACTIONS A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control Instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control Instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control Instrumentation channel.

A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.2-1. The applicable Condition referenced in the Table is Function dependent. Each time a channel is discovered inoperable, Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition.

BA.1, A.2.1, and BA.2.2 RHR System Isolation, Reactor Vessel Water Level - Low Level 3, and Reactor Water Cleanup System, Reactor Vessel Water Level -

Low Low, Level 2 functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating Drain Time. If the instrumentation is inoperable, Required Action BA.1 directs animmediate action to place the channel in trip. With the inoperable channel in the tripped condition, the remaining channel will isolate the penetration flow path on low water level. If both channels are inoperable and placed in trip, the penetration flow path will be isolated. Alternatively, Required Action A.2.1 requires immediate declaration that the associated penetration flow path(s) to be immediately declared are incapable of automatic isolation. Required Action BA.2.2 directs initiating action to calculateion of DRAIN TIME.

The calculation cannot credit automatic isolation of the affected penetration flow paths.

(continued)

HATCH UNIT 1 B 3.3-130 REVISION 98

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES ACTIONS C.1 (continued)

Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions. If the permissive is inoperable, manual initiation of ECCS is prohibited. Therefore, the permissive must be placed in the trip condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . With the permissive in the trip condition, manual initiation may be performed. Prior to placing the permissive in the tripped condition, the operator can take manual control of the pump and the injection valve to inject water into the RPV.

The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in trip.

D.1 If a Core Spray or Low Pressure Coolant Injection Pump Discharge Flow - Low bypass function is inoperable, there is a risk that the associated low pressure ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the pump and the injection valve to ensure the pump does not overheat. If a manual initiation function is inoperable, the ECCS subsystem pumps can be started manually and the valves can be opened manually, but this is not the preferred condition.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The Completion Time is appropriate given the ability to manually start the ECCS pumps and open the injection valves and to manually ensure the pump does not overheat.

E.1 With the Required Action and associated Completion Time of Condition C or D not met, the associated low pressure ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

(continued)

HATCH UNIT 1 B 3.3-131 REVISION 98

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES (continued)

SURVEILLANCE The following SRs apply to As noted in the beginning of the SRs, the SRs for each RPV Water REQUIREMENTS Inventory instrumentation Function are found in the SRs column of Table 3.3.5.2-1.

SR 3.3.5.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK guarantees that undetected outright channel failure is limited; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL FUNCTIONAL TEST.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

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

The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.

(continued)

HATCH UNIT 1 B 3.3-132 REVISION 98

LOP Instrumentation B 3.3.8.1 BASES APPLICABLE errors (e.g., drift). The trip setpoints derived in this manner provide SAFETY ANALYSES, adequate protection because instrumentation uncertainties, process LCO, and effects, calibration tolerances, instrument drift, and severe APPLICABILITY environment errors (for channels that must function in harsh (continued) environments as defined by 10 CFR 50.49) are accounted for.

The Specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.

1. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage)

Loss of voltage on a 4.16 kV emergency bus indicates that offsite power may be completely lost to the respective emergency bus and is unable to supply sufficient power for proper operation of the applicable equipment. Therefore, the power supply to the bus is transferred from offsite power to DG power when the voltage on the bus drops below the Loss of Voltage Function Allowable Values (loss of voltage with a short time delay). This ensures that adequate power will be available to the required equipment.

The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that power is available to the required equipment.

Two channels of 4.16 kV Emergency Bus Undervoltage (Loss of Voltage) Function per associated emergency bus are only required to be OPERABLE when the associated DG is required to be OPERABLE to ensure that no single instrument failure can preclude the DG function. (Refer to LCOs 3.8.1, "AC Sources - Operating," and 3.8.2, "AC Sources - Shutdown," for Applicability Bases for the DGs.)

2. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

A reduced voltage condition on a 4.16 kV emergency bus indicates that, while offsite power may not be completely lost to the respective emergency bus, available power may be insufficient for starting large ECCS motors without risking damage to the motors that could disable the ECCS Function. Therefore, power supply to the bus is transferred from offsite power to onsite DG power when the voltage on the bus drops below the Degraded Voltage Function Allowable Values (degraded voltage with a time delay). This ensures that adequate power will be available to the required equipment.

(continued)

HATCH UNIT 1 B 3.3-199 REVISION 109

LOP Instrumentation B 3.3.8.1 BASES APPLICABLE 2. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

SAFETY ANALYSES, (continued)

LCO, and APPLICABILITY The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that sufficient power is available to the large ECCS motors. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that sufficient power is available to the required equipment.

Two channels of 4.16 kV Emergency Bus Undervoltage (Degraded Voltage) Function per associated bus are only required to be OPERABLE when the associated DG is required to be OPERABLE to ensure that no single instrument failure can preclude the DG function.

Refer to LCO 3.8.1 and LCO 3.8.2 for Applicability Bases for the DGs.

ACTIONS A Note has been provided to modify the ACTIONS related to LOP instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable LOP instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable LOP instrumentation channel.

A.1 With one or more required channels inoperable, the Function does not maintain initiation capability for the associated emergency bus.

Therefore, only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore the inoperable channel to OPERABLE status. The Required Action does not allow placing a channel in trip since this action will result in a DG initiation.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

(continued)

HATCH UNIT 1 B 3.3-200 REVISION 109

LOP Instrumentation B 3.3.8.1 BASES ACTIONS B.1 (continued)

If any Required Action and associated Completion Time are not met, the associated Function does not maintain initiation capability for the associated emergency bus. Therefore, the associated DG(s) is declared inoperable immediately. This requires entry into applicable Conditions and Required Actions of LCO 3.8.1 and LCO 3.8.2, which provides appropriate actions for the inoperable DG(s).

SURVEILLANCE As noted at the beginning of the SRs, the SRs are applicable to each REQUIREMENTS LOP instrumentation Function in Table 3.3.8.1-1. The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains initiation capability. Functions 1 and 2 maintain initiation capability provided that, for 2 of the 3 emergency buses, the following can be initiated by the Function: DG start, disconnect from the offsite power source, DG output breaker closure, load shed, and activation of the ECCS pump power permissive. Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.

SR 3.3.8.1.1 Deleted.

SR 3.3.8.1.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

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

SR 3.3.8.1.3 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

(continued)

HATCH UNIT 1 B 3.3-201 REVISION 109

LOP Instrumentation B 3.3.8.1 BASES SURVEILLANCE SR 3.3.8.1.3 (continued)

REQUIREMENTS CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations, consistent with the plant specific setpoint methodology.

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

SR 3.3.8.1.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel.

The system functional testing performed in LCO 3.8.1 and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety functions.

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

REFERENCES 1. FSAR, Section 8.4.

2. FSAR, Section 4.8.

3. FSAR, Section 6.5.

4. Unit 2 FSAR, Chapter 15.

HATCH UNIT 1 B 3.3-202 REVISION 109

RPV Water Inventory Control B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not SAFETY ANALYSES required to mitigate any events or accidents evaluated in the safety analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material to the environment should an unexpected draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulated considered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems.

