Text

TSTF-479, Revision 0, Changes to Reflect Revision of 10 CFR 50.55a.
	ML052990317
Person / Time
Issue date:	12/02/2004
From:	Buschbaum D, Furio P, Infanger P, Morris B; B & W Owners Group, BWR Owners Group, Technical Specifications Task Force, Westinghouse Owners Group
To:	Boyce T; NRC/NRR/DIPM/IROB
References
	NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, NUREG-1434, TSTF-04-15 TSTF-479, Rev 0
	Download: ML052990317 (111)
	v • d • e

TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY December 2, 2004 TSTF-04-15 Thomas H. Boyce, Section Chief Technical Specifications Section Reactor Operations Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

TSTF-479, Revision 0, Changes to Reflect Revision of 10 CFR 50.55a

Dear Mr. Boyce:

Enclosed for NRC review is Revision 0 of TSTF-479, Revision 0, Changes to Reflect Revision of 10 CFR 50.55a.

TSTF-479 proposes to revise the Technical Specification Administrative Controls Inservice Test Program and references in the Bases to Section XI of the American Society of Mechanical Engineers (ASME) Code, to reflect the current edition of the Code referenced in 10 CFR 50.55a(b). NRC regulations require the Inservice Testing Program at nuclear power plants to be revised every 120 months to comply with the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b). The adoption of the latest edition renders incorrect certain statements in the Technical Specifications Administrative Controls Inservice Test Program and in the Bases.

We request that NRC review of TSTF-479 be granted a fee waiver pursuant to the provisions of 10 CFR 170.11. This Traveler meets the exemption requirement in 10 CFR 170.11(a)(1)(iii), in that it is a means of exchanging information between industry organizations and the NRC for the specific purpose of supporting the NRC's generic regulatory improvements or efforts. In this case, the generic regulatory effort is the NRCs revision to 10 CFR 50.55a and the need for the NRCs Standard Technical Specifications (NUREG-1430 through -1434) to be consistent with the regulations. If this change is not granted a fee waiver, please inform us so we may consider whether we wish to pursue this change.

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Email: tstf@excelservices.com Administered by EXCEL Services Corporation

TSTF 04-15 December 2, 2004 Page 2 Should you have any questions, please do not hesitate to contact us.

Dennis Buschbaum (WOG) Bert Morris (BWROG)

Patricia Furio (CEOG) Paul Infanger (BWOG)

Enclosure cc: NRC Document Control Desk

WOG-173, Rev. 0 TSTF-479, Rev. 0 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Changes to Reflect Revision of 10 CFR 50.55a NUREGs Affected: 1430 1431 1432 1433 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement: Correction NRC Fee Status: Exempt Industry

Contact:

Denny Buschbaum, (254) 897-5851, dbuschb1@txu.com

1.0 DESCRIPTION

The proposed change revises the improved Standard Technical Specification (ISTS) Administrative Controls, Inservice Testing Program, for consistency with the requirements of 10 CFR 50.55a(f)(4) for pumps and valves which are classified as American Society of Mechanical Engineers (ASME) Code Class 1, Class 2 and Class 3.

2.0 PROPOSED CHANGE

The proposed change will revise:

Inservice Testing Program This specification is revised to indicate that the Inservice Testing Program shall include testing frequencies applicable to the ASME Code for Operations and Maintenance (ASME OM Code).

It is also revised to indicate that there may be some non-standard Frequencies utilized in the Inservice Testing Program in which the provisions of SR 3.0.2 are applicable. Specifically, it is revised to state:

The provisions of SR 3.0.2 are applicable to the above required Frequencies and other normal and accelerated Frequencies specified in the Inservice Testing Program for performing inservice test activities.

Various sections of the TS Bases are also revised for consistency with the requirements of 10 CFR 50.55a(f)(4).

3.0 BACKGROUND

In 1990, the ASME published the initial edition of the ASME OM Code which gives rules for inservice testing of pumps and valves. The ASME intended that the ASME OM Code replace Section XI of the Boiler and Pressure Vessel Code for inservice testing of pumps and valves.

10-Nov-04 Traveler Rev. 3. Copyright (C) 2004, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-173, Rev. 0 TSTF-479, Rev. 0

4.0 TECHNICAL ANALYSIS

The purposes of the Inservice Testing Programs are to assess the operational readiness of pumps and valves, to detect degradation that might affect component OPERABILITY, and to maintain safety margins with provisions for increased surveillance and corrective action. NRC regulation, 10 CFR 50.55a, defines the requirements for applying industry codes to each licensed nuclear powered facility. Licensees are required by 10 CFR 50.55a(f)(4)(i) to initially prepare programs to perform inservice testing of certain ASME Section III, Code Class 1, 2, and 3 pumps and valves during the initial 120-month interval. The regulations require that programs be developed utilizing the latest edition and addenda incorporated into paragraph (b) of 10 CFR 50.55a on the date 12 months prior to the date of issuance of the operating license subject to the limitations and modification identified in paragraph (b).

NRC regulations also require that the Inservice Testing Programs be revised during successive 120-month intervals to comply with the latest edition and addenda of the Code incorporated by reference in paragraph (b) 12 months prior to the start of the interval.

Section XI of the ASME Codes has been revised on a continuing basis over the years to provide updated requirements for the inservice inspection and inservice testing of components. Until 1990, the ASME Code requirements addressing the IST of pumps and valves were contained in Section XI, Subsections IWP (pumps) and IWV (valves). In 1990, the ASME published the initial edition of the OM Code that provides the rules for the inservice testing of pumps and valves. Since the establishment of the 1990 Edition of the OM Code, the rules for the inservice testing of pumps are no longer being updated in Section XI. As identified in NRC SECY-99-017 dated January 13, 1999, the NRC has generally considered the evolution of the ASME Code to result in a net improvement in the measures for inspecting piping and components and testing pumps and valves.

The Technical Specification Inservice Testing Program is revised to indicate that the provisions of SR 3.0.2 are applicable to other IST Frequencies that are not specified in the Program. The Inservice Test Program may have Frequencies for testing that are based on risk and do not conform to the standard testing Frequencies specified in the Technical Specifications. For example, an Inservice Testing Progam may use ASME Code Case OMN-1, Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Plants, in lieu of stroke time testing. The Frequency of the Surveillance may be determined through a mix of risk informed and performance based means in accordance with the Inservice Testing Program. This is consistent with the guidance in NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants, which indicates that the 25% extension of the interval specified in the Frequency would apply to increased frequencies the same what that it applies to regular frequencies. If a test interval is specified in 10 CFR 50.55a, the TS SR 3.0.2 Bases indicates that the requirements of the regulation take precedence over the TS.

10-Nov-04 Traveler Rev. 3. Copyright (C) 2004, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-173, Rev. 0 TSTF-479, Rev. 0

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration The TSTF has evaluated whether or not a significant hazards consideration is involved with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

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

Response: No The proposed change revises the improved Standard Technical Specification (ISTS) Inservice Testing Program for consistency with the requirements of 10 CFR 50.55a(f)(4) for pumps and valves which are classified as American Society of Mechanical Engineers (ASME) Code Class 1, Class 2 and Class 3. The proposed change incorporates revisions to the ASME Code that result in a net improvement in the measures for testing pumps and valves.

The proposed change does not impact any accident initiators or analyzed events or assumed mitigation of accident or transient events. They do not involve the addition or removal of any equipment, or any design changes to the facility. Therefore, this proposed change does not represent a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No The proposed change revises the improved Standard Technical Specification (ISTS) Inservice Testing Program for consistency with the requirements of 10 CFR 50.55a(f)(4) for pumps and valves which are classified as American Society of Mechanical Engineers (ASME) Code Class 1, Class 2 and Class 3. The proposed change incorporates revisions to the ASME Code that result in a net improvement in the measures for testing pumps and valves.

The proposed change does not involve a modification to the physical configuration of the plant (i.e., no new equipment will be installed) or change in the methods governing normal plant operation. The proposed change will not impose any new or different requirements or introduce a new accident initiator, accident precursor, or malfunction mechanism. Additionally, there is no change in the types or increases in the amounts of any effluent that may be released off-site and there is no increase in individual or cumulative occupational exposure. Therefore, this proposed change does not create the possibility of an accident of a different kind than previously evaluated.

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

Response: No The proposed change revises the improved Standard Technical Specification (ISTS) Inservice Testing Program for consistency with the requirements of 10 CFR 50.55a(f)(4) for pumps and valves which are classified as American Society of Mechanical Engineers (ASME) Code Class 1, Class 2 and Class 3. The proposed change incorporates revisions to the ASME Code that result in a net improvement in the measures for testing pumps and valves. The safety function of the affected pumps and valves will be maintained. Therefore, this proposed change does not involve a significant reduction in a margin of safety.

10-Nov-04 Traveler Rev. 3. Copyright (C) 2004, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-173, Rev. 0 TSTF-479, Rev. 0 5.2 Applicable Regulatory Requirements/Criteria NRC regulation, 10 CFR 50.55a, defines the requirements for applying industry codes to each licensed nuclear powered facility. Licensees are required by 10 CFR 50.55a(f)(4)(i) to initially prepare programs to perform inservice testing of certain ASME Section III, Code Class 1, 2, and 3 pumps and valves during the initial 120-month interval. The regulations require that programs be developed utilizing the latest edition and addenda incorporated into paragraph (b) of 10 CFR 50.55a on the date 12 months prior to the date of issuance of the operating license subject to the limitations and modification identified in paragraph (b).

This Technical Specification change will not reduce the leak-tightness of the containment. Therefore, 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) Issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed change would change a requirement with respect to installation or use of a facility component located within the restricted areas, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, 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 effluent tha me 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.

