PNP 2019-017, Submittal of Changes to Technical Specifications Bases

Submittal of Changes to Technical Specifications Bases

ML19080A002
Person / Time
Site:	Palisades
Issue date:	03/21/2019
From:	Hardy J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2019-017
Download: ML19080A002 (21)

Text

- Entergr.

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Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269-764-2000 Jeffery A. Hardy Regulatory Assurance Manager 10 CFR 50.4 PNP 2019-017 March 21, 2019 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Submittal of Changes to Palisades Nuclear Plant Technical Specifications Bases Palisades Nuclear Plant Docket 50-255 Renewed Facility Operating License No. DPR-20 In accordance with Palisades Nuclear Plant (PNP) Technical Specification Section 5.5.12, "Technical Specifications (TS) Bases Control Program," which requires that changes to the TS Bases, implemented without prior Nuclear Regulatory Commission (NRC) approval, be provided to the NRC on a frequency consistent with Title 10 of the Code of Federal Regulations, Subsection 50.71 (e), Entergy Nuclear Operations, Inc. hereby provides all PNP TS Bases changes implemented without prior NRC approval since the previous PNP TS Bases submittal, dated November 8,2017. provides a list of the affected sections and descriptions of the changes. provides page change instructions, and copies of the revised List of Effective Pages, the TS Bases Title Page, and the TS Bases sections identified in Attachment 1.

This letter identifies no new regulatory commitments.

Should you have any questions concerning this letter, or require additional information, please contact Jeff Erickson at 269-764-2375.

Respectively, 9A~\1-Jeffery A. Hardy JAH/jse

PNP 2019-017 Page 2 of 2 Attachments: 1. List of Palisades Nuclear Plant Technical Specifications Bases Changes and Descriptions of Changes

2. Page Change Instructions and Revised Technical Specifications Bases cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

ATTACHMENT 1 LIST OF PALISADES NUCLEAR PLANT TECHNICAL SPECIFICATIONS BASES CHANGES AND DESCRIPTIONS OF CHANGES Affected Date Change Description Bases May 30,2018 Section B 3.7.6 This Bases change adds that, when transferring water via the gravity flow path from the primary makeup storage tank (T-81) to the condensate storage tank (T-2) under loss of offsite power conditions, the condensate inventory analysis credits both the control valves and the manual bypass valves in the gravity flow path as being open. This change was made to clarify that both the control valves and the manual valves are credited in this gravity flow path.

February 28, Section B 3.7.8 The Bases was revised to remove the aftercoolers for 2019 the instrument air compressors C-2A and C-2C from the list of major cooling loads in the service water system.

This revision reflects a plant modification in which air-cooling air compressors were installed in place of water-cooled air compressors. With this change, the air compressor aftercoolers are no longer a service water system cooling load.

Page 1 of 1

ATTACHMENT 2 PAGE CHANGE INSTRUCTIONS AND REVISED TECHNICAL SPECIFICATIONS BASES 17 Pages Follow

Technical Specifications Bases Page Change Instructions Revise the Palisades Nuclear Plant Technical Specifications Bases by removing the pages identified below and inserting the revised pages. Vertical lines in the margin indicate the area of change.

TECHNICAL SPECIFICATION BASES PAGES REMOVE INSERT Palisades Technical Specification Bases Palisades Technical Specification Bases List of Effective Pages List of Effective Pages Revised 05/30/2018 (3 pages) Revised 02/28/2019 (3 pages)

Technical Specification Bases Title Page Technical Specification Bases Title Page (1 page) (1 page)

Revised 05/30/2018 Revised 02/28/2019 B 3.7.6 B 3.7.6-4 (4 pages) B 3.7.6 B 3.7.6-4 (4 pages)

Revised 04/14/2011 Revised 05/30/2018 B 3.7.8 B 3.7.8-8 (8 pages) B 3.7.8 B 3.7.8-8 (8 pages)