Instead, an event is considered in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, an event that creates a drain path through multiple vessel penetrations located below top of active fuel, such as loss of normal power, or a single human error). It is assumed, based on engineering judgement, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level.

As discussed in References 3, 4, 5, 6, and 7, operating experience has shown RPV water inventory to be significant to public health and safety. Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO The RPV water level must be controlled in MODES 4 and 5 to ensure that if an unexpected draining event should occur, the reactor coolant water level remains above the top of the active irradiated fuel as required by Safety Limit 2.1.1.3.

The Limiting Condition for Operation (LCO) requires the DRAIN TIME of RPV water inventory to the TAF to be 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

(continued)

HATCH UNIT 1 B 3.5-16 REVISION 98

RPV Water Inventory Control B 3.5.2 BASES LCO A DRAIN TIME of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and (continued) initiate action to mitigate unexpected draining of reactor coolant. An event that could cause loss of RPV water inventory and result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

One low pressure ECCS injection/spray subsystem is required to be OPERABLE and capable of being manually aligned and started from the control room to provide defense-in-depth should an unexpected draining event occur. OPERABILITY of the ECCS injection/spray subsystem includes any necessary valves, instrumentation, or controls needed to manually align and start the subsystem from the control room. A low pressure ECCS injection/spray subsystem consists of either one Core Spray (CS) subsystem or one Low Pressure Coolant Injection (LPCI) subsystem. Each CS subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or condensate storage tank (CST) to the RPV. Each LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV. In MODES 4 and 5, the RHR System cross tie valve is not required to be closed. Management of gas voids is important to ECCS injection/spray subsystem OPERABILITY. The necessary portions of the Plant Service Water System are also required to provide appropriate cooling to each required ECCS subsystem.

One LPCI subsystem may be aligned for decay heat removal and considered OPERABLE for the ECCS function, if it can be manually realigned (remote or local) to the LPCI mode and is not otherwise inoperable. Because of the restrictions on DRAIN TIME, sufficient time will be available following an unexpected draining event to manually align and initiate LPCI subsystem operation to maintain RPV water inventory prior to the RPV water level reaching the TAF.

APPLICABILITY RPV water inventory control is required in MODES 4 and 5.

Requirements on water inventory control in other MODES are contained in LCOs in Section 3.3, Instrumentation, and other LCOs in Section 3.5, ECCS, RCIC, and RPV Water Inventory Control, and RCIC System. RPV water inventory control is required to protect Safety Limit 2.1.1.3 which is applicable whenever irradiated fuel is in the reactor vessel.

(continued)

HATCH UNIT 1 B 3.5-17 REVISION 98

RPV Water Inventory Control B 3.5.2 BASES ACTIONS C.1, C.2, and C.3 (continued) secondary containment boundary are preplanned and necessary materials are available. The secondary containment boundary is considered established when the required Standby Gas Treatment (SGT) subsystem(s) are capable of maintaining a negative pressure in the secondary containment with respect to the environment.

Verification that the secondary containment boundary can be established must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The required verification is an administrative activity and does not require manipulation or testing of equipment. Secondary containment penetration flow paths form a part of the secondary containment boundary. Required Action C.2 requires verification of the capability to isolate each secondary containment penetration flow path in less than the DRAIN TIME. The required verification confirms actions to isolate the secondary containment penetration flow paths are preplanned and necessary materials are available. Power operated valves are not required to receive automatic isolation signals if they can be closed manually within the required time. Verification that the secondary containment penetration flow paths can be isolated must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The required verification is an administrative activity and does not require manipulation or testing of equipment.

The required SGT subsystem(s) (dependent on secondary containment configuration, refer to Reference 2; single failure protection is not required while in this ACTION) are capable of maintaining the secondary containment at a negative pressure with respect to the environment and filter gaseous releases. Required Action C.3 requires verification of the capability to place the required SGT subsystem(s) in operation in less than the DRAIN TIME. The required verification confirms actions to place the required SGT subsystem(s) in operation are preplanned and necessary materials are available. Verification that the SGT subsystem(s) can be placed in operation must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The required verification is an administrative activity and does not require manipulation or testing of equipment.

Required Actions C.1, C.2, and C.3 are considered to be met when secondary containment, secondary containment penetrations, and the Standby Gas Treatment System are OPERABLE in accordance with LCO 3.6.4.1, LCO 3.6.4.2, and LCO 3.6.4.3.

D.1, D.2. D.3, and D.4 With the DRAIN TIME less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , mitigating actions are (continued)

HATCH UNIT 1 B 3.5-19 REVISION 98

RPV Water Inventory Control B 3.5.2 BASES ACTIONS D.1, D.2, D.3, and D.4 (continued)

Required Action D.1 requires immediate action to establish an additional method of water injection augmenting the ECCS injection/spray subsystem required by the LCO. The additional method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur. The Note to Required Action D.1 states that either the ECCS injection/spray subsystem or the additional method of water injection must be capable of operating without offsite electrical power. The additional method of water injection may be manually initiated and may consist of one or more systems or subsystems. The additional method of water injection must be able to access water inventory capable of being injected to maintain the RPV water level above the TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The additional method of water injection and the ECCS injection/spray subsystem may share all or part of the same water sources. If recirculation of injected water would occur, it may be credited in determining the required water volume.

Should a draining event lower the reactor coolant level to below the TAF, there is potential for damage to the reactor fuel cladding and release of radioactive material. Additional actions are taken to ensure that radioactive material will be contained, diluted, and processed prior to being released to the environment.

The secondary containment provides a control volume in which fission products can be contained, diluted, and processed prior to release to the environment. Required Action D.2 requires that actions be immediately initiated to establish the secondary containment boundary [at least including: the Unit 1 reactor building zone if in MODE 4; or the common refueling floor zone if in MODE 5]. With the secondary containment boundary established, the required SGT subsystem(s) are capable of maintaining a negative pressure in the secondary containment with respect to the environment.

The secondary containment penetrations form a part of the secondary containment boundary. Required Action D.3 requires that actions be immediately initiated to verify that each secondary containment penetration flow path is isolated or to verify that it can be automatically or manually isolated from the control room.

The required SGT subsystem(s) (dependent on secondary containment configuration, refer to Reference 2; single failure protection is not required while in this ACTION) are capable of maintaining the secondary containment at a negative pressure with respect to the environment and filter gaseous releases.

(continued)

HATCH UNIT 1 B 3.5-21 REVISION 98

RPV Water Inventory Control B 3.5.2 BASES ACTIONS D.1, D.2, D.3, and D.4 (continued)

Required Action D.4 requires that actions be immediately initiated to verify that the required SGT subsystem(s) is capable of being placed in operation. The required verification is an administrative activity and does not require manipulation or testing of equipment.

Required Actions D.2, D.3, and D.4 are considered to be met when secondary containment, secondary containment penetrations, and the Standby Gas Treatment System are OPERABLE in accordance with LCO 3.6.4.1, LCO 3.6.4.2, and LCO 3.6.4.3.