7.0 REFERENCES

1. 10 CFR 50.55a

2. SECY-99-017, Proposed Amendment to 10 CFR 50.55a

3. NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants, Revision History OG Revision 0 Revision Status: Active Revision Proposed by: Wolf Creek Revision

Description:

Original Issue 10-Nov-04 Traveler Rev. 3. Copyright (C) 2004, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-173, Rev. 0 TSTF-479, Rev. 0 OG Revision 0 Revision Status: Active Owners Group Review Information Date Originated by OG: 29-Jul-03 Owners Group Comments:

(No Comments)

Owners Group Resolution: Approved Date: 29-Jul-03 TSTF Review Information TSTF Received Date: 01-Sep-04 Date Distributed for Review: 01-Sep-04 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 15-Sep-04 Affected Technical Specifications Ref. 3.8.1 Bases AC Sources - Operating NUREG(s)- 1430 1431 1432 1433 1434 Only SR 3.8.1.6 Bases AC Sources - Operating NUREG(s)- 1430 1431 1432 1433 1434 Only Ref. 3.4.10 Bases Pressurizer Safety Valves NUREG(s)- 1430 1431 1432 Only SR 3.4.10.1 Bases Pressurizer Safety Valves NUREG(s)- 1430 1431 1432 Only Ref. 3.4.11 Bases Pressurizer PORVs NUREG(s)- 1430 1431 1432 Only SR 3.4.11.1 Bases Pressurizer PORVs NUREG(s)- 1430 1431 1432 Only Ref. 3.4.14 Bases RCS PIV Leakage NUREG(s)- 1430 1431 1432 Only SR 3.4.14.1 Bases RCS PIV Leakage NUREG(s)- 1430 1431 1432 Only SR 3.5.2.4 Bases ECCS - Operating NUREG(s)- 1430 1431 1432 Only Ref. 3.7.1 Bases MSSVs NUREG(s)- 1430 1431 1432 Only SR 3.7.1.1 Bases MSSVs NUREG(s)- 1430 1431 1432 Only Ref. 3.7.2 Bases MSIVs NUREG(s)- 1430 1431 1432 Only SR 3.7.2.1 Bases MSIVs NUREG(s)- 1430 1431 1432 Only 5.5.8 Inservice Testing Program NUREG(s)- 1430 1431 1432 Only Ref. 3.5.2 Bases ECCS - Operating NUREG(s)- 1430 Only 10-Nov-04 Traveler Rev. 3. Copyright (C) 2004, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-173, Rev. 0 TSTF-479, Rev. 0 Ref. 3.6.6 Bases Containment Spray and Cooling Systems NUREG(s)- 1430 Only SR 3.6.6.4 Bases Containment Spray and Cooling Systems NUREG(s)- 1430 Only Ref. 3.7.3 Bases [MFSVs, MFCVs, and Associated SFCVs] NUREG(s)- 1430 Only SR 3.7.3.1 Bases [MFSVs, MFCVs, and Associated SFCVs] NUREG(s)- 1430 Only Ref. 3.7.5 Bases EFW System NUREG(s)- 1430 Only SR 3.7.5.2 Bases EFW System NUREG(s)- 1430 Only Ref. 3.6.6A Bases Containment Spray and Cooling Systems NUREG(s)- 1431 1432 Only Ref. 3.6.6B Bases Containment Spray and Cooling Systems NUREG(s)- 1431 1432 Only Ref. 3.6.12 Bases Vacuum Relief Valves NUREG(s)- 1431 1432 Only SR 3.6.12.1 Bases Vacuum Relief Valves NUREG(s)- 1431 1432 Only Ref. 3.7.5 Bases AFW System NUREG(s)- 1431 1432 Only SR 3.7.5.2 Bases AFW System NUREG(s)- 1431 1432 Only Ref. 3.4.12 Bases LTOP System NUREG(s)- 1431 Only SR 3.4.12.4 Bases LTOP System NUREG(s)- 1431 Only Ref. 3.6.6C Bases Containment Spray System NUREG(s)- 1431 Only Ref. 3.6.6D Bases QS System NUREG(s)- 1431 Only Ref. 3.6.6E Bases RS System NUREG(s)- 1431 Only SR 3.6.6C.2 Bases Containment Spray System NUREG(s)- 1431 Only SR 3.6.6D.2 Bases QS System NUREG(s)- 1431 Only SR 3.6.6A.4 Bases Containment Spray and Cooling Systems NUREG(s)- 1431 Only SR 3.6.6B.4 Bases Containment Spray and Cooling Systems NUREG(s)- 1431 Only SR 3.6.6E.5 Bases RS System NUREG(s)- 1431 Only Ref. 3.7.3 Bases MFIVs and MFRVs [and Associated Bypass Valves] NUREG(s)- 1431 Only SR 3.7.3.1 Bases MFIVs and MFRVs [and Associated Bypass Valves] NUREG(s)- 1431 Only SR 3.5.2.5 Bases ECCS - Operating NUREG(s)- 1432 Only SR 3.6.6B.5 Bases Containment Spray and Cooling Systems NUREG(s)- 1432 Only SR 3.6.6A.5 Bases Containment Spray and Cooling Systems NUREG(s)- 1432 Only 10-Nov-04 Traveler Rev. 3. Copyright (C) 2004, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-173, Rev. 0 TSTF-479, Rev. 0 Ref. 3.7.3 Bases MFIVs [and [MFIV] Bypass Valves] NUREG(s)- 1432 Only SR 3.7.3.1 Bases MFIVs [and [MFIV] Bypass Valves] NUREG(s)- 1432 Only Ref. 3.6.1.6 Bases LLS Valves NUREG(s)- 1433 1434 Only SR 3.6.1.6.1 Bases LLS Valves NUREG(s)- 1433 1434 Only Ref. 3.6.2.3 Bases RHR Suppression Pool Cooling NUREG(s)- 1433 1434 Only SR 3.6.2.3.2 Bases RHR Suppression Pool Cooling NUREG(s)- 1433 1434 Only 5.5.7 Inservice Testing Program NUREG(s)- 1433 1434 Only SR SR 3.5.1.7 Bases ECCS - Operating NUREG(s)- 1433 Only Ref. 3.4.3 Bases S/RVs NUREG(s)- 1433 Only SR 3.4.3.2 Bases S/RVs NUREG(s)- 1433 Only Ref. 3.4.5 Bases RCS PIV Leakage NUREG(s)- 1433 Only SR 3.4.5.1 Bases RCS PIV Leakage NUREG(s)- 1433 Only Ref. 3.6.2.4 Bases RHR Suppression Pool Spray NUREG(s)- 1433 Only SR 3.6.2.4.2 Bases RHR Suppression Pool Spray NUREG(s)- 1433 Only SR SR 3.5.1.4 Bases ECCS - Operating NUREG(s)- 1434 Only Ref. 3.4.3 Bases S/RVs NUREG(s)- 1434 Only SR 3.4.4.2 Bases S/RVs NUREG(s)- 1434 Only Ref. 3.4.6 Bases RCS PIV Leakage NUREG(s)- 1434 Only SR 3.4.6.1 Bases RCS PIV Leakage NUREG(s)- 1434 Only Ref. 3.6.1.7 Bases RHR Containment Spray System NUREG(s)- 1434 Only SR 3.6.1.7.2 Bases RHR Containment Spray System NUREG(s)- 1434 Only 10-Nov-04 Traveler Rev. 3. Copyright (C) 2004, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-479, Rev. 0 INSERT 1 ASME code for Operation and Maintenance of Nuclear Power Plants.

TSTF-479, Rev. 0 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.4 Radioactive Effluent Controls Proqram (continued)

j. Limitations on the annual dose or dose commitment to any member of the public, beyond the site boundary, due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Radioactive Effluent Controls Program surveillance frequency.

Component Cvclic or Transient Limit This program provides controls to track the FSAR, Section [ 1, cyclic and transient occurrences to ensure that components are maintained within the design limits.

[ Pre-Stressed Concrete Containment Tendon Surveillance Proqram This program provides controls for Monitoring any tendon degradation in pre-stressed concrete containments, including effectiveness of its corrosion protection medium, to ensure containment structural integrity. The program shall include baseline measurements prior to initial operations. The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with [Regulatory Guide 1.35, Revision 3, 19901.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Tendon Surveillance Program inspection frequencies. ]

Reactor Coolant P u m Flvwheel

~ Insbection Program This program shall provide for the inspection of each reactor coolant pump flywheel per the recommendation of Regulatory position c.4.b of Regulatory Guide 1.14, Revision 1, August 1975.

Inservice Testing Program This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 components. The program shall include the following:

BWOG STS 5.5-4 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 lnservice Testing Proaram (continued)

ASME ( $ o w ~re&e ~4) e Code and applicable Addenda Required Frequencies for terminology for inservice testing performing inservice testing activities activities Weekly At least once per 7 days Monthly At least .once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days

b. The provisions of SR 3.0.2 a r e a ~ ~ l i c a bto l ethe above reauired

~ r e q u e n c i e ~ fperforming or inservice testing activities,

c. The provisions of SR 3.0.3 are applicable to inservice testing activities, and

d. Nothing in the ASME Code shall be construed to supersede the req Steam Generator (SG) Tube Surveillance Program

........................................ REVI~WER'SNOTE........................................

The Licensee's current licensing basis steam generator tube surveillance requirements shall be relocated from the L C 0 and included here. An appropriate administrative controls program format should be used.

The provisions of SR 3.0.2 are appliqable to the SG Tube Surveillance Program test frequencies.

Secondary Water Chemistry Proararn This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low bressure turbine disc stress corrosion cracking. The program shall include:

a. ldentification of a sampling schedule for the critical variables and control points for these variables,

b. ldentification of the procedures used to measure the values of the critical variables, BWOG STS 5.5-5 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 Pressurizer Safety Valves B 3.4.10 BASES LC0 (continued)

ACTIONS 1

condition. Only one valve at time will be removed from service for testing. The [36] hour except on is based on an 18 hour2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months outage time for each of the two valves. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period is derived from operating experience that hot testing cB be performed in this timeframe.