Revised 10/29/09 Revised 02/28/2019 1 of 1

PALISADES TECHNICAL SPECIFICATIONS BASES 1 LIST OF EFFECTIVE PAGES COVERSHEET Title Page Revised 02/28/2019 TABLE OF CONTENTS Pages i and ii Revised 02/19/09 TECHNICAL SPECIFICATIONS BASES Bases 2.0 Pages B 2.1.1 B 2.1.1-4 Revised 04/14/11 Pages B 2.1.2 B 2.1.2-4 226 - Revised 04/14/16 Bases 3.0 Pages B 3.0 B 3.0-21 262 - Revised 07/26/17 Bases 3.1 Pages B 3.1.1 B 3.1.1-5 226 - Revised 04/14/16 Pages B 3.1 .2 B 3.1.2-6 Revised 09/09/03 Pages B 3.1.3 B 3.1.3-4 189 Pages B 3.1.4 B 3.1.4-13 Revised 07/18/07 Pages B 3.1.5 B 3.1 .5-7 Revised 07/02/04 Pages B 3.1.6 B 3.1.6-9 Revised 07/30/03 Pages B 3.1 .7 B 3.1.7-6 Revised 05/15/07 Bases 3.2 Pages B 3.2.1 B 3.2.1-11 Revised 08/06/04 Pages B 3.2.2 B 3.2.2-3 Revised 09/28/01 Pages B 3.2.3 B 3.2.3-3 Revised 09/28/01 Pages B 3.2.4 B 3.2.4-3 189 - Revised 08/09/00 Bases 3.3 Pages B 3.3.1 B 3.3.1-35 226 - Revised 04/14/16 Pages B 3.3.2 B 3.3.2-10 226 - Revised 04/14/16 Pages B 3.3.3 B 3.3.3-24 Revised 03/20/08 Pages B 3.3.4 B 3.3.4-12 Revised 09/09/03 Pages B 3.3.5 B 3.3.5-6 Revised 11/08/2017 Pages B 3.3.6 B 3.3.6-6 226 - Revised 04/14/16 Pages B 3.3.7 B 3.3.7-12 Revised 11/08/2012 Pages B 3.3.8 B 3.3.8-6 Revised 02/24/05 Pages B 3.3.9 B 3.3.9-5 189 - Revised 08/09/00 Pages B 3.3.10 B 3.3.10-4 226 - Revised 04/14/16 Bases 3.4 Pages B 3.4.1 B 3.4.1-4 Revised 08/24/04 Pages B 3.4.2 B 3.4.2-2 189 Pages B 3.4.3 B 3.4.3-7 Revised 02/17/12 Pages B 3.4.4 B 3.4.4-4 Revised 09/21/06 Pages B 3.4.5 B 3.4.5-5 Revised 09/21/06 Pages B 3.4.6 B 3.4.6-6 Revised 07/31/07 Pages B 3.4.7 B 3.4.7-7 Revised 07/31/07 Pages B 3.4.8 B 3.4.8-5 Revised 07/31/07 Pages B 3.4.9 B 3.4.9-6 256 - Revised 07/29/15 Pages B 3.4.10 B 3.4.10-4 262 - Revised 07/26/17 Pages B 3.4.11 B 3.4.11-7 Revised 02/24/05 Revised 02/28/2019