E.1 If the Required Actions and associated Completion times of Conditions C or D are not met or if the DRAIN TIME is less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , actions must be initiated immediately to restore the DRAIN TIME to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In this condition, there may be insufficient time to respond to an unexpected draining event to prevent the RPV water inventory from reaching the TAF. Note that Required Actions D.1, D.2, D.3, and D.4 are also applicable when DRAIN TIME is less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE SR 3.5.2.1 REQUIREMENTS This Surveillance verifies that the DRAIN TIME of RPV water inventory to the TAF is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The period of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate draining of reactor coolant. Loss of RPV water inventory that would result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

The definition of DRAIN TIME states that realistic cross-sectional areas and drain rates are used in the calculation. A realistic drain rate may be determined using a single, step-wise, or integrated calculation considering the changing RPV water level during a draining event.

For a Control Rod RPV penetration flow path with the Control Rod Drive Mechanism removed and not replaced with a blank flange, the realistic cross-sectional area is based on the control rod blade seated in the control rod guide tube. If the control rod blade will be raised from the penetration to adjust or verify seating of the blade, the exposed cross-sectional area of the RPV penetration flow path is used.

(continued)

HATCH UNIT 1 B 3.5-22 REVISION 98

RPV Water Inventory Control B 3.5.2 The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed positionclosed and administratively controlled, blank flanges, or other (continued)

HATCH UNIT 1 B 3.5-23 REVISION 98

RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 (continued)

REQUIREMENTS devices that prevent flow of reactor coolant through the penetration flow paths. A blank flange or other bolted device must be connected with a sufficient number of bolts to prevent draining in the event of an Operating Basis Earthquake. Normal or expected leakage from closed systems or past isolation devices is permitted. Determination that a system is intact and closed or isolated must consider the status of branch lines and ongoing plant maintenance and testing activities.

The Residual Heat Removal (RHR) Shutdown Cooling System is only considered an intact closed system when misalignment issues (Reference 8) have been precluded by functional valve interlocks or by isolation devices, such that redirection of RPV water out of an RHR subsystem is precluded. Further, RHR Shutdown Cooling System is only considered an intact closed system if its controls have not been transferred to Remote Shutdown, which disables that interlocks and isolation signals.

The exclusion of a single penetration flow paths, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME must should consider the potential effects of temporary alterations in support of maintenance a single operator error or initiating event on items supporting maintenance and testing (rigging, scaffolding, temporary shielding, piping plugs, snubber removal, freeze seals, etc.). If reasonable controls are implemented to prevent If failure of such items temporary alterations from could result and would causing e a draining event from a closed system or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered.

Reasonable controls include, but are not limited to, the penetration flow path may not be excluded from the DRAIN TIME calculation.

controls consistent with the guidance in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4, NUMARC 91-06, Guidelines for Industry Actions to Access Shutdown Management, or commitments to NUREG-0612, Control of Heavy Loads at Nuclear Power Plants.

Surveillance Requirement 3.0.1 requires SRs to be met between performances. Therefore, any changes in plant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined.

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

(continued)

HATCH UNIT 1 B 3.5-24 REVISION 98

RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.2 and SR 3.5.2.3 (continued)

REQUIREMENTS The required CS System is considered OPERABLE when the suppression pool water level is 146 inches or when it can take suction from the CST, and the CST water level is sufficient to provide the required NPSH for the CS pump. Therefore, a verification that either the suppression pool water level is 146 inches or that a required CS is aligned to take suction from the CST and the CST contains 150,000 gallons of water, equivalent to 13 ft, ensures that the CS System can supply at least 50,000 gallons of makeup water to the RPV. The CS suction is uncovered at the 100,000 gallon level.

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

SR 3.5.2.4 The Bases provided for SR 3.5.1.1 are applicable to SR 3.5.2.4.

SR 3.5.2.5 DeletedVerifying the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow paths provides assurance that the proper flow paths will be available for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

In MODES 4 and 5, the RHR System may operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Therefore, RHR valves that are required for LPCI subsystem operation may be aligned for decay heat removal. Therefore, this SR is modified by a Note 1 that allows a required LPCI subsystem of the RHR System to be considered OPERABLE for the ECCS function if all the required valves in the LPCI flow path can be manually realigned (remote or local) to allow injection into the RPV, and the system is not otherwise inoperable.

(continued)

HATCH UNIT 1 B 3.5-26 REVISION 98

RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.5 (continued)

REQUIREMENTS This will ensure adequate core cooling if an inadvertent RPV draindown should occur.

The Surveillance is also modified by a Note 2 which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual who can rapidly close the system vent flow path if directed.

SR 3.5.2.6 Verifying that the required ECCS injection/spray subsystem can be manually aligned, and the pump started and operated for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This SR is modified by two Notes. Note 1 states that Testing testing the ECCS injection/spray subsystem may be done through the test return recirculation line is necessary to avoid overfilling the refueling cavity. Note 2 states that credit for meeting the SR may be taken for normal system operation that satisfies the SR, such as using RHR mode of LPCI for 10 minutes. The minimum operating time of 10 minutes was based on engineering judgement.

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

SR 3.5.2.7 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below that TAF should an unexpected draining event occur.

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

SR 3.5.2.8 The required ECCS subsystem shall be capable of being manually operated. This Surveillance verifies that the a required CS or LPCI subsystem (including the associated pump and valve(s)) can be manually aligned and started from the control room, including any HATCH UNIT 1 B 3.5-27 REVISION 98

RPV Water Inventory Control B 3.5.2 necessary valve alignment, instrumentation, or controls, to transfer water from the suppression pool or CST to the RPV.operated to provide additional RPV Water Inventory, if needed.

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

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

HATCH UNIT 1 B 3.5-28 REVISION 98

RCIC System B 3.5.3 BASES SURVEILLANCE SR 3.5.3.3 and SR 3.5.3.4 (continued)

REQUIREMENTS Therefore, these SRs are modified by Notes that state the Surveillances are not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam pressure and flow are adequate to perform the test.

The 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed is sufficient to achieve stable conditions for testing and provides a reasonable time to complete the SR. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.3.5 The RCIC System is required to actuate automatically in order to verify its design function satisfactorily. This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of the RCIC System will cause the system to operate as designed, including actuation of the system throughout its emergency operating sequence; that is, automatic pump startup and actuation of all automatic valves to their required positions. This test also ensures the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.2 3 overlaps this Surveillance to provide complete testing of the assumed safety function.

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

This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

(continued)

HATCH UNIT 1 B 3.5-32 REVISION 98

PCIVs B 3.6.1.3 BASES ACTIONS D.1 (continued)

With the MSIV leakage rate not within limit, the assumptions of the safety analysis may not be met. Therefore, the leakage must be restored to within limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Restoration can be accomplished by isolating the penetration that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. When a penetration is isolated, the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable considering the time required to restore the leakage by isolating the penetration and the relative importance to the overall containment function.