Wlth one pressurizer safety valve inoperable, restoration must take place within 15 minutes. The Completion Time of 15 minutes reflects the importance of maintaining thd RCS overpressure protection system. An inoperable safety valve coincibent with an R c s overpressure event could challenge the integrity of the RCPB.

B.l and B.2 If the Required Action met within the required Completion Time or if both pressurizer are inoperable, the plant must be brought to a MODE does not apply. To achieve this status, the plant MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 with 5 [283IoFwithin 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The 6 experience, to change from MODE 1,2, or 3 t o MODE 4 reduces the RCS energy (core power and pressure), lowers potential for large pressurizer insurges, and thereby removes the overpressure protection by two pressurizer safety valves.

SURVEILLANCE SR 3.4.10.1 REQUIREMENTS SRs are specified in the lnserbice Testing Program. Pressurizer safet valves are to be tested in accordance with the requirements of the ASME Code (Ref. I ) , vyhich provides the activities and the Frequency necessary to satisiy the SRs. No additional requirements are specified. I The pressurizer safety valve setpoint is [3]% for OPERABILITY; however, the valves are reset to 1% during the Surveillance to allow for drift.

I BWOG STS B 3.4.10-3 i Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 Pressurizer Safety Valves B 3.4.10 BASES I BWOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 Pressurizer PORV B 3.4.11 BASES ACTIONS (continued) 8.1 and 8.2 If the block valve is inoperabl4, it must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The prime impQrtancefor the capability to close the block valve is to isolate a stuck ope0 PORV. Therefore, if the block valve cannot be restored to OPERqBLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the Required Action is to close the block valve and remove power within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rendering the PORV isolated,,The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Times are consistent with an allowance Of some time for correcting minor problems, restoring the valve to operation, and establishing correct valve positions and restricting the time without adequate protection against RCS depressurization.

C.1 and C.2 If the Required Action and as$ociated Completion Time cannot be met, the plant must be brought to B( MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowed is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. Similarly, the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed is reasonable, based on operating experience, to reaqq MODE 4 from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.1 1.1 REQUIREMENTS Block valve cycling verifies th,+tit can be closed if needed. The basis for the Frequency of 92 days is ASME ~odefWtr6fnX) (Ref. 3). Block valve cycling, as stated in the Note, i s not required to be performed when it is closed for isolation; cycling cohd increase the hazard of an existing degraded flow path.

PORV cycling demonstrates its function. The Frequency of 18 months is based on a typical refueling oycle and industry accepted practice.

BWOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 Pressurizer PORV B 3.4.11 BASES SURVEILLANCE REQUIREMENTS (continued)

This Surveillance is not required for plants with permanent 1E power supplies to the valves.

This SR demonstrates that emergency power can be provided and is performed by transferring power from the normal supply to the emergency supply and cycling the valves. The Frequency of 18 months is based on a typical refueling cycle and ihdustry accepted practice.

REFERENCES 1. NUREG-0737, Paragraph Ill, G.1, November 1980.

2. NRC IE Bulletin 79-05B, April 21, 1979.

BWOG STS Rev. 3.0. 03/31/04

TSTF-479, Rev. 0 RCS PIV Leakage B 3.4.14 BASES SURVEILLANCE SR 3.4.14.1 REQUIREMENTS Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.l or A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition.

For the two PlVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PlVs are not individually leakage tested, one valve may have failed completely and not detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.

Testing is to be performed every [I81 months, a typical refueling cycle, if the plant does not go into MODE 5 for at least 7 days. The [ I 8 month]

Frequency is consistent with 10 CFR 50.55a(g) (Ref. 8) as contained in the lnservice Testing Program, is within frequency allowed by the American Society of Mechanical Engineers (ASME) c o d - %

(Ref. 7), and is based on the need to perform such surveillances under conditions that apply during an outage and the potential for an unplanned transient if the Surveillance were performed with the plant at power.

[ In addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PlVs disturbed in the performance of this Surveillance should also be tested unless documentation shows that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the valve has been reseated. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable and practical time limit for performing this test after opening or reseating a valve. ]

The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures.

Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complimentary to the Frequency of prior to entry into MODE 2 whenever the unit has been BWOG STS 6 3.4.14-5 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 RCS PIV Leakage B 3.4.14 BASES SURVEILLANCE REQUIREMENTS (continued)

These SRs are modified by Notes allowing the DHR autoclosure function to be disabled when using the DHR System suction relief valve for cold overpressure protection in accordance with LC0 3.4.12. ]

REFERENCES 1. 10 CFR 50.2.

2. 10 CFR 55a(c).

3. 10 CFR 50, Appendix A, Section V, GDC 55.

4. NUREG-751014, Appendix V, October 1975.

5. NUREG-0677, NRC, May 1980.

6. [Document containing list of PIVs.]

8. 10 CFR 50.55ah).

BWOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 ECCS - Operating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued)

Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required b y ~ ~ X C a F ) t ASMEh e Code (Ref. 6). This type of testing may be accomplished by measuring the pump's developed head at only one point of the pump's characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline peflormance and that the performance at the test flow is greater than or equal to the performance assumed in the plant 5 provides the actiqities and Frequencies necessary to satisfy the requirements.

SR 3.5.2.5 and SR 3.5.2.6 These SRs demonstrate that each automatic ECCS valve actuates to the required position on an actual or simulated ESFAS signal and that each ECCS pump starts on receipt ?f an actual or simulated ESFAS signal.

This SR is not required for valyes that are locked, sealed, or otherwise secured in position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during il plant outage and the potential for an unplanned transient if the Suhleillance were performed with the reactor at power. The 18 month Frequehcy is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment. The actuation logic is tested as part of the ESFAS testing, and equipment performance is monitored as part of the lnservice Testing Program.

This Surveillance ensures that these valves are in the proper position to prevent the HPI pump from exceeding its runout limit. This 18 month Frequency is based on the sahe reasons as those stated for SR 3.5.2.5 and SR 3.5.2.6.

BWOG STS B 3.5.2-8 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 ECCS - Operating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued)

This Surveillance ensures that the flow controllers for the LPI throttle valves will automatically control the LPI train flow rate in the desired range and prevent LPI pump runout as RCS pressure decreases after a LOCA. The 18 month Frequency is justified by the same reasons as those stated for SR 3.5.2.5 and SR 3.5.2.6.

Periodic inspections of the containment sump suction inlet ensure that it is unrestricted and stays in proper operating condition. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage, on the need to preserve access to the location, and on the potential for an unplanned transient if the Surveillance were performed with the reactor at power. This Frequency has been found to be sufficient to detect abnormal degradation and has been confirmed by operating experience.

REFERENCES 1. 10 CFR 50.46.

2. FSAR, Section [6.3].

3. BAW-2295-A, Revision 1, Justification for Extension of Allowed Outage Time for Low Pressure Injection and Reactor Building Spray System.

4. NRC Memorandum to V. Stello, Jr., from R.L. Baer, "Recommended Interim Revisions to LCOs for ECCS Components,"

December 1, 1975.

5. IE Information Notice 87-01, "RHR Valve Misalignment Causes Degradation of ECCS in PWRs," January 6, 1987.

BWOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 Containment Spray and Cooling Systems B 3.6.6 BASES SURVEILLANCE REQUIREMENTS (continued)

Verifying that each [required] containment cooling train provides an essential raw water cooling flow rate of r [I7801 gpm to each cooling unit provides assurance that the design flow rate assumed in the safety analyses will be achieved (Ref. 1). The Frequency was developed considering the known reliability of the Cooling Water System, the two train redundancy available, and the low probability of a significant degradation of flow occurring between surveillances.

Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential pressure are normal tests of centrifugal pump performance required b - v g t h e ASME Code (Ref. 6). Since the Containment Spray System pumps cannot be tested with flow through the spray headers, they are tested on recirculation flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the lnservice Testing Program.

SR 3.6.6.5 and SR 3.6.6.6 These SRs require verification that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of arr actual or simulated actuation signal. This SR is not required for valves that are locked, sealed, or otherwise secured in position under administrative controls. The [I81 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillances when performed at the [I81 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

BWOG STS B 3.6.6-8 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 Containment Spray and Cooling Systems B 3.6.6 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR requires verification that each [required] containment cooling train actuates upon receipt of an actual or simulated actuation signal.

The 1181 month Frequency is based on engineering judgment and has been shown to be acceptable through operating experience. See SR 3.6.6.5 and SR 3.6.6.6, above, for further discussion of the basis for the 1181 month Frequency.

With the containment spray header isolated and drained of any solution, low pressure air or smoke can be blown through test connections.

Performance of this Surveillance demonstrates that each spray nozzle is unobstructed and provides as$urance that spray coverage of the containment during an accident is not degraded. Due to the passive nature of the design of the nozzles, a test at [the first refueling and at]

10 year intervals is considered adequate to detect obstruction of the spray nozzles.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 38, GDC 39, GDC 40, GDC 41, GDC 42, and GDC 43.

2. FSAR, Section [14.1].

3. FSAR, Section [6.3].

4. FSAR, Section [14.2].

5. BAW-2295-A, Revision 1, Justification for Extension of Allowed Outage Time for Low Pressure Injection and Reactor Building Spray Systems.

BWOG STS Rev. 3.0, 03/31/04 I

TSTF-479, Rev. 0 MSSVs B 3.7.1 BASES ACTIONS (continued) reduce the setpoints. The Completion Time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months for Required Action A.2 is based on a reasonable time to correct the MSSV inoperability, the time required to perform the power reduction, operating experience in resetting all channels of a protective function, and on the low probability of the occurrence of a transient that could result in steam generator overpressure during this period.