PALISADES TECHNICAL SPECIFICATIONS BASES 2 LIST OF EFFECTIVE PAGES Bases 3.4 Pages B 3.4.12-1 - B 3.4.12-13 Revised 02/17/12 (Continues) Pages B 3.4.13-1 - B 3.4.13-7 226 - Revised 04/14/16 Pages B 3.4.14-1 - B 3.4.14-8 262 - Revised 07/26/17 Pages B 3.4.15-1 - B 3.4.15-6 Revised 02/24/05 Pages B 3.4.16-1 - B 3.4.16-5 226 - Revised 04/14/16 Pages B 3.4.17-1 - B 3.4.17-7 226 - Revised 04/14/16 Bases 3.5 Pages B 3.5.1 B 3.5.1-5 189 Page B 3.5.1-6 191 Page B 3.5.1-7 189 Page B 3.5.1-8 191 ages B 3.5.2 B 3.5.2-12 262 - Revised 07/26/17 Pages B 3.5.3 B 3.5.3-4 Revised 07/22/02 Pages B 3.5.4 B 3.5.4-7 227 Pages B 3.5.5 B 3.5.5-5 227 Bases 3.6 Pages B 3.6.1 B 3.6 .1-4 Revised 03/15/12 Pages B 3.6.2 B 3.6.2-8 Revised 03/15/12 Pages B 3.6.3 B 3.6.3-12 262 - Revised 07/26/17 Pages B 3.6.4 B 3.6.4-3 Revised 03/15/12 Pages B 3.6.5 B 3.6.5-3 Revised 03/15/12 Pages B 3.6.6 B 3.6.6-13 262 - Revised 07/26/17 Bases 3.7 Pages B 3.7.1 B 3.7.1-4 262 - Revised 07/26/17 Pages B 3.7.2 B 3.7.2-6 226 - Revised 04/14/16 Pages B 3.7.3 B 3.7.3-5 Revised 12/02/02 Pages B 3.7.4 B 3.7.4-4 Revised 07/16/08 Pages B 3.7.5 B 3.7.5-9 262 - Revised 07/26/17 Pages B 3.7.6 B 3.7.6-4 Revised 05/30/18 Pages B 3.7.7 B 3.7.7-9 Revised 06/07/05 Pages B 3.7.8 B 3.7.8-8 Revised 02/28/2019 Pages B 3.7.9 B 3.7.9-3 Revised 04/14/11 Pages B 3.7.10 B 3.7.10-8 256 - Revised 07/29/15 Pages B 3.7.11 B 3.7.11-5 256 - Revised 07/29/15 Pages B 3.7.12 B 3.7.12-7 226 - Revised 04/14/16 Pages B 3.7.13 B 3.7.13-3 226 - Revised 04/14/16 Pages B 3.7.14 B 3.7.14-3 226 - Revised 04/14/16 Pages B 3.7.15 B 3.7.15-2 236 Pages B 3.7.16 B 3.7.16-5 250 - Revised 09/15/14 Pages B 3.7.17 B 3.7.17-3 226 - Revised 04/14/16 Revised 02/28/2019

PALISADES TECHNICAL SPECIFICATIONS BASES 3 LIST OF EFFECTIVE PAGES Bases 3.8 Pages B 3.8.1 B 3.8.1-24 Revised 11/08/12 Pages B 3.8.2 B 3.8.2-4 Revised 11/06/01 Pages B 3.8.3 B 3.8.3-7 Revised 08/08/17 Pages B 3.8.4 B 3.8.4-9 Revised 07/13/06 Pages B 3.8.5 B 3.8.5-3 Revised 11/06/01 Pages B 3.8.6 B 3.8.6-6 189 - Revised 08/09/00 Pages B 3.8.7 B 3.8 .7-3 189 Pages B 3.8.8 B 3.8.8-3 Revised 11/06/01 Pages B 3.8.9 B 3.8.9-7 Revised 11/06/01 Pages B 3.8.10 B 3.8.10-3 Revised 11/06/01 Bases 3.9 Pages B 3.9.1-1 - B 3.9.1-4 189 - Revised 08/09/00 Pages B 3.9 .2 B 3.9.2-3 189 - Revised 02/12/01 Page B 3.9.3-1 - B 3.9.3-6 226 - Revised 04/14/16 Pages B 3.9.4-1 - B 3.9.4-4 Revised 07/31/07 Pages B 3.9.5-1 - B 3.9.5-4 Revised 07/31/07 Pages B 3.9.6-1 - B 3.9.6-3 226 - Revised 04/14/16 Revised 02/28/2019