E.1 and E.2 If any Required Action and associated Completion Time cannot be met in MODE 1, 2, or 3, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

HATCH UNIT 1 B 3.6-21 REVISION 98

AC Sources - Shutdown B 3.8.2 BASES LCO transmission network and the onsite Class 1E Electrical Distribution (continued) System capable of supplying power to the required LPCI valve load center must be OPERABLE. The circuit can be any of the Unit 2 circuits supplying the 2E and 2G ESF buses and the Unit 1 circuit supplying the 1F ESF bus. Also, one DG capable of supplying power to the required LPCI valve load center must be OPERABLE. The DG can be any one of the Unit 2 DGs (i.e., 2A and 2C DGs) and the swing DG (i.e., DG 1B). It is preferable to use the Unit 2 circuit and DG to supply power to the LPCI valve load center, since in the case of an LOSP on both units, one LPCI valve load center would be without power if the swing DG was aligned to the opposite unit, thereby rendering one LPCI subsystem inoperable. The Unit 1 RCIC steam supply valve is powered from the same source as the Division II LPCI valve load center for 10 CFR 50, Appendix R design considerations.

The qualified offsite circuits must be capable of maintaining rated frequency and voltage while connected to their respective ESF buses, and of accepting required loads during an accident. Qualified offsite circuits are those that are described in the FSAR and are part of the licensing basis for the unit. The Unit 1 and Unit 2 offsite circuits consist of incoming breaker and disconnect to the 1C ,1D, or 1E and the 2C, 2D, or 2E startup auxiliary transformers (SATs), associated 1C, 1D, or 1E and 2C, 2D, or 2E SATs, and the respective circuit path including feeder breakers to all 4.16 kV ESF buses required by LCO 3.8.8. (However, for design purposes, the offsite circuit excludes the feeder breakers to each 4.16 kV ESF bus).

The required DGs must be capable of being manually started,starting, accelerating to rated frequency and voltage, connecting to their respective ESF bus on detection of bus undervoltage, and accepting required loads. This sequence must be accomplished within 12 seconds. Each DG must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with engine hot and DG in standby with engine at ambient conditions. Additional DG capabilities must be demonstrated to meet required Surveillances, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode.

Proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY.

(continued)

HATCH UNIT 1 B 3.8-44 REVISION 109

AC Sources - Shutdown B 3.8.2 BASES ACTIONS A.2.1, A.2.2, A.2.3, B.1, B.2, and B.3 (continued)

With one or more offsite circuits not available to all required 4160 V ESF buses, the option still exists to declare all required features inoperable (per Required Action A.1). Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With one or more required DGs inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power.

Pursuant to LOC 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A have been modified by a Note to indicate that when Condition A is entered with no AC power to any required ESF bus, ACTIONS for LCO 3.8.8 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit whether or not a bus is de-energized. LCO 3.8.8 provides the appropriate restrictions for the situation involving a de-energized bus.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.6 is not required to be met since only one Unit 1 and one Unit 2 offsite circuits are required to be OPERABLE. SR 3.8.1.5, SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.13, SR 3.8.1.16, and SR 3.8.1.17 are not required to be met because DG start and load within a specified time and response on an offsite power or ECCS initiation signal is not required. SR 3.8.1.15 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods of HATCH UNIT 1 B 3.8-46 REVISION 85

AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE SR 3.8.2.1 (continued)

REQUIREMENTS being synchronized to the offsite circuit. SR 3.8.1.18 is excepted because starting independence is not required with the DG(s) that is not required to be OPERABLE. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

This SR is modified by a Note which precludes. The reason for the Note is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs, and to preclude de-energizing a required 4160 V ESF bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit(s) and the DG(s). It is the intent that these SRs must still be capable of being met, but actual performance is not required.

This Surveillance is provided to direct that the appropriate Surveillances for the required Unit 2 DG and offsite circuit are governed by the Unit 2 Technical Specifications. Performance of the applicable Unit 2 Surveillances will satisfy both any Unit 2 requirements, as well as satisfying this Unit 1 Surveillance requirement. The Frequency required by the applicable Unit 2 SR also governs performance of that SR for both Units.

REFERENCES 1. NRC No.93-102, "Final Policy Statement on Technical Specification Improvements," July 23, 1993.

HATCH UNIT 1 B 3.8-47 REVISION 85

RPV Water Inventory Control Instrumentation B 3.3.5.2 B 3.3 INSTRUMENTATION B 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSS) for variables that have significant safety functions. LSSS are defined by the regulation as Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded. The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is not exceeded.

Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The actual settings for the automatic isolation channels are the same as those established for the same functions in MODES 1, 2, and 3 in LCO 3.3.5.1, Emergency Core Cooling System (ECCS) Instrumentation, or LCO 3.3.6.1, Primary Containment Isolation Instrumentation.

With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur.

Under the definition of DRAIN TIME, some penetration flow paths may be excluded from the DRAIN TIME calculation if they will be isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation.

The purpose of the RPV Water Inventory Control Instrumentation is to support the requirements of LCO 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control, and the definition of DRAIN TIME.

There are functions that are required for manual initiation or operation (continued)

HATCH UNIT 2 B 3.3-125 REVISION 110

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES BACKGROUND of the ECCS injection/spray subsystem required to be OPERABLE by (continued) LCO 3.5.2 and other functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

The RPV Water Inventory Control Instrumentation supports operation of core spray (CS) and low pressure coolant injection (LPCI). The equipment involved with each of these systems is described in the Bases for LCO 3.5.2.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not SAFETY ANALYSES, required to mitigate any events or accidents evaluated in the safety LCO, and analyses. RPV water inventory control is required in MODES 4 and 5 APPLICABILITY to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur.

A doubled-ended guillotine break of the Reactor Coolant System (RCS) is not postulated considered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is postulated considered in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety. Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy.

(continued)

HATCH UNIT 2 B 3.3-126 REVISION 110

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE The specific Applicable Safety Analyses, LCO, and Applicability SAFETY ANALYSES, discussions are listed below on a Function by Function basis.

LCO, and APPLICABILITY Core Spray and Low Pressure Coolant Injection Systems (continued) 1.a, 2.a. Reactor Steam Dome Pressure - Low (Injection Permissive)

Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions. This function ensures that, prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems maximum design pressure. While it is assured during MODES 4 and 5 that the reactor steam dome pressure will be below the ECCS maximum design pressure, the Reactor Steam Dome Pressure - Low signals are assumed to be OPERABLE and capable of permitting initiation of the ECCS.

The Reactor Steam Dome Pressure - Low signals are initiated from four pressure transmitters that sense the reactor dome pressure. The transmitters are connected to four trip units. The outputs of the trip units are connected to relays whose contacts are arranged in a one-out-of-two taken twice logic.

The Allowable Value is low enough to prevent overpressuring the equipment in the low pressure ECCS.

The four channels of Reactor Steam Dome Pressure - Low Function are required to be OPERABLE in MODES 4 and 5 when ECCS manual initiation is required to be OPERABLE by LCO 3.5.2.

1.b, 2.b Core Spray and Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass)

The minimum flow instruments are provided to protect the associated low pressure ECCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump.

One flow transmitter per ECCS subsystem is used to detect the associated subsystems flow rates. The logic is arranged such that each transmitter causes its associated miniumum flow valve to open.

