NOC-AE-04001682, Response to NRC Questions on Proposed Change to Technical Specification 3/4.3.3.5 for Remote Shutdown System

Response to NRC Questions on Proposed Change to Technical Specification 3/4.3.3.5 for Remote Shutdown System

ML041890388
Person / Time
Site:	South Texas
Issue date:	06/29/2004
From:	Jordan T South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-04001682, STI:31699052, TAC MC1246, TAC MC1247
Download: ML041890388 (17)

Text

Nuclear Operating Company South TcwsPq/dEkdrkcCeiinStaDbon S 0. &r282 PO idsinrth. Tr 77483-V June 29, 2004 NOC-AE-04001682 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Response to NRC Questions on Proposed Change to Technical Specification 3/4.3.3.5 for Remote Shutdown System (TAC# MC1246 and #MC1247)

Reference:

Letter from T. J. Jordan, STPNOC, to NRC Document Control Desk, dated November 4, 2003 (NOC-AE-03001584)

STP Nuclear Operating Company (STPNOC) submitted the referenced proposed amendment to South Texas Project Operating Licenses requesting revision of Technical Specification 3/4.3.3.5 for the Remote Shutdown System to be consistent with the requirements of NUREG-1431.

The attachment to this letter responds to NRC staff reviewers' questions on the proposed change and proposes a clarification to the wording of the proposed revision to Technical Specification (TS) 3.3.5. A revised TS page 3/4 3-61 is attached. It replaces the same page submitted in the original application. The other TS page changes submitted with the original submittal are still valid and necessary. STPNOC considers the proposed change to the wording to be an editorial enhancement and the No Significant Hazards Determination submitted in the referenced letter remains valid.

The STPNOC Plant Operations Review Committee has reviewed and concurred with the proposed change to the Technical Specifications.

In accordance with 10 CFR 50.91(b), STPNOC is notifying the State of Texas of this request for license amendment by providing a copy of this letter and its attachments.

04001682 (TSC-323 remote shutdown RAI response).doc STI:316990520OO

NOC-AE-04001682 Page 2 If there are any questions regarding the responses, please contact Mr. A. W. Harrison at (361) 972-7298 or me at (361) 972-7902.

There are no commitments in this submittal.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on JLonie'1 , Zoo+

date Vice President Engineering & Technical Services awh/

Attachments:

1. Response to NRC Staff Request for Additional Information

2. Revised Technical Specification Page

3. Revised Bases for TS 3/4.3.3.5

NOC-AE-04001682 Page 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 L. D. Blaylock City Public Service U. S. Nuclear Regulatory Commission David H. Jaffe Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Texas Genco, LP Richard A. Ratliff A. Ramirez Bureau of Radiation Control City of Austin Texas Department of Health 1100 West 49th Street C. A. Johnson Austin, TX 78756-3189 AEP Texas Central Company Jeffrey Cruz Jon C. Wood U. S. Nuclear Regulatory Commission Matthews & Branscomb P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

NOC-AE-04001 682 Attachment 1 ATTACHMENT 1 Response to NRC Staff Request for Additional Information

NOC-AE-04001 682 Attachment 1 Page 1 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTION REGULATION SOUTH TEXAS NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNIT 1 AND UNIT 2 DOCKET NOS. 50-498 AND 50-499 TAC # MC1 246 AND #MC1 247 STPNOC proposes TS changes in this request which relocate lists of remote shutdown system instrumentation and controls details related to system design and operation to the TS Bases. In addition, changes are proposed to relax action requirements for inoperable Remote Shutdown System functions by extending action time limits, eliminate reporting requirements for a Remote Shutdown System function inoperable for more than 60 days, limit monthly channel testing to normally energized circuits and incorporate administrative changes, as appropriate, to adopt the format of NURG-1431.

The staff finds that additional information is required to complete its' review. Change items and evaluations given below reference STPNOC Letter NOC-AE-03001584, Section 4.0, Technical Analysis.

1. Change item 1: Revise TS 3.3.3.5 Limiting Condition for Operation (LCO) to simply state that the Remote Shutdown System functions shall be OPERABLE.

References to transfer switches, power or controls and monitoring instrumentation as shown in the associated Table 3.3-9, "Remote Shutdown System" are deleted. Current TS 3.3.3.5 Table 3.3-9 lists the Readout Location, and Controls Location for remote shutdown instrumentation. The proposed change will relocate these requirements to licensee controlled documents. The Change Item #1 evaluation states: ..... Listing specific instrumentation and controls is unnecessary and may lead to needless expenditure of licensee and NRC resources processing license amendments to revise the table when the licensee can adequately control the information. These details are not necessary to adequately describe the actual regulatory requirement ...... The details relocated to plant procedures will be controlled by the plant procedure change process.