B.l and B.2 W~thone or more MSSVs inoperable, a verification by administrative means that at least [two] required MSSVs per steam generator are OPERABLE, with each valve from a different lift setting range, is performed.

If the MSSVs cannot be restored to OPERABLE status in the associated Completion Time, the unit must be placed in a MODE in which the LC0 does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasorlable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.1.I REQUIREMENTS This SR verifies the OPERABILITY of the MSSVs by the verification of each MSSV lift setpoint in ith the Inservice Testing Program. The ASME Cod Ref. 4) requires that safety and relief valve tests be perfor nce with ANSIIASME OM-1-1987 (Ref. 5). According to Reference 5, the following tests are required for MSSVs:

a. Visual examination,

b. Seat tightness determination,

c. Setpoint pressure determination (lift setting),

d. Compliance with owner's seat tightness criteria, and

e. Verification of the balancing device integrity device on balanced valves.

BWOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 MSSVs B 3.7.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The ANWASME Standard requires the testing of all valves every 5 years, with a minimum of 20% of the valves tested every 24 months.

Reference 4 provides the activities and frequencies necessary to satisfy the requirements. Table 3.7.1-1 allows a k [3]% setpoint tolerance for OPERABILITY; however, the valves are reset to k 1% during the Surveillance to allow for drift.

This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. The MSSVs may be either bench tested or tested in situ at hot conditions using an assist device to simulate lift pressure. If the MSSVs are not tested at hot conditions, the lift setting pressure shall be corrected to ambient conditions of the valve at operating temperature and pressure.

REFERENCES 1. FSAR, Section [5.2].

2. ASME, Boiler and Pressure Vessel Code, Section Ill, Article NC-7000, Class 2 Components.

3. FSAR, Section [15.2].

4.

BWOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 MSlVs B 3.7.2 BASES ACTIONS (continued)

D . l and D.2 If the MSlV cannot be restored to OPERABLE status or closed in the associated Completion Time, the unit must be placed in a MODE in which the LC0 does not apply. To qchieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies that MSlV closure time of each MSlV is I [6] seconds.

The MSlV isolation time is assumed in the accident and containment analyses. This Surveillance is normally performed upon returning the unit to operation following a refueling outage, because the MSlVs should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generating power. As the MSlVs are not to be tested at power, they are exempt from the ASME Code (Ref. 5) requirements during operation in MODES 1 and 2.

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

This test is conducted in MODE 3, with the unit at operating temperature and pressure. This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. This allows delaying testing until MODE 3 in order to establish conditions consistent with those under which the acceptance criterion was generated.

This SR verifies that each MSlV can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage. The Frequency of MSlV testing is every [I81 months. The [I81 month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the

[I81 month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

BWOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 BASES REFERENCES 1. FSAR, Section [10.3].

2. FSAR, Section [6.2].

3. FSAR, Section [15.4].

4. 10 CFR 100.11.

BWOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0

[MFSVs, MFCVs, and Associated SFCVs]

B 3.7.3 BASES ACTIONS (continued)

E.1 and E.2 If the [MFSVs], [MFCVs], and [associated SFCVs] cannot be restored to OPERABLE status, or closed, or isolated within the associated Completion Time, the unit must be in a MODE in which the LC0 does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that the closure time of each [MFSV], [MFCV], and

[associated SFCV] is 2 7 seconds.

The [MFSV], [MFCV], and [associated SFCV] isolation time is assumed in the accident and containment analyses. This Surveillance is normally performed upon returning the unit to operation following a refueling outage. The [MFSV], [MFCV], and [associated SFCV] should not be tested at power since even a part stroke exercise increases the risk of a valve closu it geqerating power. This is consistent with the ASME Cod (Ref. 2) requirements during operation in MODES 1 and 2.

This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR.

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

This SR verifies that each [MFSV, MFCV, and associated SFCV] can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage.

The Frequency for this SR is every [I81 months. The [I81 month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the [ I 81 month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

BWOG STS B 3.7.3-5 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0

[MFSVs, MFCVs, and Associated SFCVs]

B 3.7.3 BASES REFERENCES 1. FSAR, Section [10.4.7].

2. h s ~ @ a n d ~ r d ~ ee s d d eS, p 6 n XI)

BWOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 EFW System B 3.7.5 BASES SURVEILLANCE REQUIREMENTS (continued)

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

Verifying that each EFW pump's developed head at the flow test point is greater than or equal to the required developed head ensures that EFW pump performance has not degraded during the cycle. Flow and differential head are normal tests of pump performance required by Wn'mthe ASME Code (Ref. 3). Because it is undesirable to introduce cold EFW into the steam generators while they are operating, this test is performed on recirculation flow.

This test confirms one point on the pump design curve and is indicative of overall performance. Such in$ervice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnorm rmance. Performance of inservice testing in the ASME Cod Ref. 3), at 3 month intervals, satisfies this requirement.

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

This SR verifies that EFW can be delivered to the appropriate steam generator in the event of any gccident or transient that generates a Steam and Feedwater Rupture Control System (SFRCS) signal by demonstrating that each automatic valve in the flow path actuates to its correct position on an actual or simulated actuation signal. This SR is not required for valves that are locked, sealed, or otherwise secured in position under administrative ~ontrols.The [I81 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The

[I81 month Frequency is also acceptable based on operatipg experience and design reliability of the equipment. This SR is modified by a Note that states the SR is not required to be met in MODE 4. In MODE 4, the required AFW train is already aligned and operating. This SR is modified by [a] [two] Note[s]. [Note 1 indicates that the SR be deferred until BWOG STS B 3.7.5-7 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 EFW System B 3.7.5 BASES SURVEILLANCE REQUIREMENTS (continued)

System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgment, in view of other administrative controls to ensure that the flow paths are OPERABLE. To further ensure EFW System alignment, flow path PERA ABILITY is verified, following extended outages to determine no misalignment of valves has occurred.

This SR ensures that the flow path from the CST to the steam generator is properly aligned. (This SR is not required by those units that use EFW for normal startup and shutdown.)

[ SR 3.7.5.6 and SR 3.7.5.7 For this facility, the CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION for the EFW pump suction pressure interlocks are as follows:

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 i$ 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 at least once per refueling interval with applicable extensions. ]

REFERENCES 1. FSAR, Section [9.2.7].

2. FSAR, Section [9.2.8]. &xy1se/f 1) and ~ & e Vessel @ ~ e c t i d x l _ )

BWOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUlREMENTS (continued)

This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.

[ The Frequency for this SR is variable, depending on individual system design, with up to a 1921day interval. The 1921 day Frequency corresponds to the testing requirements for pumps as contained in the ASME ~odm-N(~ef. 12); however, the design of fuel transfer systems is such that pumps will operate automatically or must be started manually in order to maintain an adequate volume of fuel oil in the day

[and engine mounted] tanks during or following DG testing. In such a case, a 31 day Frequency is appropriate. Since proper operation of fuel transfer systems is an inherent part of DG OPERABILITY, the Frequency of this SR should be modified to reflect individual designs. ]

See SR 3.8.1.2.

Transfer of each [4.16 kV ESF bus] power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads.

The [ I 8 month] Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the [ I 8 month] Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

BWOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 AC Sources - Operating B 3.8.1 BASES REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. FSAR, Chapter [8].

3. Regulatory Guide 1.9, Rev. 3.

4. FSAR, Chapter [6].

5. FSAR, Chapter [ I 51.

6. Regulatory Guide 1.93, Rev. [0], [date].

7. Generic Letter 84-15.

8. 10 CFR 50, Appendix A, GDC 18.

9. Regulatory Guide 1.108, Rev. [I], [August 19771.

10. Regulatory Guide 1.I 37, Rev. [ ] , [date].

11.

12.

13, IEEE Standard 308-[I 9781.

BWOG STS Rev. 3.0, 03/31/04

TSTF-479, Programs and Rev. 0 Manuals 5.5 5.5 Programs and Manuals 5.5.7 Reactor Coolant Pump Flywheel lnspection Program (continued)

- REVIEWER'S NOTES -

1. The inspection interval and scope for RCP flywheels stated above can be applied to plants that satisfy the staff requirements in the safety evaluation of Topical Report, WCAP-14535A, "Topical Report on Reactor Coolant Pump Flywheel lnspection Elimination."

2. Licensees shall confirm that the flywheels are made of SA 533 B material.

Further, licensees having Group-15 flywheels (as determined in WCAP-14535A, "Topical Report on Reactor Coolant Pump Flywheel lnspection Elimination") need to demonstrate that material properties of their A516 material is equivalent to SA 533 B material, and its reference temperature, RT, is less than 30 O F .

3. For flywheels not made of SA 533 B or A516 material, licensees need to either demonstrate that the flywheel material properties are bounded by those of SA 533 B material, or provide the minimum specified ultimate tensile stress, the fracture toughness, and the reference temperature, RTNDT, for that material. For the latter, the licensees should employ these material properties, and use the methodology in the topical report, as extended in the two responses to the staff's RAI, to provide an assessment to justify a change in inspection schedule for their plants.