The logic will close the minimum flow valve once the closure setpoint is exceeded. The LPCI minimum flow valves are time delayed such (continued)

HATCH UNIT 2 B 3.3-127 REVISION 110

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE 1.b, 2.b Core Spray and Low Pressure Coolant Injection Pump SAFETY ANALYSES Discharge Flow - Low (Bypass) (continued)

LCO, and APPLICABILITY that the valves will not open for 10 seconds after the switches detect low flow. The time delay is provided to limit reactor vessel inventory loss during the startup of the Residual Heat Removal (RHR) shutdown cooling mode.

The Pump Discharge Flow - Low Allowable Values are high enough to ensure that the pump flow rate is sufficient to protect the pump, yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core.

One channel of the Pump Discharge Flow - Low Function is required to be OPERABLE in MODES 4 and 5 when the associated Core Spray or LPCI pump is required to be OPERABLE by LCO 3.5.2 to ensure the pumps are capable of injecting into the Reactor Pressure Vessel when manually initiated.

A note is added to TS Table 3.3.5.2-1 for Function 2.b to clarify the intent of allowing credit for an OPERABLE Low Pressure Coolant Injection subsystem when it is aligned and operating in the decay heat removal mode of RHR. This note is appropriate since the associated RHR pump minimum flow valve (while operating in the decay heat removal mode) is closed and deactivated to prevent inadvertent vessel drain down events.

RHR System Isolation 31.a - Reactor Vessel Water Level - Low, Level 3 The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low, Level 3 Function associated with RHR System isolation may be credited for automatic isolation of penetration flow paths associated with the RHR System.

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. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low, Level 3 Function are available, only two channels (all in (continued)

HATCH UNIT 2 B 3.3-128 REVISION 110

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE 31.a - Reactor Vessel Water Level - Low, Level 3 (continued)

SAFETY ANALYSES LCO, and the same trip system) are required to be OPERABLE.

APPLICABILITY The Reactor Vessel Water Level - Low, Level 3 Allowable Value was chosen to be the same as the Primary Containment Isolation Instrumentation Reactor Vessel Water Level - Low, Level 3 Allowable Value (LCO 3.3.6.1), 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 when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

This Function isolates the Group 11 valves.

Reactor Water Cleanup (RWCU) System Isolation 42.a - Reactor Vessel Water Level - Low Low, Level 2 The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low Low, Level 2 Function associated with RWCU System isolation may be credited for automatic isolation of penetration flow paths associated with the RWCU System.

Reactor Vessel Water Level - Low Low, Level 2 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.

While four channels (two channels per trip system) of the Reactor Vessel Water Level -- Low Low, Level 2 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low Low, Level 2 Allowable Value was chosen to be the same as the ECCS Reactor Vessel Water Level

- Low Low, Level 2 Allowable Value (LCO 3.3.5.1), since the capability to cool the fuel may be threatened.

The Reactor Vessel Water Level - Low Low, Level 2 Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

(continued)

HATCH UNIT 2 B 3.3-129 REVISION 110

RPV Water Inventory Control Instrumentation B 3.3.5.2 This Function isolates the Group 5 valves.

BASES (continued)

ACTIONS A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control instrumentation channel.

A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.2-1. The applicable Condition referenced in the Table is Function dependent. Each time a channel is discovered to be inoperable, Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition.

BA.1, A.2.1, and BA.2.2 RHR System Isolation, Reactor Vessel Water Level - Low Level 3, and Reactor Water Cleanup System, Reactor Vessel Water Level -

Low Low, Level 2 functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating Drain Time. If the instrumentation is inoperable, Required Action BA.1 directs an immediate declaration that immediate action to place the channel in trip. With the inoperable channel in the tripped condition, the remaining channel will isolate the penetration flow path on low water level. If both channels are inoperable and placed in trip, the penetration flow path will be isolated. Alternatively, Required Action A.2.1 requires the associated penetration flow path(s) to be immediately declared are incapable of automatic isolation. Required Action BA.2.2 directs initiating action to calculateion of DRAIN TIME.

The calculation cannot credit automatic isolation of the affected penetration flow paths.

C.1 Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection (continued)

HATCH UNIT 2 B 3.3-130 REVISION 110

RPV Water Inventory Control Instrumentation B 3.3.5.2 functions. If the permissive is inoperable, manual initiation of ECCS is prohibited. Therefore, the permissive must be placed in the trip condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . With the permissive in the trip condition, manual initiation may be performed. Prior to placing the permissive in the tripped condition, the operator can take manual control of the pump and the injection valve to inject water into the RPV.

(continued)

HATCH UNIT 2 B 3.3-131 REVISION 110

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES ACTIONS C.1 (continued)

The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in trip.

D.1 If a Core Spray or Low Pressure Coolant Injection Pump Discharge Flow - Low bypass function is inoperable, there is a risk that the associated low pressure ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the pump and the injection valve to ensure the pump does not overheat. If a manual initiation function is inoperable, the ECCS subsystem pumps can be started manually and the valves can be opened manually, but this is not the preferred condition.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The Completion Time is appropriate given the ability to manually start the ECCS pumps and open the injection valves and to manually ensure the pump does not overheat.

E.1 With the Required Action and associated Completion Time of Condition C or D not met, the associated low pressure ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

(continued)

HATCH UNIT 2 B 3.3-132 REVISION 110

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES (continued)

SURVEILLANCE The following SRs apply to As noted in the beginning of the SRs, the SRs for each RPV Water REQUIREMENTS Inventory Control instrumentation Function are found in the SRs column of Table 3.3.5.2-1.

SR 3.3.5.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK guarantees that undetected outright channel failure is limited; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL FUNCTION TEST.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

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

The CHANNEL CHECK supplements less formal, but more frequent checks of channels during normal operational use of the displays associated with the channels required by the LCO.

SR 3.3.5.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance (continued)

HATCH UNIT 2 B 3.3-133 REVISION 110

LOP Instrumentation B 3.3.8.1 BASES APPLICABLE setpoints are then determined accounting for the remaining instrument SAFETY ANALYSES, errors (e.g., drift). The trip setpoints derived in this manner provide LCO, and adequate protection because instrumentation uncertainties, process APPLICABILITY effects, calibration tolerances, instrument drift, and severe (continued) environment errors (for channels that must function in harsh environments as defined by 10 CFR 50.49) are accounted for.

The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.

1. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage)

Loss of voltage on a 4.16 kV emergency bus indicates that offsite power may be completely lost to the respective emergency bus and is unable to supply sufficient power for proper operation of the applicable equipment. Therefore, the power supply to the bus is transferred from offsite power to DG power when the voltage on the bus drops below the Loss of Voltage Function Allowable Values (loss of voltage with a short time delay). This ensures that adequate power will be available to the required equipment.

The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that power is available to the required equipment.

Two channels of 4.16 kV Emergency Bus Undervoltage (Loss of Voltage) Function per associated emergency bus are only required to be OPERABLE when the associated DG is required to be OPERABLE to ensure that no single instrument failure can preclude the DG function. Refer to LCO 3.8.1, "AC Sources - Operating,"

and 3.8.2, "AC Sources - Shutdown," for Applicability Bases for the DGs.

2. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

A reduced voltage condition on a 4.16 kV emergency bus indicates that, while offsite power may not be completely lost to the respective emergency bus, available power may be insufficient for starting large ECCS motors without risking damage to the motors that could disable the ECCS function. Therefore, power supply to the bus is transferred from offsite power to onsite DG power when the voltage on the bus drops below the Degraded Voltage Function Allowable Values (continued)

HATCH UNIT 2 B 3.3-199 REVISION 121

LOP Instrumentation B 3.3.8.1 BASES APPLICABLE 2. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

SAFETY ANALYSES, (continued)

LCO, and APPLICABILITY (degraded voltage with a time delay). This ensures that adequate power will be available to the required equipment.

The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that sufficient power is available to the large ECCS motors. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that sufficient power is available to the required equipment.

Two channels of 4.16 kV Emergency Bus Undervoltage (Degraded Voltage) Function per associated bus are only required to be OPERABLE when the associated DG is required to be OPERABLE to ensure that no single instrument failure can preclude the DG function.

Refer to LCO 3.8.1 and LCO 3.8.2 for Applicability Bases for the DGs.

ACTIONS A Note has been provided to modify the ACTIONS related to LOP instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable LOP instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable LOP instrumentation channel.

A.1 With one or more required channels inoperable, the Function does not maintain initiation capability for the associated emergency bus.

Therefore, only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore the inoperable channel to OPERABLE status. The Required Action does not allow placing a channel in trip since this action will result in a DG initiation.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

(continued)

HATCH UNIT 2 B 3.3-200 REVISION 121

LOP Instrumentation B 3.3.8.1 BASES ACTIONS B.1 (continued)

If any Required Action and associated Completion Time are not met, the associated Function does not maintain initiation capability for the associated emergency bus. Therefore, the associated DG(s) is declared inoperable immediately. This requires entry into applicable Conditions and Required Actions of LCO 3.8.1 and LCO 3.8.2, which provides appropriate actions for the inoperable DG(s).

SURVEILLANCE As noted at the beginning of the SRs, the SRs are applicable to REQUIREMENTS each LOP instrumentation Function in Table 3.3.8.1-1. The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains initiation capability. Functions 1 and 2 maintain initiation capability provided that, for 2 of the 3 emergency buses, the following can be initiated by the Function: DG start, disconnect from the offsite power source, DG output breaker closure, load shed, and activation of the ECCS pump power permissive. Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.

SR 3.3.8.1.1 Deleted.

SR 3.3.8.1.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

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

SR 3.3.8.1.3 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for (continued)

HATCH UNIT 2 B 3.3-201 REVISION 121

LOP Instrumentation B 3.3.8.1 BASES SURVEILLANCE SR 3.3.8.1.3 (continued)

REQUIREMENTS instrument drifts between successive calibrations, consistent with the plant specific setpoint methodology.

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

SR 3.3.8.1.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel.

The system functional testing performed in LCO 3.8.1 and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety functions.

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

REFERENCES 1. FSAR, Section 8.3.1.

2. FSAR, Section 5.2.

3. FSAR, Section 6.3.

4. FSAR, Chapter 15.

(continued)

HATCH UNIT 2 B 3.3-202 REVISION 121

RPV Water Inventory Control B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not SAFETY ANALYSES required to mitigate any events or accidents evaluated in the safety analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material to the environment should an unexpected draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulated considered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems.

Instead, an event is considered in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, an event that creates a drain path through multiple vessel penetrations located below top of active fuel, such as loss of normal power, or a single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level.

As discussed in References 3, 4, 5, 6, and 7, operating experience has shown RPV water inventory to be significant to public health and safety. Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO The RPV water level must be controlled in MODES 4 and 5 to ensure that if an unexpected draining vent should occur, the reactor coolant water level remains above the top of the active irradiated fuel as required by Safety Limit 2.1.1.3.

The Limiting Condition for Operation (LCO) requires the DRAIN TIME of RPV water inventory to the TAF to be 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A DRAIN TIME (continued)

HATCH UNIT 2 B 3.5-17 REVISION 110

RPV Water Inventory Control B 3.5.2 BASES LCO of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to (continued) mitigate unexpected draining of reactor coolant. An event that could cause loss of RPV water inventory and result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

One low pressure ECCS injection/spray subsystems is required to be OPERABLE and capable of being manually aligned and started from the control room to provide defense-in-depth should an unexpected draining event occur. OPERABILITY of the ECCS injection/spray subsystem includes any necessary valves, instrumentation, or controls needed to manually align and start the subsystem from the control room. A low pressure ECCS injection/spray subsystem consists of either one Core Spray (CS) subsystem or one Low Pressure Coolant Injection (LPCI) subsystem.

Each CS subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or condensate storage tank (CST) to the RPV. Each LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV. In MODES 4 and 5, the RHR System cross tie valve is not required to be closed. Management of gas voids is important to ECCS injection/spray subsystem OPERABILITY. The necessary portions of the Plant Service Water System are also required to provide appropriate cooling to each required ECCS subsystem.

One LPCI subsystem may be aligned for decay heat removal and considered OPERABLE for the ECCS function, if it can be manually realigned (remote or local) to the LPCI mode and is not otherwise inoperable. Because of the restrictions on DRAIN TIME, sufficient time will be available following an unexpected draining event to manually align and initiate LPCI subsystem operation to maintain RPV water inventory prior to the RPV water level reaching the TAF.

APPLICABILITY RPV water inventory control is required in MODES 4 and 5.

Requirements on water inventory control in other MODES are contained in LCOs in Section 3.3, Instrumentation, and other LCOs in Section 3.5, ECCS, RCIC, and RPV Water Inventory Control, and RCIC System. RPV water inventory control is required to protect Safety Limit 2.1.1.3 which is applicable whenever irradiated fuel is in the reactor vessel.

(continued)

HATCH UNIT 2 B 3.5-18 REVISION 110

RPV Water Inventory Control B 3.5.2 BASES ACTIONS C.1, C.2, and C.3 (continued) secondary containment boundary are preplanned and necessary materials are available. The secondary containment boundary is considered established when the required Standby Gas Treatment (SGT) subsystem(s) are capable of maintaining a negative pressure in the secondary containment with respect to the environment.

Verification that the secondary containment boundary can be established must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The required verification is an administrative activity and does not require manipulation or testing of equipment. Secondary containment penetration flow paths form a part of the secondary containment boundary. Required Acton C.2 requires verification of the capability to isolate each secondary containment penetration flow path in less than the DRAIN TIME. The required verification confirms actions to isolate the secondary containment penetration flow paths are preplanned and necessary materials are available. Power operated valves are not required to receive automatic isolation signals if they can be closed manually within the required time. Verification that the secondary containment penetration flow paths can be isolated must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The required verification is an administrative activity and does not require manipulation or testing of equipment.

The required SGT subsystem(s) (dependent on secondary containment configuration, refer to Reference 2; single failure protection is not required while in this ACTION) are capable of maintaining the secondary containment at a negative pressure with respect to the environment and filter gaseous releases. Required Action C.3 requires verification of the capability to place the required SGT subsystem(s) in operation in less than the DRAIN TIME. The required verification confirms actions to place the required SGT subsystem(s) in operation and are preplanned and necessary materials are available. Verification that the required SGT subsystem(s) can be placed in operation must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The required verification is an administrative activity and does not require manipulation or testing of equipment.