PALISADES PLANT FACILITY OPERATING LICENSE DPR-20 APPENDIX A TECHNICAL SPECIFICATIONS BASES Revised 02/28/2019

Condensate Storage and Supply B 3.7.6 B 3.7 PLANT SYSTEMS B 3.7.6 Condensate Storage and Supply BASES BACKGROUND The Condensate Storage and Supply provides a safety grade source of water to the steam generators for removing decay and sensible heat from the Primary Coolant System (PCS) . The Condensate Storage Tank (CST) and the Primary Makeup Storage Tank (T-81) provide a passive flow of water, by gravity, to the Auxiliary Feedwater (AFW) System (LCO 3.7.5, "Auxiliary Feedwater (AFW) System"). Three AFW pumps take a suction from a common line from the CST. T-81 provides makeup to the CST either by use of a pump or by gravity flow. Backup sources from the Service Water System (SWS) and Fire Water System provide additional water supply to the AFW pump suctions if the normal source is lost. SWS provides an emergency source to AFW pump P-8C , and the Fire Water System provides an emergency source to AFW pumps P-8A and P-8B. The steam produced is released to the atmosphere by the Main Steam Safety Valves (MSSVs) or the atmospheric dump valves.

The AFW pumps operate with a continuous recirculation to the CST.

When the main steam isolation valves are open, the preferred means of heat removal is to discharge steam to the condenser by the nonsafety grade path of the turbine bypass valve. This has the advantage of conserving condensate while minimizing releases to the environment.

Because the CST is a principal component in removing residual heat from the PCS, it is designed to withstand earthquakes. The tornado protected supply is provided by the SWS and Fire Water System. The CST is designed to Seismic Category I requirements to ensure availability of the feedwater supply.

A description of the Condensate Storage and Supply is found in the FSAR, Section 9.7 (Ref. 1).

Palisades Nuclear Plant B 3.7.6-1 Revised 05/30/2018

Condensate Storage and Supply B 3.7.6 BASES APPLICABLE The Condensate Storage and Supply provides condensate to remove SAFETY ANALYSES decay heat and to cool down the plant following all events in the accident analysis, discussed in the FSAR, Chapters 5 and 14. For anticipated operational occurrences and accidents which do not affect the OPERABILITY of the steam generators, the analysis assumption is generally 30 minutes at MODE 3, steaming through the MSSVs followed by a cool down to Shutdown Cooling (SOC) entry conditions at the design cool down rate.

The Condensate Storage and Supply satisfies Criterion 3 of 10 CFR 50.36(c)(2).

LCO To satisfy accident analysis assumptions, the CST and T-81 must contain sufficient cooling water to remove decay heat for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following a reactor trip from 2580.6 MWth. This amount of time allows for cool down of the PCS to SOC entry conditions, assuming a coincident loss of offsite power and the most adverse single failure. In doing this the CST and T-81 must retain sufficient water to ensure adequate net positive suction head for the AFW pumps, and makeup for steaming required to remove decay heat.

In a loss of offsite power, only the gravity flow path would be available to transfer water from T-81 to the CST. The inventory analysis in Reference 2 credits the T-81 and CST control valves and bypass valves, in their open positions, for the gravity flow path.

OPERABILITY of the Condensate Storage and Supply System is determined by maintaining the combined tank levels at or above the minimum required volume.

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

In MODES 5 and 6, the Condensate Storage and Supply is not required because the AFW System is not required.

Palisades Nuclear Plant B 3.7.6-2 Revised 05/30/2018

Condensate Storage and Supply B 3.7.6 BASES ACTIONS A.1 and A.2 If the condensate volume is not within the limit, the OPERABILITY of the backup water supplies must be verified by administrative means within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter.