RAI #1 Provide a safety analysis discussion to support the evaluation statements that specific instrumentation and controls are unnecessary and may lead to needless expenditure of resources and show that licensee change control processes will ensure adequate control of future changes that are commensurate with the license amendment process.

NOC-AE-04001 682 Attachment 1 Page 2

Response

The definition of OPERABLE in the Technical Specification (TS) provides adequate guidance for determining what instrumentation and controls are necessary for a particular remote shutdown function. The ability to transfer control of a function from the main control room to the auxiliary shutdown panel (ASP) is a required support function by the TS definition of OPERABLE. In addition, the surveillance requirement SR 4.3.3.5.2 still requires the local panel transfer function to be tested. The current panel locations are adequately described in the UFSAR and retaining this level of detail in the TS is not necessary. Application of 10CFR50.59 for this information in the UFSAR is adequate control for licensees to make design changes that affect the location of the Remote Shutdown System functions.

Relocation of the list of variables to the Bases is acceptable because the TS Bases are controlled by the STPNOC Bases Control Program, which provides assurance that the Bases are consistent with the design basis as described in the UFSAR. Changes to the Bases are evaluated in accordance with 10CFR50.59. Changes to the Bases will not affect the requirements of the LCO for the Remote Shutdown System. The LCO continues to assure the Remote Shutdown System functions and changes to the LCO requirements would require NRC approval.

Precedent for the relocation has been established with TSTF-266 and Revision 2 of NUREG-1 431 that incorporated TSTF-266.

2. Change item 2: Revise TS 3.3.3.5 ACTION a. to delete the references to transfer switches, power or controls and monitoring instrumentation as shown in the associated Table 3.3-9. The ACTION will be simplified to state the entry condition for the action as "one or more of the number of required remote shutdown monitoring functions inoperable." Add a note to permit separate condition entry. The Change Item #2 evaluation states: "Same as item 1."

RAI #2 Explain the change to current TS requirements that results from addition of "separate condition entry for each function" and provide a safety basis discussion of the proposed change.

Response

The proposed note is consistent with NUREG-1431. STP's application of the current TS would permit separate entry into the required action should more than one function be inoperable (e.g., one inoperable channel of Reactor Coolant Hot Leg temperature concurrent with one inoperable channel of Steam Line Pressure). Without the proposed note, the

NOC-AE-04001 682 Attachment 1 Page 3 proposed new wording could be interpreted not to allow separate entry for each function. Consequently, the proposed change is considered to be an administrative clarification.

3. Chance Item 7: Revise the requirements for decay heat removal in the information relocated to the Bases to allow the use of either AFW flow or steam generator level instead of both as in current TS Table 3.3-9. The Change Item

1. 7 evaluation states: The purpose of these indications is to determine if decay heat removal is taking place via the SGs to ensure a safe shutdown. Therefore, adequate information to determine if decay heat removal is occurring via the SGs can be obtained by either of these indications.

RAI#3 Explain the current licensing basis for requiring both AFW flow and steam generator level. Show that the requirements of 10 CFR 50, Appendix A, GDC 19 would be met by allowing the use of either AFW flow or steam generator level instead of both as required in current TS Table 3.3-9.

Response

To simplify the review process, STPNOC will revise application to retain the requirement for both functions. The attached proposed Bases page has been revised accordingly.

4. Change Item 8: Simplify the Remote Shutdown System information relocated to the Bases to show only the list of required functions, instruments and control parameters and the required number of channels or functions. The Change Item

1. 8 evaluation states: Change the format of the information and removing the details describing the location of the functions has not effect on the application of the TS to the functions. This is an administrative change.

RAI #4 Remote Shutdown System TS LCO specify requirements for Total Number of Channels and Minimum Channels OPERABLE for channels, transfer switches, power or control circuits. The staff compared the current TS Table 3.3-9 Total Number of Channels and Minimum Channels OPERABLE requirements to the proposed Bases Table 3.3.5-1 Required Number of Functions requirements. For the most part the proposed TS delete requirements for the total number of operable channels, transfer switches, power or control switches, while retaining the requirements for minimum channels operable requirements. These changes are not identified or evaluated in the application. Provide a detailed safety assessment of the proposed changes to current TS requirements.

NOC-AE-04001 682 Attachment 1 Page 4

Response

This proposed change is administrative and does not affect the design or operation of the remote shutdown system. The control and transfer switch locations are design details that are described in the UFSAR and not needed in the TS. Basing the Required Number of Functions in Table B 3.3.5-1 on the current TS minimum channels operable requirement retains the current licensing basis for a shutdown action level for the Remote Shutdown LCO.