4. Licensees with Group-10 flywheels need to confirm that their flywheels have an adequate shrink fit to preclude loss of shrink fit of the flywheel at the maximum overspeed, or to provide an evaluation demonstrating that no detrimental effects would occur if the shrink fit was lost as maximum overmeed.

pp/;ub/c jome I I ~ W I G WCL r wy=----

5.5.8 Inservice Testina Proaram nd hrr d ddf4' p" OUeC. ~~46)

SME OA 6de)

This program provides controls for inserv~cetesting/of ASME Code Class 1, 2, and 3 components. The program shall include the-following:

1

~ d d e s d aterminology for performing inservice testing inservice testing activities activities Weekly At least once per 7 days WOG STS 5.5 - 5 Rev. 2, 04/30/01

TSTF-479, Rev. 0 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Inservice Testing Program (continued)

A S M F - ~ ~ ~ PresSur

@&ellcode and applicable Required Frequencies for Addenda terminology for performing inservice testing inservice testing activities activities Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Ily or every 2 years At least once per 731 days visions of SR 3.0.2 are applicable to the above required for performing inservice testing activities, ns of SR 3.0.3 are applicable to inservice testing activities, and

d. Nothing in the ASME ode shall be construed to supersede the req Steam Generator (SG) Tube Surveillance Proaram

- REVIEWER'S NOTE -

The Licensee's current licensing basis steam generator tube surveillance requirements shall be relocated from the LC0 and included here. An appropriate administrative controls program format should be used.

The provisions of SR 3.0.2 are applicable to the SG Tube Surveillance Program test frequencies.

5.5.10 Secondarv Water Chemistrv Proaram This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:

a. ldentification of a sampling schedule for the critical variables and control points for these variables,

b. ldentification of the procedures used to measure the values of the critical variables, WOG STS 5.5 - 6 Rev. 2, 04/30/01

TSTF-479, Rev. 0 Pressurizer Safety Valves B 3.4.10 BASES ACTIONS (continued) power and pressure), lowers the potential for large pressurizer insurges, and thereby removes the need for overpressure protection by [three]

pressurizer safety valves.

SURVEILLANCE SR 3.4.10.1 REQUIREMENTS SRs are specified in the Inservice Testing Program. Pressurizer safet valves are to bettested in accordance with the r e q u i r e m e n t s @ m g of the ASME Code (Ref. 4), which provides the activities and Frequenc~es necessary to satisfy the SRs. No additional requirements are specified.

+

The pressurizer safety valve setpoint is [3]% for OPERABILITY; however, the valves are reset to k 1% during the Surveillance to allow for drift.

REFERENCES 1. ASME, Boiler and Pressure Vessel Code, Section Ill.

2. FSAR, Chapter [15].

3. WCAP-7769, Rev. 1, June 1972.

WOG STS Rev. 2, 04/30/01

TSTF-479, Rev. 0 Pressurizer PORVs B 3.4.1 1 BASES ACTIONS (continued) based on the small potential for challenges to the system during this time and provide the operator time to correct the situation.

The Required Actions F.l, F.2, and F.3 are modified by a Note stating that the Required Actions do not apply if the sole reason for the block valve being declared inoperable is a result of power being removed to comply with other Required Actions. In this event, the Required Actions for inoperable PORV(s) (which require the block valve power to be removed once it is closed) are adequate to address the condition. While it may be desirable to also place the PORV(s) in manual control, this may not be possible for all causes of Condition B or E entry with PORV(s) inoperable and not capable of being manually cycled (e.g., as a result of failed control power fuse(s) or control switch malfunctions(s)).

G.l and G.2 If the Required Actions of Condition F are not met, then the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4 and 5, automatic PORV OPERABILITY may be required. See LC0 3.4.12.

SURVEILLANCE SR 3.4.1 1. I REQUIREMENTS Block valve cycling verifies that the valve(s) can be opened and closed if needed. The basis for the Frequency of 92 days is the ASME code&

@ r m ~ e f3)..

This SR is modified by two Notes. Note Imodifies this SR by stating that it is not required to be performed with the block valve closed in accordance with the Required Actions of this LCO. Opening the block valve in this condition increases the risk of an unisolable leak from the RCS since the PORV is already inoperable. Note 2 modifies this SR to allow entry into and operation in MODE 3 prior to performing the SR.

This allows the test to be performed in MODE 3 under operating temperature and pressure conditions, prior to entering MODE 1 or 2. [In accordance with Reference 4, administrative controls require this test be performed in MODE 3 or 4 to adequately simulate operating temperature and pressure effects on PORV operation.]

WOG STS B 3.4.11 - 6 Rev. 2, 04/30/01

TSTF-479, Rev. 0 Pressurizer PORVs B 3.4.1 1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.11.2 requires a complete cycle of each PORV. Operating a PORV through one complete cycle ensures that the PORV can be manually actuated for mitigation of an SGTR. The Frequency of

[I81 months is based on a typical refueling cycle and industry accepted practice.

The Note modifies this SR to allow entry into and operation in MODE 3 prior to performing the SR. This allows the test to be performed in MODE 3 under operating temperature and pressure conditions, prior to entering MODE 1 or 2. [In accordance with Reference 4, administrative controls require this test be performed in MODE 3 or 4 to adequately simulate operating temperature and pressure effects on PORV operation.]

Operating the solenoid air control valves and check valves on the air accumulators ensures the PORV control system actuates properly when called upon. The Frequency of [I81 months is based on a typical refueling cycle and the Frequency of the other Surveillances used to demonstrate PORV OPERABILITY. ]

[SR 3.4.11.4 This Surveillance is not required for plants with permanent 1E power supplies to the valves.

The Surveillance demonstrates that emergency power can be provided and is performed by transferring power from normal to emergency supply and cycling the valves. The Frequency of [I81 months is based on a typical refueling cycle and industry accepted practice. ]

REFERENCES 1. Regulatory Guide 1.32, February 1977.

2. FSAR, Section [15.2].

WOG STS B 3.4.11 - 7 Rev. 2, 04130101

TSTF-479, Rev. 0 LTOP System B 3.4.12 BASES SURVEILLANCE REQUIREMENTS (continued) single action will not result in an injection into the RCS. This may be accomplished through the pump control switch being placed in [pull to lock] and at least one valve in the discharge flow path being closed.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, considering other indications and alarms available to the operator in the control room, to verify the required status of the equipment.

Each required RHR suction relief valve shall be demonstrated OPERABLE by verifying its RHR suction valve and RHR suction isolation valves are open and by testing it in accordance with the lnservice Testing Program. (Refer to SR 3.4.12.7 for the RHR suction isolation valve Surveillance.) This Surveillance is only required to be performed if the RHR suction relief valve is being used to meet this LCO.

The RHR suction valve is verified to be opened every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The Frequency is considered adequate in view of other administrative controls such as valve status indications available to the operator in the control room that verify the RHR suction valve remains open.

The ASME ~ o d e @ a ) ( ~ e f 8), . test per lnservice Testing Program verifies OPERABILITY by proving proper relief valve mechanical motion and by measuring and, if required, adjusting the lift setpoint. ]

The RCS vent of 2 12.071 square inches is proven OPERABLE by verifying its open condition either:

a. Once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for a valve that is not locked (valves that are sealed or secured in the open position are considered "locked" in this context) or

b. Once every 31 days for other vent path(s) (e.g., a vent valve that is locked, sealed, or secured in position or a removed pressurizer safety valve or open manway also fits this category).

The passive vent path arrangement must only be open to be OPERABLE. This Surveillance is required to be met if the vent is being used to satisfy the pressure relief requirements of the LC0 3.4.12d.

WOG STS B 3.4.12 - 11 Rev. 2, 04/30/01

TSTF-479, Rev. 0 LTOP System B 3.4.12 BASES SURVEILLANCE REQUIREMENTS (continued) change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL OPERATIONAL 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 at least once per refueling interval with applicable extensions. The COT will verify the setpoint is within the PTLR allowed maximum limits in the PTLR. PORV actuation could depressurize the RCS and is not required.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency considers the unlikelihood of a low temperature overpressure event during this time.

A Note has been added indicating that this SR is required to be performed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS cold leg temperature to I [275"F] [LTOP arming temperature specified in the PTLR]. The COT cannot be performed until in the LTOP MODES when the PORV lift setpoint can be reduced to the LTOP setting. The test must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering the LTOP MODES.

Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every [I81 months to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input.

REFERENCES 1. 10 CFR 50, Appendix G.

2. Generic Letter 88-11

3. ASME, Boiler and Pressure Vessel Code, Section Ill.

4. FSAR, Chapter [I51

5. 10 CFR 50, Section 50.46.

6. 10 CFR 50, Appendix K.

7. Generic Letter 90-06. ,

rr-

8. ~ S M E i , m r e s s u r e Vess-de, Section X l n ~ ~ M S e f l + g WOG STS B 3.4.12 - 13 Rev. 2, 04/30/01

TSTF-479, Rev. 0 RCS PIV Leakage B 3.4.14 BASES SURVEILLANCE SR 3.4.14.1 REQUIREMENTS Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.l and Required Action A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition.

For the two PlVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PlVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.

Testing is to be performed every [I81 months, a typical refueling cycle, if the plant does not go into MODE 5 for at least 7 days. The [ I 8 month]

Frequency is consistent with 10 CFR 50.55a(g) (Ref. 8) as contained in the lnservice Testing Program, is within frequency allowed by the American Society of Mechanical Engineers (ASME) ~ o d e ( ~ d n d (Ref. 7), and is based on the need to perform such surveillances under the conditions that apply during an outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

In addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PlVs disturbed in the performance of this Surveillance should also be tested unless documentation shows that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the valve has been reseated. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable and practical time limit for performing this test after opening or reseating a valve.

The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures.

Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complementary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. In addition, this Surveillance is not required to WOG STS B 3.4.14 - 5 Rev. 2, 04/30/01

TSTF-479, Rev. 0 RCS PIV Leakage B 3.4.14 BASES SURVEILLANCE REQUIREMENTS (continued) be performed on the RHR System when the RHR System is aligned to the RCS in the shutdown cooling mode of operation. PlVs contained in the RHR shutdown cooling flow path must be leakage rate tested after RHR is secured and stable unit conditions and the necessary differential pressures are established.