OPERABILITY of the backup feedwater supplies must include verification of the OPERABILITY of flow paths from the Fire Water System and SWS to the AFW pumps, and availability of the water in the backup supplies.

The Condensate Storage and Supply volume must be returned to OPERABLE status within 7 days, as the backup supplies may be performing this function in addition to their normal functions. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time is reasonable, based on operating experience, to verify the OPERABILITY of the Fire Water System and SWS. Additionally, verifying the backup water supplies every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is adequate to ensure the backup water supplies continue to be available. The 7 day Completion Time is reasonable, based on OPERABLE backup water supplies being available, and the low probability of an event requiring the use of the water from the CST and T-81 occurring during this period.

As stated in SR 3.0.2, the 25% extension allowed by SR 3.0.2 may be applied to Required Actions whose Completion Time is stated as "once per ... " however, the 25% extension does not apply to the initial performance of a Required Action with a periodic Completion Time that requires performance on a "once per . . ." basis. The 25% extension applies to each performance of the Required Action after the initial performance. Therefore, while Required Action 3.7.6 A.1 must be initially performed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> without any SR 3.0.2 extension, subsequent performances at the "Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />" interval may utilize the 25% SR 3.0.2 extension .

B.1 and B.2 If the condensate volume cannot be restored to OPERABLE status within the associated Completion Time, the plant must be placed in a MODE in which the LCO does not apply. To achieve this status, the plant must be placed in 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 in MODE 4, without reliance on steam generator for heat removal, within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. 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.

Palisades Nuclear Plant B 3.7.6-3 Revised 05/30/2018

Condensate Storage and Supply B 3.7.6 BASES SURVEILLANCE SR 3.7.6.1 REQUIREMENTS This SR verifies that the combination of CST and T-81 contain the required useable volume of cooling water. (This volume ~ 100,000 gallons.) The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is based on operating experience, and the need for operator awareness of plant evolutions that may affect the Condensate Storage and Supply inventory between checks. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is considered adequate in view of other indications in the control room, including alarms , to alert the operator to abnormal CST and T-81 level deviations.

REFERENCES 1. FSAR, Section 9.7

2. Analysis EA-GOTHIC-CST-01 Palisades Nuclear Plant B 3.7.6-4 Revised 05/30/2018

SWS B 3.7.8 B 3.7 PLANT SYSTEMS B 3.7.8 Service Water System (SWS)

BASES BACKGROUND The SWS provides a heat sink for the removal of process and operating heat from safety related components during a Design Basis Accident (DBA) or transient. During normal operation or a normal shutdown, the SWS also provides this function for various safety related and nonsafety related components. The safety related function is covered by this LCO.

The isolation of the SWS to components or systems may render those components inoperable but does not affect the OPERABILITY of the SWS System .

The SWS consists of three pumps connected in parallel taking suction from a common intake structure supplied by Lake Michigan. The discharge of the pumps flow into a common header before splitting into three headers (two critical headers for safety-related equipment and a single non-critical header for non safety-related equipment) . The return piping from the three headers join into a common line and discharge to the cooling tower makeup basin. A train of SWS shall be that equipment electrically connected to a common safety bus necessary to remove heat from the various heat loads. There are two SWS trains, each associated with a Safeguards Electrical Train which are described in Specification 3.8.9, "Distribution Systems - Operating." The SWS train associated with the Left Safeguards Train consists of one SWS pump (P-7B), associated piping, valves, and controls for the equipment to perform their safety function. The SWS train associated with the Right Safeguards Train consists of two SWS pumps (P-7A, P-7C), associated piping, valves, and controls for the equipment to perform their safety function. The pumps and valves are remote manually aligned, except in the unlikely event of a Loss Of Coolant Accident (LOCA).

SWS components receive three automatic actuation signals, a Safety Injection Signal (SIS), a Recirculation Actuation Signal (RAS), or a Diesel Generator (DG) start signal :

1. SIS starts the SWS pumps, isolates the non-critical service water header, and realigns the Containment Air Cooler (CAC) service water valves to the post accident cooling configuration .