Required Actions C.1, C.2, and C.3 are considered to be met when secondary containment, secondary containment penetrations, and the Standby Gas Treatment System are OPERABLE in accordance with LCO 3.6.4.1, LCO 3.6.4.2, and LCO 3.6.4.3.

D.1, D.2, D.3, and D.4 With the DRAIN TIME less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , mitigating actions are (continued)

HATCH UNIT 2 B 3.5-20 REVISION 110

RPV Water Inventory Control B 3.5.2 BASES ACTIONS D.1, D.2, D.3, and D.4 (continued) or refueling cavity should an unexpected draining event occur. The Note to Required Action D.1 states that either the ECCS injection/spray subsystem or the additional method of water injection must be capable of operating without offsite electrical power. The additional method of water injection may be manually initiated and may consist of one or more systems or subsystems. The additional method of water injection must be able to access water inventory capable of being injected to maintain the RPV water level above the TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The additional method of water injection and the ECCS injection/spray subsystem may share all or part of the same water sources. If recirculation of injected water would occur, it may be credited in determining the required water volume.

Should a draining event lower that reactor coolant level to below the TAF, there is potential for damage to the reactor fuel cladding and release of radioactive material. Additional actions are taken to ensure that radioactive material will be contained, diluted, and processed prior to being released to the environment.

The secondary containment provides a control volume in which fission products can be contained, diluted, and processed prior to release to the environment. Required Action D.2 requires that actions be immediately initiated to establish the secondary containment boundary

[at least including: the Unit 1 reactor building zone if in MODE 4; or the common refueling floor zone if in MODE 5]. With the secondary containment boundary established, the required SGT subsystem(s) are capable of maintaining a negative pressure in the secondary containment with respect to the environment.

The secondary containment penetrations form a part of the secondary containment boundary. Required Action D.3 requires that actions be immediately initiated to verify that each secondary containment penetration flow path is isolated or to verify that it can be automatically or manually isolated from the control room.

The required SGT subsystem(s) (dependent on secondary containment configuration, refer to Reference 2; single failure protection is not required while in this ACTION) are capable of maintaining the secondary containment at a negative pressure with respect to the environment and filter gaseous releases. Required Action D.4 requires that actions be immediately initiated to verify that the required SGT subsystem(s) is capable of being placed in operation. The required verification is an administrative activity and does not require manipulation or testing of equipment.

(continued)

HATCH UNIT 2 B 3.5-22 REVISION 110

RPV Water Inventory Control B 3.5.2 Required Actions D.2, D.3, and D.4 are considered to be met when secondary containment, secondary containment penetrations, and the Standby Gas Treatment System are OPERABLE in accordance with LCO 3.6.4.1, LCO 3.6.4.2, and LCO 3.6.4.3.

(continued)

HATCH UNIT 2 B 3.5-23 REVISION 110

RPV Water Inventory Control B 3.5.2 BASES ACTIONS E.1 (continued)

If the Required Actions and associated Completion times of Conditions C or D are not met or if the DRAIN TIME is less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , actions must be initiated immediately to restore the DRAIN TIME to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In this condition, there may be insufficient time to respond to an unexpected draining event to prevent the RPV water inventory from reaching the TAF. Note that Required Actions D.1, D.2, D3, and D4 are also applicable when DRAIN TIME is less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE SR 3.5.2.1 REQUIREMENTS This Surveillance verifies that the DRAIN TIME of RPV water inventory to the TAF is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The period of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate draining of reactor coolant. Loss of RPV water inventory that would result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

The definition of DRAIN TIME states that realistic cross-sectional areas and drain rates are used in the calculation. A realistic drain rate may be determined using a single, step-wise, or integrated calculation considering the changing RPV water level during a draining event.

For a Control Rod RPV penetration flow path with the Control Rod Drive Mechanism removed and not replaced with a blank flange, the realistic cross-sectional area is based on the control rod blade seated in the control rod guide tube. If the control rod blade will be raised from the penetration to adjust or verify seating of the blade, the exposed cross-sectional area of the RPV penetration flow path is used.

The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position closed and administratively controlled, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths. A blank flange or other bolted device must be connected with a sufficient number of bolts to prevent draining in the event of an Operating Basis Earthquake.

Normal or expected leakage from closed systems or past isolation devices is permitted. Determination that a system is intact and closed or isolated must consider the status of branch lines and ongoing plant maintenance and testing activities.

The Residual Heat Removal (RHR) Shutdown Cooling System is only (continued)

HATCH UNIT 2 B 3.5-24 REVISION 110

RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 (continued)

REQUIREMENTS (Reference 8) have been precluded by functional valve interlocks or by isolation devices, such that redirection of RPV water out of an RHR subsystem is precluded. Further, RHR Shutdown Cooling System is only considered an intact closed system if its controls have not been transferred to Remote Shutdown, which disables the interlocks and isolation signals.

The exclusion of a single penetration flow paths, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME must should consider the potential effects of temporary alterations in support of maintenance a single operator error or initiating event on items supporting maintenance and testing (rigging, scaffolding, temporary shielding, piping plugs, snubber removal, freeze seals, etc.). If reasonable controls are implemented to preventIf failure of such items temporary alterations from could result and would causinge a draining event from a closed system or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered.

Reasonable controls include, but are not limited to, the penetration flow path may not be excluded from the DRAIN TIME calculation.

controls consistent with the guidance in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4, NUMARC 91-06, Guidelines for Industry Actions to Access Shutdown Management, or commitments to NUREG-0612, Control of Heavy Loads at Nuclear Power Plants.

Surveillance Requirement 3.0.1 requires SRs to be met between performances. Therefore, any changes in plant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined.

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

SR 3.5.2.2 and SR 3.5.2.3 The minimum water level of 146 inches required for the suppression pool is periodically verified to ensure that the suppression pool will provide adequate net positive suction head (NPSH) for the CS subsystem or LPCI subsystem pumps, recirculation volume, and vortex prevention. With the suppression pool water level less than the required limit, the required LPCI injection/spray subsystem is inoperable.

(continued)

HATCH UNIT 2 B 3.5-26 REVISION 110

RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.2 and SR 3.5.2.3 (continued)

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

SR 3.5.2.4 The Bases provided for SR 3.5.1.1 are applicable to SR 3.5.2.4.

SR 3.5.2.5 DeletedVerifying the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow path provides assurance that the proper flow paths will be available for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

In MODES 4 and 5, the RHR System may operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Therefore, RHR valves that are required for LPCI subsystem operation may be aligned for decay heat removal. Therefore, this SR is modified by a Note 1 that allows a required LPCI subsystem of the RHR System to be considered OPERABLE for the ECCS function if all the required valves in the LPCI flow path can be manually realigned (remote or local) to allow injection into the RPV, and the system is not otherwise inoperable. This will ensure adequate core cooling if an inadvertent RPV draindown should occur.