[ SR 3.4.14.2 and SR 3.4.14.3 Verifying that the RHR autoclosure interlocks are OPERABLE ensures that RCS pressure will not pressurize the RHR system beyond 125% of its design pressure of [600] psig. The interlock setpoint that prevents the valves from being opened is set so the actual RCS pressure must be

< [425] psig to open the valves. This setpoint ensures the RHR design pressure will not be exceeded and the RHR relief valves will not lift. The

[I81 month Frequency is based on the need to perform the Surveillance under conditions that apply during a plant outage. The [I81 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.

These SRs are modified by Notes allowing the RHR autoclosure function to be disabled when using the RHR System suction relief valves for cold overpressure protection in accordance with SR 3.4.12.7. ]

REFERENCES 1. 10 CFR 50.2.

10 CFR 50.55a(c).

10 CFR 50, Appendix A, Section V, GDC 55.

WASH-1400 (NUREG-75/014), Appendix V, October 1975.

NUREG-0677, May 1980.

Document containing list of PIVs. ]

CSME, e d Pressure vesel&e, Section 10 CFR 50.55a(g).

I WOG STS Rev. 2, 04/30/01

TSTF-479, Rev. 0 ECCS - Operating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued) or securing. A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve will automatically reposition within the proper stroke time. This Surveillance does not require any testing or valve manipulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct position. The 31 day Frequency is appropriate because the valves are operated under administrative control, and an improper valve position would only affect a single train. This Frequency has been shown to be acceptable through operating experience.

With the exception of the operating centrifugal charging pump, the ECCS pumps are normally in a standby, nonoperating mode. As such, flow path piping has the potential to develop voids and pockets of entrained gases.

Maintaining the piping from the ECCS pumps to the RCS full of water ensures that the system will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent water hammer, pump cavitation, and pumping of noncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an SI signal or during shutdown cooling. The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the ECCS piping and the procedural controls governing system operation.

Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damaqe or other hydraulic component problems is required b@ec-o$he ASME Code. This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the plant ASME Code provides the activities and Frequencies necessary to satisfy the requirements.

SR 3.5.2.5 and SR 3.5.2.6 These Surveillances demonstrate that each automatic ECCS valve actuates to the required position on an actual or simulated SI signal and WOG STS B 3.5.2 - 8 Rev. 2, 04/30/01

TSTF-479, Rev. 0 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6A BASES SURVEILLANCE REQUIREMENTS (continued)

Operating each [required] containment cooling train fan unit for 2 15 minutes ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The 31 day Frequency was developed considering the known reliability of the fan units and controls, the two train redundancy available, and the low probability of significant degradation of the containment cooling train occurring between surveillances. It has also been shown to be acceptable through operating experience.

Verifying that each [required] containment cooling train ESW cooling flow rate to each cooling unit is 2 [700] gpm provides assurance that the design flow rate assumed in the safety analyses will be achieved (Ref. 3).

The Frequency was developed considering the known reliability of the Cooling Water System, the two train redundancy available, and the low probability of a significant degradation of flow occurring between surveillances.

Verifying each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential pressure are normal t s of centrifugal pump performance required b y @ e @ d % l e ASME Code (Ref. 8). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on recirculation flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by abnormal performance. The Frequency of the SR is in accordance with the Inservice Testing Program.

SR 3.6.6A.5 and SR 3.6.6A.6 These SRs require verification that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation of a containment High-3 pressure signal. This Surveillance is not required for WOG STS B 3.6.6A - 8 Rev. 2, 04/30/01

TSTF-479,and Containment Spray and Cooling Systems (Atmospheric Rev. 0 Dual)

B 3.6.6A BASES REFERENCES (continued)

6. FSAR, Section [ 1.

7. FSAR, Section [ 1.

WOG STS Rev. 2,04/30/01

TSTF-479, Rev. 0 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6B BASES SURVEILLANCE REQUIREMENTS (continued)

Frequency was developed considering the known reliability of the Cooling Water System, the two train redundancy available, and the low probability of a significant degradation of flow occurring between surveillances.

Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle.

Flow and differential pressure are normal tests of centrifugal pump performance required b y c m m h e ASME Code (Ref. 8). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on recirculation flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the lnservice Testing Program.

SR 3.6.6B.5 and SR 3.6.68.6 These SRs require verification that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated containment High-3 pressure signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The [I81 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillances when performed at the [I81 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

The surveillance of containment sump isolation valves is also required by SR 3.5.2.5. A single surveillance may be used to satisfy both requirements.

This SR ensures that each [required] containment cooling train actuates upon receipt of an actual or simulated safety injection signal. The WOG STS B 3.6.6B - 8 Rev. 2, 04/30/01

TSTF-479, Rev. 0 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6B BASES SURVEILLANCE REQUIREMENTS (continued)

[I81 month Frequency is based on engineering judgment and has been proven acceptable through operating experience. See SR 3.6.6B.5 and SR 3.6.68.6, above, for further discussion of the basis for the [I81 month Frequency.

With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and that spray coverage of the containment during an accident is not degraded. Because of the passive design of the nozzle, a test at [the first refueling and at] 10 year intervals is considered adequate to detect obstruction of the spray nozzles.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 38, GDC 39, GDC 40, GDC 41, GDC 42, and GDC 43.

2. 10 CFR 50, Appendix A.

3. FSAR, Section [ I 53.

4. FSAR, Section [6.2].

5. FSAR, Section [ 1.

6. FSAR, Section [ 1.

7. FSAR, Section [ 1.

WOG STS Rev. 2, 04/30/01

TSTF-479, Rev. 0 Containment Spray System (Ice Condenser)

B 3.6.6C BASES SURVEILLANCE REQUIREMENTS (continued)

Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle.

Flow and differential head are normal tests of centrifugal pump performance required b x i 3 ) t h e ASME Code (Ref. 5). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confirms one point on the pump design curve and is indicative of overall performance.

Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the lnservice Testing Program.

SR 3.6.6.3 and SR 3.6.6.4 These SRs require verification that each automatic containment spray valve actuates to its correct position and each containment spray pump starts upon receipt of an actual or simulated containment spray actuation signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The [I81 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillances when performed at the

[I81 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

The surveillance of containment sump isolation valves is also required by SR 3.6.6.3. A single surveillance may be used to satisfy both requirements.

With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and that spray coverage of the containment during an accident is not degraded. Because of the passive design of the nozzle, a test at [the first refueling and at] 10 year intervals is considered adequate to detect obstruction of the spray nozzles.

WOG STS B 3.6.6C - 6 Rev. 2, 04/30/01

TSTF-479, Rev. 0 Containment Spray System (Ice Condenser) 6 3.6.6C BASES REFERENCES 1. 10 CFR 50, Appendix A, GDC 38, GDC 39, GDC 40, GDC 41, GDC 42, and GDC 43.

2. FSAR, Section [6.2].

3. 10 CFR 50.49.

4. 10 CFR 50, Appendix K.

WOG STS Rev. 2,04/30/01

TSTF-479, Rev. 0 QS System (Subatmospheric)

B 3.6.6D BASES APPLICABILITY (continued)

MODES. Thus, the QS System is not required to be OPERABLE in MODE 5 or 6.

ACTIONS If one QS train is inoperable, it must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing 100% of the heat removal and iodine removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was developed taking into account the redundant heat removal and iodine removal capabilities afforded by the OPERABLE train and the low probability of a DBA occurring during this period.

B.l and B.2 If the Required Action and associated Completion Time are not met, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 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.

SURVEILLANCE SR 3.6.60.1 REQUIREMENTS Verifying the correct alignment of manual, power operated, and automatic valves, excluding check valves, in the QS System provides assurance that the proper flow path exists for QS System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they were verified to be in the correct position prior to being secured. This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that those valves outside containment and capable of potentially being mispositioned are in the correct position.

Verifying that each QS pump's developed head at the flow test point is greater than or equal to the required developed head ensures that QS pump performance has not degraded during the cycle. Flow and differential head are normal tests of centrifugal pump performance reauired b v m t h e ASME Code (Ref. 4). Since the QS Svstem WOG STS Rev. 2, 04/30/01

TSTF-479, Rev. 0 QS System (Subatmospheric) 3 3.6.6D BASES SURVEILLANCE REQUIREMENTS (continued) pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the lnservice Testing Program.

SR 3.6.6D.3 and SR 3.6.6D.4 These SRs ensure that each QS automatic valve actuates to its correct position and each QS pump starts upon receipt of an actual or simulated containment spray actuation signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The [I81 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power.

Operating experience has shown that these components usually pass the Surveillances when performed at an [I81 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and that spray coverage of the containment during an accident is not degraded. Due to the passive nature of the design of the nozzle, a test at [the first refueling and at] 10 year intervals is considered adequate to detect obstruction of the nozzles.

REFERENCES 1. FSAR, Section [6.2].

2. 10 CFR 50.49.

3. 10 CFR 50, Appendix K.

WOG STS Rev. 2, 04/30/01

TSTF-479, Rev. 0 RS System (Subatmospheric)

B 3.6.6E BASES SURVEILLANCE REQUIREMENTS (continued) otherwise secured in position, since they are verified as being in the correct position prior to being secured. This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that those valves outside containment and capable of potentially being mispositioned are in the correct position.

Verifying that each RS [and casing cooling] pump's developed head at the flow test point is greater than or equal to the required developed head ensures that these pumps' performance has not degraded during the cycle. Flow and differential head are normal tests of centrifugal pump performance required he b- ASME Code (Ref. 4). Since the QS System pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the lnservice Testing Program.

These SRs ensure that each automatic valve actuates and that the RS System and casing cooling pumps start upon receipt of an actual or simulated High-High containment pressure signal. Start delay times are also verified for the RS System pumps. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The [I81 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. Operating experience has shown that these components usually pass the Surveillance when performed at the [I81 month Frequency. Therefore, the Frequency was considered to be acceptable from a reliability standpoint.