Palisades Nuclear Plant B 3.7.8-1 Revised 02/28/2019

SWS B 3.7.8 BASES BACKGROUND 2. RAS realigns the CCW heat exchanger service water outlet valves (continued) for maximum cooling.

3. A DG start signal opens the DG lube oil and jacket water cooler inlet valves.

The DG which powers two SWS pumps (P-7A, P-7C), also powers the fans associated with VHX-1, VHX-2, and VHX-3 (V-1A, V-2A and V-3A).

This is necessary because if reliance for containment cooling is placed on CACs, at least two service water pumps must be OPERABLE to provide the necessary service water flow to assure OPERABILITY of the CACs.

The Service Water System cools three groups of loads. The SWS loads are described in the FSAR (Ref. 1), the major loads are:

1. Critical loads inside the Containment, Containment Air Coolers VHX-1, VHX-2, VHX-3, (and VHX-4)

2. Critical loads outside the Containment, and Diesel Generators 1-1 and 1-2 Component Cooling Heat Exchangers E-54A and E-54B Engineered Safeguards Room Coolers VHX-27 A and VHX-27B Control Room HVAC Coolers VC-1 0 and VC 11

3. Non-critical loads in the Turbine Building Each of these groups of loads can be cooled by the flow from one SWS pump. During normal operation, when SWS flow from the CACs and CCW heat exchangers is throttled by temperature control valves, two SWS pumps can provide the required flow for all three groups of loads.

During post accident conditions, with aU other SWS and related system components OPERABLE, one hundred percent of the required SWS post accident cooling capability can be provided by anyone SWS pump. If SWS or related systems have components out of service, additional SWS pumps may be required to provide the required cooling capability.

For post accident cooling, the Engineered Safety Features signals reposition several valves to maximize containment cooling and conserve SWS flow. Initially, a safety injection signal will start the SWS pumps, realign the SWS valves for the CACs (which cool the containment atmosphere), and close the non-critical SWS header isolation valve.

Palisades Nuclear Plant B 3.7.8-2 Revised 02/28/2019

SWS B 3.7.8 BASES BACKGROUND Subsequently, if the Safety Injection Refueling Water Tank has been (continued) emptied, a RAS will realign the SWS outlet valves on the CCW heat exchangers (CCW cools the Shutdown Cooling Heat Exchangers, which cool the containment spray flow). The occurrence of these automatic actions will provide the one hundred percent of the required post accident SWS cooling capability while limiting the SWS flow requirement to that which can be provided by two SWS pumps.

If the Containment Air Coolers are not needed for post accident containment cooling. SWS flow to the containment may then be isolated, further reducing the required SWS post accident cooling capability to that which can be provided by one SWS pump.

One hundred percent of the required SWS post accident cooling capability can be provided by anyone SWS pump if SWS flow both to the non-critical header and to the critical loads inside the containment are capable of being isolated.

1. The capability to isolate SWS flow to the non-critical SWS header requires its isolation valve, CV-1359, to be OPERABLE.

2. The allowance to isolate SWS flow to the containment requires the ability to provide post accident containment cooling without reliance on CACs.

The capability to isolate SWS flow to the containment requires one SWS Containment Isolation Valve, CV-0824 or CV-0847, to be OPERABLE.

One hundred percent of the required SWS post accident cooling capability can be provided by any two SWS pumps if SWS flow either to the non-critical header or to the critical loads inside the containment are capable of being isolated.

One hundred percent of the required SWS post accident cooling capability can be provided by three SWS pumps even with SWS flow being provided to both the CACs and the Non-critical SWS header.