The Surveillance is also modified by a Note 2 which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual who can rapidly close the system vent flow path if directed.

(continued)

HATCH UNIT 2 B 3.5-28 REVISION 110

RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.6 REQUIREMENTS (continued) Verifying that the required ECCS injection/spray subsystem can be manually aligned, and the pump started and operate for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This SR is modified by two Notes. Note 1 states that Ttesting the ECCS injection/spray subsystem may be done through the test return recirculation line is necessary to avoid overfilling the refueling cavity. Note 2 states that credit for meeting the SR may be taken for normal system operation that satisfies the SR, such as using RHR mode of LPCI for 10 minutes. The minimum operating time of 10 minutes was based on engineering judgement.

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

SR 3.5.2.7 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

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

SR 3.5.2.8 The required ECCS subsystem shall be capable of being manually operated. This Surveillance verifies that the a required CS or LPCI subsystem (including the associated pump and valve(s)) can be manually aligned and started from the control room, including any necessary valve alignment, instrumentation, or controls, to transfer water from the suppression pool or CST to the RPVoperated to provide additional RPV Water Inventory, if needed.

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

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

(continued)

HATCH UNIT 2 B 3.5-29 REVISION 110

RCIC System B 3.5.3 BASES SURVEILLANCE SR 3.5.3.5 REQUIREMENTS (continued) The RCIC System is required to actuate automatically in order to verify its design function satisfactorily. This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of the RCIC System will cause the system to operate as designed, including actuation of the system throughout its emergency operating sequence; that is, automatic pump startup and actuation of all automatic valves to their required positions. This test also ensures the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.2 3 overlaps this Surveillance to provide complete testing of the assumed safety function.

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

This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 33.

2. FSAR, Section 5.5.6.

3. Memorandum from R.L. Baer (NRC) to V. Stello, Jr. (NRC),

"Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.

4. GE Report AES-41-0688, "Safety Evaluation for Relaxation of RCIC Performance Requirements for Plant Hatch Units 1 and 2," July 1988.

5. NRC No.93-102, "Final Policy Statement on Technical Specification Improvements," July 23, 1993.

6. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

HATCH UNIT 2 B 3.5-33 REVISION 110

PCIVs B 3.6.1.3 BASES ACTIONS D.1 With the secondary containment bypass leakage rate or MSIV leakage rate not within limit, the assumptions of the safety analysis may not be met. Therefore, the leakage must be restored to within limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Restoration can be accomplished by isolating the penetration that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. When a penetration is isolated, the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable considering the time required to restore the leakage by isolating the penetration and the relative importance to the overall containment function.

E.1 and E.2 If any Required Action and associated Completion Time cannot be met in MODE 1, 2, or 3, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

HATCH UNIT 2 B 3.6-21 REVISION 110

AC Sources - Shutdown B 3.8.2 BASES LCO between the offsite transmission network and the onsite Class 1E (continued) Electrical Distribution System capable of supplying power to the required LPCI valve load center must be OPERABLE. The circuit can be any of the Unit 1 circuits supplying the 1E and 1G ESF buses and the Unit 2 circuit supplying the 2F ESF bus. Also, one DG capable of supplying power to the required LPCI valve load center must be OPERABLE. The DG can be any one of the Unit 1 DGs (i.e., 1A and 1C DGs) and the swing DG (i.e., DG 1B). It is preferable to use the Unit 1 circuit and a Unit 1 DG to supply power to the LPCI valve load center, since in the case of an LOSP on both units, one LPCI valve load center would be without power if the swing DG was aligned to the opposite unit, thereby rendering one LPCI subsystem inoperable.

Together, OPERABILITY of the required offsite circuits and DGs ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

The qualified offsite circuits must be capable of maintaining rated frequency and voltage while connected to their respective ESF buses, and of accepting required loads during an accident. Qualified offsite circuits are those that are described in the FSAR and are part of the licensing basis for the unit. The Unit 1 and Unit 2 offsite circuits consist of incoming breaker and disconnect to the 1C, 1D, or 1E and the 2C, 2D, or 2E startup auxiliary transformers (SATs), associated 1C, 1D, or 1E and 2C, 2D, or 2E SATs, and the respective circuit path including feeder breakers to all 4.16 kV ESF buses required by LCO 3.8.8. (However, for design purposes, the offsite circuit excludes the feeder breakers to each 4.16 kV ESF bus.)

The required DGs must be capable of being manually startedstarting, accelerating to rated frequency and voltage, connecting to their respective ESF bus on detection of bus undervoltage, and accepting required loads. This sequence must be accomplished within 12 seconds. Each DG must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with engine hot and DG in standby with engine at ambient conditions. Additional DG capabilities must be demonstrated to meet required Surveillances, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode.

Proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY.

(continued)

HATCH UNIT 2 B 3.8-43 REVISION 121

AC Sources - Shutdown B 3.8.2 BASES ACTIONS A.2.1, A.2.2, A.2.3, B.1, B.2, and B.3 (continued)

With one or more offsite circuits not available to all required 4160 V ESF buses, the option still exists to declare all required features inoperable (per Required Action A.1). Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With one or more required DGs inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A have been modified by a Note to indicate that when Condition A is entered with no AC power to any required ESF bus, ACTIONS for LCO 3.8.8 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit whether or not a bus is de-energized. LCO 3.8.8 provides the appropriate restrictions for the situation involving a de-energized bus.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.6 is not required to be met since only one Unit 1 and one Unit 2 offsite circuits are required to be OPERABLE. SR 3.8.1.5, SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.13, SR 3.8.1.16, and SR 3.8.1.17 are not required to be met because DG start and load within a specified time and response on an offsite power or ECCS initiation signal is not required. SR 3.8.1.15 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods of HATCH UNIT 2 B 3.8-45 REVISION 96

AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE SR 3.8.2.1 (continued)

REQUIREMENTS being synchronized to the offsite circuit. SR 3.8.1.18 is excepted because starting independence is not required with the DG(s) that is not required to be OPERABLE. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

This SR is modified by a Note which precludes. The reason for the Note is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs, and to preclude de-energizing a required 4160 V ESF bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit(s) and the DG(s). It is the intent that these SRs must still be capable of being met, but actual performance is not required.

This Surveillance is provided to direct that the appropriate Surveillances for the required Unit 1 DG and offsite circuit are governed by the Unit 1 Technical Specifications. Performance of the applicable Unit 1 Surveillances will satisfy both any Unit 1 requirements, as well as satisfying this Unit 2 Surveillance requirement. The Frequency required by the applicable Unit 1 SR also governs performance of that SR for both Units.

REFERENCES 1. NRC No.93-102, "Final Policy Statement on Technical Specification Improvements," July 23, 1993.

HATCH UNIT 2 B 3.8-46 REVISION 96

v t e Letter Sequence Request
EPID:L-2020-LLA-0194, TSTF-582 (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other: ML21014A375, ML21028A388
MONTHYEAR2020-09-11 [Table View]

NL-20-0785, Southern Nuclear Operating Co - Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

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NL-20-0785, Southern Nuclear Operating Co - Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

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Enclosure:

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

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