This SR ensures that each spray nozzle is unobstructed and that spray coverage of the containment will meet its design bases objective. An air or smoke test is performed through each spray header. Due to the passive design of the spray header and its normally dry state, a test at WOG STS Rev. 2, 04/30/01

TSTF-479, Rev. 0 RS System (Subatmospheric)

B 3.6.6E BASES SURVEILLANCE REQUIREMENTS (continued)

[the first refueling and at] 10 year intervals is considered adequate for detecting obstruction of the nozzles.

REFERENCES 1. FSAR, Section [6.2].

2. 10 CFR 50.49.

3. 10 CFR 50, Appendix K.

WOG STS Rev. 2, 04/30/01

TSTF-479, Rev. 0 Vacuum Relief Valves (Atmospheric and Ice Condenser)

B 3.6.12 BASES SURVEILLANCE SR 3.6.12.1 REQUIREMENTS This SR cites the lnservice Testing Program, which establishes the reauirement that inservice testina of T ASME ME Code Class 1. 2. and 3 pumps and valves shall be perf&med in acc the ~ ~ ~ E & o i l a a r R~! r e s s u ~ e s s e ~ ~ o d e (Ref. 2). Therefore, SR Frequency is governed by the lnservice Testing Program. ,

REFERENCES 1. FSAR, Section [6.2].

WOG STS Rev. 2, 04/30/01

TSTF-479, Rev. 0 MSSVs B 3.7.1 BASES ACTIONS (continued)

The maximum THERMAL POWER corresponding to the heat removal capacity of the remaining OPERABLE MSSVs is determined via a conservative heat balance calculation as described in the attachment to Reference 6, with an appropriate allowance for Nuclear lnstrumentation System trip channel uncertainties.

- REWEWER'S NOTE -

To determine the Table 3.7.1-1 Maximum Allowable Power for Required Actions B.l and 6.2 (%RTP), the Maximum NSSS Power calculated using the equation in the Reviewer's Note above is reduced by [9]% RTP to account for Nuclear lnstrumentation System trip channel uncertainties.

Required Action B.2 is modified by a Note, indicating that the Power Range Neutron Flux-High reactor trip setpoint reduction is only required in MODE 1. In MODES 2 and 3 the reactor protection system trips specified in LC0 3.3.1, "Reactor Trip System Instrumentation," provide sufficient protection.

The allowed Completion Times are reasonable based on operating experience to accomplish the Required Actions in an orderly manner without challenging unit systems.

C.l and C.2 If the Required Actions are not completed within the associated Completion Time, or if one or more steam generators have 2 [4]

inoperable MSSVs, the unit must be placed in a MODE in which the LC0 does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.1. I REQUIREMENTS This SR verifies the OPERABILITY of the MSSVs by the verification of each MSSV lift setpoint in accordance with the lnservice Testing Program. The ASME ~ o d e p % & % f f f ( ~ e4), f . requires that safety and relief valve tests be performed in accordance with ANSIIASME OM-1-1987 (Ref. 5). According to Reference 5, the following tests are required:

WOG STS Rev. 2, 04/30/01

TSTF-479, Rev. 0 MSSVs B 3.7.1 BASES SURVEILLANCE REQUIREMENTS (continued)

a. Visual examination,

b. Seat tightness determination,

c. Setpoint pressure determination (lift setting),

d. Compliance with owner's seat tightness criteria, and

e. Verification of the balancing device integrity on balanced valves.

The ANSIIASME Standard requires that all valves be tested every 5 years, and a minimum of 20% of the valves be tested every 24 months.

The ASME Code specifies the activities and frequencies necessary to

+

satisfy the requirements. Table 3.7.1-2 allows a [3]% setpoint tolerance for OPERABILITY; however, the valves are reset to k 1%

during the Surveillance to allow for drift. The lift settings, according to Table 3.7.1-2, correspond to ambient conditions of the valve at nominal operating temperature and pressure.

This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. The MSSVs may be either bench tested or tested in situ at hot conditions using an assist device to simulate lift pressure. If the MSSVs are not tested at hot conditions, the lift setting pressure shall be corrected to ambient conditions of the valve at operating temperature and pressure.

REFERENCES 1. FSAR, Section [I 0.3. I ] .

2. ASME, Boiler and Pressure Vessel Code, Section Ill, Article NC-7000, Class 2 Components.

3. FSAR, Section [15.2]. -

5. ANSIIASME OM-1-1987. u

6. NRC Information Notice 94-60, "Potential Overpressurization of the Main Steam System," August 22, 1994.

WOG STS Rev. 2, 04130101

TSTF-479, Rev. 0 MSlVs B 3.7.2 BASES I

ACTIONS (continued) operating experie to reach the required unit conditions from MODE 2 conditions in an manner and without challenging unit systems.

SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies th MSlV closure time is I [4.6] seconds. The MSlV isolation time is as in the accident and containment analyses. This Surveillance is nor upon returning the unit to operation following a should not be tested at power, the risk of a valve closure The Frequency is i/l accordance with the Inservice Testing Program.

This test is ed in MODE 3 with the unit at operating temperature SR is modified by a Note that allows entry into and 3 prior to performing the SR. This allows a delay of 3, to establish conditions consistent with those under criterion was generated.

is based on the these 1

This SR verifies th t each MSlV can close on an actual or simulated actuation signal. T is Surveillance is normally performed upon returning the plant to operati n following a refueling outage. The Frequency of MSlV testing is ev ry [I81 months. The [I81 month Frequency for testing experience has shown that when performed at the this Frequency is acceptable from a REFERENCES 1. FSAR. Sectioi [ I 0.31.

2. FSAR, Sectiot) (6.21.

I

3. FSAR, ~ e c t i o[l5.1.5].

i WOG STS Rev. 2, 04/30/01

TSTF-479, Rev. 0 BASES REFERENCES (continued)

5. (ASME, B m n d Pressure VessePCode,Section XI)

WOG STS Rev. 2, 04130101

TSTF-479, Rev. 0 MFlVs and MFRVs [and Associated Bypass Valves]

B 3.7.3 BASES ACTIONS (continued) this flow path. Under these conditions, affected valves in each flow path must be restored to OPERABLE status, or the affected flow path isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This action returns the system to the condition where at least one valve in each flow path is performing the required safety function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable, based on operating experience, to complete the actions required to close the MFIV or MFRV, or otherwise isolate the affected flow path.

E . l and E.2 If the MFIV(s) and MFRV(s) and the associated bypass valve(s) cannot be restored to OPERABLE status, or closed, or isolated within the associated Completion Time, the unit must be placed in a MODE in which the LC0 does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s[, and in MODE 4 within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s]. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

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

[associated bypass valve] is L 7 seconds. The MFIV and MFRV isolation times are assumed in the accident and containment analyses. This Surveillance is normally performed upon returning the unit to operation following a refueling outage. These valves should not be tested at power ga since even a part stroke exercise increases the risk of a valve closure generating power. This is consistent with the ASME c o d e r I (Ref. 2), quarterly stroke requirements during operation in MODES 1 and 2.

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

This SR verifies that each MFIV, MFRV, and [associated bypass valve]

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

The Frequency for this SR is every [ I 81 months. The [I81 month Frequency for testing is based on the refueling cycle. Operating WOG STS B 3.7.3 - 5 Rev. 2, 04/30/01

TSTF-479, Rev. 0 MFlVs and MFRVs [and Associated Bypass Valves]

B 3.7.3 BASES SURVEILLANCE REQUIREMENTS (continued) experience has shown that these components usually pass the Surveillance when performed at the [ I 81 month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

REFERENCES 1. FSAR, Section [10.4.7].

WOG STS Rev. 2, 04130101

TSTF-479, Rev. 0 AFW System B 3.7.5 1 BASES SURVEILLANCE REQUIREMENTS (continued) generator level control, if it is capable of being manually (i.e., remotely or locally, as appropriate) realigned to the AFW mode of operation, provided it is not otherwise inoperable. This exception allows the system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable. Since AFW may be used during startup, shutdown, hot standby operations, and hot shutdown operations for steam generator level control, and these manual operations are an accepted function of the AFW System, OPERABILITY (i.e., the intended safety function) continues to be maintained. ]

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

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

~ o d e [ m b ( ~ e 2) f .(only required at 3 month intervals) satisfies this requirement.

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

This SR verifies that AFW can be delivered to the appropriate steam generator in the event of any accident or transient that generates an ESFAS, by demonstrating that each automatic valve in the flow path actuates to its correct position on an actual or simulated actuation signal.

This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls.

The [I81 month Frequency is based on the need to perform this WOG STS B 3.7.5 - 7 Rev. 2, 04/30/01

TSTF-479, Rev. 0 AFW System B 3.7.5 BASES SURVEILLANCE REQUIREMENTS (continued) used during startup, shutdown, hot standby operations, and hot shutdown operations for steam generator level control, and these manual operations are an accepted function of the AFW System. OPERABILITY (i.e., the intended safety function) continues to be maintained. ]

This SR verifies that the AFW is properly aligned by verifying the flow paths from the CST to each steam generator prior to entering MODE 2 after more than 30 days in any combination of MODE 5 or 6 or defueled.

OPERABILITY of AFW flow paths must be verified before sufficient core heat is generated that would require the operation of the AFW System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgement and other administrative controls that ensure that flow paths remain OPERABLE. To further ensure AFW System alignment, flow path OPERABILITY is verified following extended outages to determine no misalignment of valves has occurred. This SR ensures that the flow path from the CST to the steam generators is properly aligned. ]

- REVIEWER'S NOTE -

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

REFERENCES 1. FSAR, Section [10.4.9].

WOG STS Rev. 2, 04130101

TSTF-479, Rev. 0 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.