Additional information about the design and operation of the SWS, along with a list of the components served, is presented in the FSAR, Section 9.1 (Ref. 1). The principal safety related functions of the SWS is the removal of decay heat from the reactor via the Component Cooling Water (CCW)

System and the removal of heat from the containment atmosphere via the CACs.

Palisades Nuclear Plant B 3.7.8-3 Revised 02/28/2019

SWS B 3.7 .8 BASES APPLICABLE The design basis of the SWS is for one SWS train, in conjunction with SAFETY ANALYSES the CCW System and a 100% capacity containment cooling system (containment spray, CACs, or a combination), removing core decay heat between 20 to 40 minutes following a design basis LOCA. This prevents the containment sump fluid from increasing in temperature during the recirculation phase following a LOCA and provides for a gradual reduction in the temperature of this fluid as it is supplied to the Primary Coolant System by the safety injection pumps. The SWS is designed to perform its function with a single failure of any active component, assuming the loss of offsite power.

The SWS, in conjunction with the CCW System, also cools the plant from Shutdown Cooling (SDC) entry Condition, as discussed in the FSAR, Section 6.1 (Ref. 2) to MODE 5 during normal and post accident operations.

The time required for this evolution is a function of the number of CCW and SDC System trains that are operating. This assumes that the maximum Lake Michigan water temperature of LCO 3.7.9, "Ultimate Heat Sink (UHS),"

occurs simultaneously with maximum heat loads on the system.

The SWS satisfies Criterion 3 of 10 CFR 50.36(c)(2).

LCO Two SWS trains are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remove post accident heat loads, assuming the worst single active failure occurs coincident with the loss of offsite power.

The SWS train associated with the Left Safeguard Electrical Distribution Train is considered OPERABLE when:

a. SWS pump P-7B is OPERABLE; and

b. The associated piping, valves, and instrumentation and controls required to perform the safety related function are OPERABLE.

The SWS train associated with the Right Safeguards Electrical Distribution Train is OPERABLE when:

a. SWS pumps P-7A and P-7C are OPERABLE; and

b. The associated piping, valves, and instrumentation and controls required to perform the safety related function are OPERABLE.

The isolation of SWS from other components or systems not required for safety may render those components or systems inoperable but does not affect the OPERABILITY of the SWS System.

Palisades Nuclear Plant B 3.7.8-4 Revised 02/28/2019

SWS B 3.7.8 BASES APPLICABILITY In MODES 1, 2, 3, and 4, the SWS System is a normally operating system, which is required to support the OPERABILITY of the equipment serviced by the SWS and required to be OPERABLE in these MODES. In MODES 5 and 6, the OPERABILITY requirements of the SWS are determined by the systems it supports.

ACTIONS Condition A is applicable whenever one or more SWS trains is inoperable.

Action A.1 requires restoration of both trains to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on the assumption that at least 100% of the required SWS post accident cooling capability (that assumed in the safety analyses) is available. (If, however, less than 100% of the SWS post accident cooling is available, Condition C must also be entered .)

Mechanical system LCOs typically provide a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time under conditions when a required system can perform its required safety function, but may not be able to do so assuming an additional failure. When operating in accordance with the Required Actions of an LCO Condition, it is not necessary to be able to cope with an additional single failure.

The SWS system can provide one hundred percent of the required post accident cooling capability following the occurrence of any single active failure. Therefore, the SWS function can be met during conditions when those components which could be deactivated by a single active failure are known to be inoperable. Under that condition, however, the ability to provide the function after the occurrence of an additional failure cannot be guaranteed . Therefore, continued operation with one or more trains inoperable is allowed only for a limited time.

B.1 and B.2 Condition B is applicable when the Required Actions of Condition A cannot be completed within the required Completion Time. Condition A is applicable whenever one or more trains is inoperable. Therefore, when Condition B is applicable, Condition A is also applicable. (If less than 100% of the post accident SWS cooling capability is available, Condition C must be entered as well.) Being in Conditions A and B concurrently maintains both Completion Time clocks for instances where equipment repair allows exit from Condition B while the plant is still within the applicable conditions of the LCO.