The current TS allow unlimited operation with one less than the total number of channels. The only requirement is to submit a special report if an inoperable function is not restored within 60 days. Deletion of the requirement to submit a report has no effect on the safety of the plant. Not specifying the total number of channels in the TS has no effect on the design of the functions. The functions, including the total number of functions or channels associated with a function, are described in the STP UFSAR and are therefore part of the design basis of the facility as required by GDC-19. STPNOC cannot change the UFSAR design basis without an evaluation in accordance with the requirements of 10CFR50.59. Based on guidance from Generic Letter 91-18 Rev. 1, procedural requirements for implementation of 10CFR50.59 also require STPNOC to apply 10CFR50.59 to any condition where operation with an inoperable channel of the remote shutdown system will be accepted "as-is". Consequently, eliminating the total number of channels information from the current TS does not eliminate the requirement for the channels from the design. In addition, the components and functions are subject to the requirements of the STPNOC Corrective Action Program.

The Required Number of Functions in Table B 3.3.5-1 is based on the minimum channels operable requirements from the current TS. This is consistent with the current licensing basis requirement for shutdown action as required in the existing ACTION a. The Bases state that ACTION

a. is to address "...the situation where one or more required Functions of the Remote Shutdown System are inoperable." If the Required Number of Functions listed in the table are met, STP can achieve safe shutdown from outside the control room in accordance with regulatory requirements and the Remote Shutdown System is OPERABLE.

If the Required Number of Functions were based on the total number of channels, the proposed TS would be substantially more restrictive than the current TS because the shutdown requirement of revised ACTION a. would apply if only one channel of a function were inoperable. As discussed in the response to the first RAI, the definition of OPERABLE will be applied to assure the appropriate control and transfer instrumentation is available.

NOC-AE-04001682 Attachment 1 Page 5 The TS surveillance requirements provide for adequate testing of the functions.

5. Change Item 9: Revise Surveillance Requirement (SR) 4.3.3.5.1 to apply the channel check only to normally energized Remote Shutdown System instrumentation and to delete the reference to the channel calibration (moved to new SR 4.3.3.5.3). References to Table 4.3-6 are deleted. The Change Item #9 evaluation states: Performing a channel check of this instrumentation is not practical or feasible during power operation. The other changes to this SR are administrative.

RAI #5 The practical and/or feasibility matters of testing at power can, in part, be addressed through a robust design allowances for testing instrumentation channels. Provide a summary of plant experience with failures to complete testing as a result of practical and/or feasibility matters. Provide a safety basis for the proposed relaxation to current TS requirements.

Response

STPNOC included the provision because it is accepted in NUREG-1431.

However, none of the STP remote instrumentation is normally de-energized. The provision would probably be commonly applied to source range neutron flux for Westinghouse plants. STP's design uses extended range neutron flux - startup rate for this application. Although the detectors are over-range during power operation, they are not de-energized and STP does currently perform monthly channel checks. STP proposes to retain the provision to allow flexibility for any future design change that might replace an existing instrument that is normally energized with one that is not. However, STP does not anticipate any changes to existing surveillance test requirements upon implementation of this proposed change.

RAI#6 The STP TS Table B 3.3.5-1, "Remote Shutdown System Instrumentation and Controls" does not include the "Manual Reactor Trip" capability. WOG standard TS Table B 3.3.4-1, Item 1.c listed that capability. Please justify this deviation.

Response

Manual reactor trip is not in the current STP TS for remote shutdown and is not part of the STP remote shutdown system. The STP control room evacuation procedure requires manual reactor trip prior to leaving the control room. Page 4 of Attachment 1 to the November 3, 2003 application

NOC-AE-04001 682 Attachment 1 Page 6 (NOC-AE-03001584) does discuss trip breaker indication and why STPNOC did not propose to include the surveillance for the RTB position indication.

6. NRC Comment on proposed wording of TS 3.3.3.5 and Table B 3.3.5-1: The NRC reviewer commented that the use of the terms "function" and "channel" were not clear and the application of the TS might not be clear to the operator.

Response

STPNOC incorporated the standard wording from NUREG-1431 in the original application. However, STPNOC agrees that the wording can be clarified. Consequently, TS 3.3.3.5 ACTION a. has been revised as shown below. In addition, the term "Remote Shutdown System" is now used consistently in the proposed LCO and surveillance requirements.

3.3.3.5 The Remote Shutdown System Functions shall be OPERABLE.

a. With one or more required channels of one or more Remote Shutdown System Functions inoperable, restore the inoperable Function(s) to OPERABLE status within 30 days, or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

NOTE: Separate condition entry is allowed for each Function.

The headings of the columns of Table B 3.3.5-1 have been revised to "Function" and "Required Number of Channels".

NOC-AE-04001 682 Attachment 2 Page 1 Attachment 2 Revised Technical Specification Page A revised TS page 3/4 3-61 is attached. It replaces the same page submitted in the original application. The other TS page changes submitted with the original submittal are still valid and necessary.

NOC-AE-04001 682 Attachment 1 Page 2 INSTRUMENTATION REMOTE SHUTDOWN SYSTEM LIMITING CONDITION FOR OPERATION 3.3.3.5 The Remote Shutdown System runctions transfor twitches, power, controls and monitnring inctrumnttin hannic ChoInn Tabl 3 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

a. With 'one or more required channels of one or more tho number of HNERA01 Remote Shutdown System Functionsi inoperable monnnorin rf twitohoc, poweror cOentr! ncircuiteloc than theMinimum Channelc OPERALIE a required by Table 3.3 -9,restore the inoperable Function(s) to OPERABLE status within 30 AZ days, or be in WOT STANDBYw*ithin the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the followingie6t ~4Q hours.

NOTE: Separate condition entry is allowed for each Function.'

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b. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.5.1 Each normally energized Remote Shutdown System monitoring instrumentation channel shall be demonstrated OPERABLE by performance of a OH;-CHANNEL CHECK Ft least p ce per 31 days. nE GAILIBR.ATIGN era at I

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4.3.3.5.2 Each Remote Shutdown System transfer switch, power and control circuit including the actuated components, shall be demonstrated OPERABLE at least once per 18 months.

4.3.3.5.3, Each Remote Shutdown System required instrumentation channel shall be demonstrated OPERABLE by performance of a CHANNEL CALIBRATION at least once per

~18 months. [NOTE: Neutron detectors and reactor trip breaker indication are excluded from CHANNELCALIBRATION.]

SOUTH TEXAS - UNITS 1 & 2 3/4 3-61 Unit 1 - Amendment No. 4=1 Unit 2 - Amendment No. 439

NOC-AE-04001 682 Attachment 3 Revised Bases for TS 3/4.3.3.5

[STPNOC has revised the TS Bases originally submitted with the referenced letter to incorporate NRC reviewer comments and to reformat Table B 3.3.5-1 to better reflect the Remote Shutdown System functions.]

NOC-AE-04001 682 Attachment 3 Page 1 BACKGROUND The Remote Shutdown System provides the control room operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. A safe shutdown condition is defined as MODE 3. With the unit in MODE 3, the Auxiliary Feedwater (AFW) System and the steam generator (SG) safety valves or the SG power operated relief valves (PORVs) can be used to remove core decay heat and meet all safety requirements. The long term supply of water for the AFW System and the ability to borate the Reactor Coolant System (RCS) from outside the control room allows extended operation in MODE 3.

If the control room becomes inaccessible, the operators can establish control at the remote shutdown panel, and place and maintain the unit in MODE 3. Not all controls and necessary transfer switches are located at the remote shutdown panel. Some controls and transfer switches will have to be operated locally at the switchgear, motor control panels, or other local stations. The unit automatically reaches MODE 3 following a unit shutdown and can be maintained safely in MODE 3 for an extended period of time.

The OPERABILITY of the remote shutdown control and instrumentation Functions ensures there is sufficient information available on selected unit parameters to place and maintain the unit in MODE 3 should the control room become inaccessible.

APPLICABLE SAFETY ANALYSES The Remote Shutdown System is required to provide equipment at appropriate locations outside the control room with a capability to promptly shut down and maintain the unit in a safe condition in MODE 3.

The criteria governing the design and specific system requirements of the Remote Shutdown System are located in 10 CFR 50, Appendix A, GDC 19 (Ref. 1).

LCO The Remote Shutdown System LCO provides the OPERABILITY requirements of the instrumentation and controls necessary to place and maintain the unit in MODE 3 from a location other than the control room. The instrumentation and controls required are listed in Table B 3.3.5-1.

NOC-AE-04001 682 Attachment 3 Page 2 The controls, instrumentation, and transfer switches are required for:

• Core reactivity control (initial and long term),

• RCS pressure control,

• Decay heat removal via the AFW System and the SG safety valves or SG PORVs,

• RCS inventory control via charging flow, and

• Safety support systems for the above Functions, including Essential Cooling Water, Component Cooling Water, and onsite power, including the diesel generators.

A Function of a Remote Shutdown System is OPERABLE if all instrument and control channels needed to support the Remote Shutdown System Function are OPERABLE.