Palisades Nuclear Plant B 3.7.8-5 Revised 02/28/2019

SWS B 3.7.8 BASES ACTIONS B.1 and B.2 (continued)

If the inoperable SWS trains cannot be restored to OPERABLE status within the associated required Completion Time of Condition A, the plant must be placed in a MODE in which the LCO does not apply. To achieve this status, the plant must be placed in 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 in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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.

Condition C is applicable with one or more trains inoperable when there is less than 100% of the required SWS post accident cooling capability available. Condition A is applicable whenever one or more trains is inoperable. Therefore, when this Condition is applicable, Condition A is also applicable. Being in Conditions A and C concurrently maintains both Completion Time clocks for instances where equipment repair restores 100%

of the required SWS post accident cooling capability while the LCO is still applicable, allowing exit from Condition C (and LCO 3.0.3) .

The Service Water System cools three groups of loads:

1. Critical loads inside the Containment,

2. Critical loads outside the Containment, and

3. Non-critical loads in the Turbine Building.

As discussed in the Background section of these bases, each of these groups of loads can be cooled by the flow from one SWS pump.

One hundred percent of the required SWS post accident cooling capability can be provided by anyone SWS pump if:

1. The non-critical SWS header isolation valve, CV-1359, is OPERABLE, and

2. Plant conditions allow adequate containment cooling to be provided without reliance on CACs and one SWS Containment Isolation Valve, CV-0824 or CV-0847, is OPERABLE.

One hundred percent of the required SWS post accident cooling capability can be provided by any two SWS pumps if:

Palisades Nuclear Plant B 3.7.8-6 Revised 02/28/2019

SWS B 3.7.8 BASES ACTIONS (continued)

1. The non-critical SWS header isolation valve, CV-1359, is OPERABLE, or

2. Plant conditions allow adequate containment cooling to be provided without reliance on CACs and one SWS Containment Isolation Valve, CV-0824 or CV-0847, is OPERABLE.

One hundred percent of the required SWS post accident cooling capability can be provided by three SWS pumps even with SWS flow being provided to both the CACs and the Non-critical SWS header.

With less than 100% of the required SWS post accident cooling capability available, the plant is in a condition outside the assumptions of the safety analyses. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.8.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the SWS flow path ensures that the proper flow paths exist for SWS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to locking, sealing, or securing . This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This SR is modified by a Note indicating that the isolation of SWS to components or systems may render those components inoperable but does not affect the OPERABILITY of the SWS.

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

Palisades Nuclear Plant B 3.7.8-7 Revised 02/28/2019

SWS B 3.7.8 BASES SURVEILLANCE SR 3.7.8.2 REQUIREMENTS This SR verifies proper automatic operation of the SWS valves on an actual or simulated actuation signal. Specific signals (e.g., safety injection) are tested under Section 3.3, "Instrumentation." This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls .

This SR is modified by a Note which states this SR is only required to be met in MODES 1, 2, and 3. The instrumentation providing the input signal is not required in MODE 4, therefore, to keep consistency with Section 3.3, "Instrumentation," the SR is not required to be met in this MODE.

Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

SR 3.7.8.3 The SR verifies proper automatic operation of the SWS pumps on an actual or simulated actuation signal in the "with standby power available" mode which tests the starting of the pumps by the SIS-X relays. The starting of the pumps by the sequencer is performed in Section 3.8, "Electrical Power Systems." This SR is modified by a Note which states this SR is not required to be met in MODE 4. The instrumentation providing the input signal is not required in MODE 4, therefore, to keep consistency with Section 3.3, "Instrumentation," the SR is not required to be met in this MODE. Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

REFERENCES 1. FSAR, Section 9.1

2. FSAR, Section 6.1 Palisades Nuclear Plant B 3.7.8-8 Revised 02/28/2019