In some cases, Table B 3.3.5-1 may indicate that the required information or control capability is available from several alternate sources. In these cases, the Function is OPERABLE as long as one channel of any of the alternate instrumentation or control sources is OPERABLE.

The remote shutdown instrument and control circuits covered by this LCO do not need to be energized to be considered OPERABLE. This LCO is intended to ensure the instruments and control circuits will be OPERABLE if unit conditions require that the Remote Shutdown System be placed in operation.

APPLICABILITY The Remote Shutdown System LCO is applicable in MODES 1, 2, and 3. This is required so that the unit can be placed and maintained in MODE 3 for an extended period of time from a location other than the control room.

ACTIONS ACTION a. addresses the situation where one or more required Functions of the Remote Shutdown System is in a condition where one or more of its required channels are inoperable. This includes the control and transfer switches for any required Function. The Required Action is to restore the required Function to OPERABLE status within 30 days. The allowed outage time is based on operating experience and the low probability of an event that would require evacuation of the control room. If the Required Action and associated allowed outage time of ACTION a. is not met, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed outage time is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Action a. is modified by a note that states that separate condition entry is allowed for each function. The allowed outage time(s) of the inoperable channel(s)/train(s) of a

NOC-AE-04001 682 Attachment 3 Page 3 Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

ACTION b. states that LCO 3.0.4 does not apply. This exception allows entry into an applicable MODE while relying on the ACTIONS even though the ACTIONS may eventually require a unit shutdown. This exception is acceptable due to the low probability of an event requiring the Remote Shutdown System and because the equipment can generally be repaired during operation without significant risk of spurious trip.

SURVEILLANCE REQUIREMENTS SR 4.3.3.5.1 requires performance of a CHANNEL CHECK once every 31 days to ensure 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.

As specified in the Surveillance, a CHANNEL CHECK is only required for those channels, which are normally energized. The Frequency of 31 days is based upon operating experience, which demonstrates that channel failure is rare.

SR 4.3.3.5.2 verifies each required Remote Shutdown System control circuit and transfer switch performs the intended function. This verification is performed from the remote shutdown panel and locally, as appropriate. Operation of the equipment from the remote shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the unit can be placed and maintained in MODE 3 from the remote shutdown panel and the local control stations. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. (However, this Surveillance is not required to be performed only during a unit outage.) Operating experience demonstrates that remote shutdown control channels usually pass the Surveillance test when performed at the 18 month Frequency.

SR 4.3.3.5.3 requires a CHANNEL CALIBRATION, which is a complete check of the instrument loop and the sensor. The Frequency of 18 months is based upon operating experience and consistency with the typical industry refueling cycle.

NOC-AE-04001 682 Attachment 3 Page 4 Table B 3.3.5-1 Remote Shutdown System Instrumentation and Controls FUNCTION REQUIRED NUMBER OF CHANNELS

1. Reactivity Control

a. Extended Range Startup Rate 2

b. Extended Range Neutron Flux Level 2

c. Reactor Trip Breaker Position Indication 1 per trip breaker

2. Reactor Coolant System (RCS) Pressure Control

a. RCS Extended Range Pressure 2

b. RCS Wide Range Pressure 2

c. Pressurizer Power Operated Relief Valve (PORV) Control and 1(a)

Block Valve Control

3. Decay Heat Removal via Steam Generators (SGs)

a. RCS Hot Leg Temperature (Wide Range) 1 per loop in 3 loops(b)

b. RCS Cold Leg Temperature (Wide Range) 1 per loop in 3 loops(b)

c. AFW Controls 2 (b)

d. AFW Storage Tank Level 2

e. Steam Line Pressure 1 per steam line in 3 steam lines(b)

f. SG Level (Wide Range) 1 per SG in 3 SGs(b)

g. AFW Flow 1 per SG in 3 SGs(b)

h. Steam Generator Power Operated Relief Valves (SG PORVs) 2 (b)

4. RCS Inventory Control

a. Pressurizer Level 2

b. Charging Pump Controls 1 c Letdown Isolation Valves 1

d. Reactor Head Vent Throttle Valve 1

e. Reactor Head Vent Isolation Valves 1 pair

5. Safety Support Systems

a. Boric Acid Transfer Pumps 1

b. Accumulator Discharge Isolation Valves and Power Lockouts 3

c. CCW Pumps and Heat Exchanger Outlet valves 2

d. ECW Pumps 2

e. EAB HVAC Fans 2

f. Reactor Containment Fan Coolers 3 (a) Controls must be for PORV and block valves on same line.

(b) The instruments and control parameters must be in the same OPERABLE RCS loop/secondary loop.