[ The Frequency for this SR is variable, depending on individual system design, with up to a [92] day interval. The [92] day Frequency ASME Code S &

corresponds to the ting requirements for pumps as contained in the n XI Ref. 11); however, the design of fuel transfer systems is such that pumps operate automatically or must be started manually in order to maintain an adequate volume of fuel oil in the day

[and engine mounted] tanks during or following DG testing. In such a case, a 31 day Frequency is appropriate. Since proper operation of fuel transfer systems is an inherent part of DG OPERABILITY, the Frequency of this SR should be modified to reflect individual designs. ]

See SR 3.8.1.2.

Transfer of each [4.16 kV ESF bus] power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads.

The [ I 8 month] Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the [I8 month]

Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by a Note. The reason for the Note is that, during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This restriction from normally performing the Surveillance in WOG STS Rev. 2, 04/30101

TSTF-479, Rev. 0 AC Sources - Operating B 3.8.1 BASES REFERENCES (continued)

10. Regulatory Guide 1.I%',

Rev. [ 1, [date].

11.

12. IEEE Standard 308-1978.

WOG STS Rev. 2, 04/30/01

TSTF-479, Rev. 0 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.4 Radioactive Effluent Controls Program (continued)

i. Limitations on the annual and quarterly doses to a member of the public from iodine-131, iodine-133, trltlum, and all radionuclides in particulate form with half lives > 8 days in gas? us effluents released from each unit to areas beyond the site boundall , conforming to 10 CFR 50, Appendix I, and j.

+

Limitations on the annual dosd or dose commitment to any member of the public, beyond the site boundd , due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.

I The provisions of SR 3.0.2 and SR $.~0.3are applicable to the Radioactive Effluent Controls Program surveillanqe frequency. I I

5.5.5 Component Cvclic or Transient Limit I I

This program provides controls to tr bk the FSAR, Section [ 1, cyclic and transient occurrences to ensure Components are maintained within the design limits.

5.5.6 [ Pre-Stressed Concrete Containmehf Tendon Surveillance Program This program provides controls for nldnitoring any tendon degradation in pre-stressed concrete containments, incl ding effectiveness of its corrosion protection medium, to ensure contain I nent structural integrity. The program shall include baseline measurements prior to initial operations. The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with [Regulatory Guide { b 5 , Revision 3. 19901.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Tendon Surveillance Program inspection fredaencies. ]

5.5.7 Reactor Coolant Pump Flvwheel lns$?ction Program I

I This program shall provide for the in pection of each reactor coolant pump flywheel per the recommendation of egulatory position c.4.b of Regulatory Guide 1.14, Revision 1, August 197g.

5.5.8 lnservice Testing Proaram This program provides controls for indervice testing of ASME Code Class 1, 2, and 3 components. The program shbll include the following:

CEOG STS Rev. 3.0, 03/31/04 ~

I TSTF-479, Rev. 0 Programs and Manuals 5.5 5.5 Programs and Manuals I 5.5.8 Inservice Testing Program (continue Required Frequencies for Addenda terminology for I performing inservice testing inservice testing activities 1 I

activities I

Weekly At least once per 7 days I

Monthly

~ At least once per 31 days Quarterly or every 3 months Semiannually or every 6 months

~ At least once per 92 days At least once per 184 days Every 9 months I At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days I

b.

?

The provisions of SR 3.0.2 are pplicable to the above required performing inskyvice testing activities,

d. Nothing in the ASME a

SR 3.0.3 are pplicable to inservice testing activities, and shall be construed to supersede the req Steam Generator (SG) Tube ~ u r v e i ~ ~ ~ Program dnce

........................................ ER'S NOTE........................................

The Licensee's current generator tube surveillance requirements shall be and included here. An appropriate administrative I

The provisions of SR 3.0.2 are applic ble to the SG Tube Surveillance Program.

Secondary Water Chemistrv Proara4 d

This program provides controls for rq nitoring secondary water chemistry to inhibit SG tube degradation and low qressure turbine disc stress corrosion cracking. The program shall indude;

a. Identification of a sampling schlE/dule for the critical variables and control points for these variables, 1 CEOG STS 5.5-5, 1 I

Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 I

Pressurizer Safety Valves 1 B 3.4.10 BASES i

ACTIONS A.1 I 3

With one pressurizer safety v Ive inoperable, restoration must take place within 15 minutes. The comb etion Time of 15 minutes reflects the importance of maintaining the RCS overpressure protection system. An inoperable safety valve coinc' ent with an RCS overpressure event could challenge the integrity of the CPB.

B.l and 8.2 If the Required Action cannot be met within the required Completion Time t a or if two or more pressufizer fety valves are inoperable, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant $ust be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 with yny RCS cold leg temperature less than or equal to the LTOP enable temperature specified in the PTLR within overpressure protection or 3 to MODE 4 pressure), lowers the potential for large pressurizer removes the need for overpressure safety valves.

i SURVEILLANCE SR 3.4.10.1 REQUIREMENTS SRs are specified in the Pressurizer safet valves are to be tested in with the requirements of@&r6&I)

@the ASME Code (Ref. the activities and the Frequency necessary to additional requirements are specified.

I The pressurizer safety valve pktpoint is [3]% for OPERABILITY; however, the valves are reset to 1% during the Surveillance to allow for drift.

CEOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 Pressurizer PORVs B 3.4.11 BASES ACTIONS (continued)

If two block valves are inopeiqble, it is necessary to restore at least one block valve to OPERABLE stetus within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The Completion Time is a!

reasonable based on the sm I potential for challenges to the system during this time and provides the operator time to correct the situation.

G.l and G.2, If the Required Actions and dssociated Completion Times of Condition E or F are not met, then the plant must be brought to a MODE in which the LC0 does not apply. THe plat%must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE # within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based On operating experience, to reach MODE 3 from full power in an orderly Wanner and without challenging safety 1

systems. Similarly, the Com letion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach MODE 4 is reasonable considering that plant can cool down within that time frame on one safety system train. I MODES 4 and 5, maintaining PORV OPERABILITY may be r'equi ed. See LC0 3.4.12.

SURVEILLANCE SR 3.4.11.1 REQUIREMENTS I Block valve cycling verifies t sed if necessary. The basis for the Frequency of [92 da This SR is modified by two this SR by stating that this SR is not required t~ be Wormed with the block valve closed in accordance with the Require Actions of this LCO. Opening the block valve in this condition increagqs the risk of an unisolable leak from the RCS since the PORV is already inoperable. Note 2 modifies this SR to allow entry into and operatio in MODE 3 prior to performing the SR.

\

This allows the test to be pe drmed in MODE 3 under operating temperature and pressure co ditions, prior to entering MODE 1 or 2. [In accordance with Reference 4, administrative controls require this test be 1

performed in MODE 3 or 4 to $dequately simulate operating temperature and pressure effects on POR operation.]

SR 3.4.11.2 SR 3.4.11.2 requires complete cycling of each PORV. PORV cycling demonstrates its functioh. The Frequency of [I81 months is based on a typical refueling cycle arid industry accepted practice.

CEOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 Pressurizer PORVs B 3.4.1 1 BASES SURVEILLANCE REQUIREMENTS (continued)

The Note modifies this SR toallow entry into and operation in MODE 3 prior to performing the SR. This allows the test to be performed in MODE 3 under operating teAperature and pressure conditions, prior to 1 entering MODE 1 or 2. [In adcordance with Reference 4, administrative I controls require this test be performed in MODE 3 or 4 to adequately simulate operating temperature and pressure effects on PORV operation.]

I

[SR 3.4.11.3 Operating the solenoid air trol valves and check valves on the air accumulators ensures the control system actuates properly when called upon. The Frequencyof [I81 months is based on a typical refueling cycle and the Frequency of the other surveillances used to I demonstrate PORV OPERA$ LITY. ]

I This Surveillance is not requihed for plants with permanent 1E power supplies to the valves. The tbst demonstrates that emergency power can be provided and is performed by transferring power from the normal supply to the emergency supPly and cycling the valves. The Frequency of (181 months is based on a typical refueling cycle and industry accepted practice. ]

I REFERENCES 1. NUREG-0737, paragraph Ill G.I. November 1980.

2. Inspection and Enforceflent (IE) Bulletin 79-058, April 21, 1979.

I I

[ 4. Generic Letter 90-06, "~esolutionof Generic lssue 70. 'Power-Operated Relief Valve atM Block Valve Reliability,' and Generic lssue 94, 'Additional Low-Temberature Overpressure for Light-Water Reactors,' Pursuant to 1 9 . c 50.54(0,"

~ ~ June 25, 1990. ]

CEOG STS B3.4.11-7 Rev. 3.0, 03/31/04 I

TSTF-479, Rev. 0 RCS PIV Leakage B 3.4.14 BASES SURVEILLANCE SR 3.4.14.1 REQUIREMENTS Performance of leakage testipg on each RCS PIV or isolation valve used to satisfy Required Action A . l or A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch of nt$minal valve diameter up to 5 gpm maximum applies to each valve. Leakdge testing requires a stable pressure condition.

For the two PlVs in series, th'e leakage requirement applies to each valve individually and not to the cohbined leakage across both valves. If the PlVs are not individually leakhge tested, one valve may have failed completely and not be detectbd if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.

Testing is to be performed edgry 9 months, but may be extended up to a maximum of [I81 months, a tgpical refueling cycle, if the plant does not go into MODE 5 for at least 7 days. The [I81 month Frequency is consistent with 10 CFR 50.55a(g) (Ref. 8), as contained in the lnservice Testing Program, is within frequency qllowed by the A ican Society of Mechanical Engineers (ASME) Cod , Ref. 7), and is based on the need to perform the Survbillance% conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performedwith the reactor at power.

In addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PlVs disturbed in the performance of this Surv4illance should also be tested unless documentation shows that ad infinite testing loop cannot practically be avoided. Testing must be pevormed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the valve has been reseated. Within 24 hobrs is a reasonable and practical time limit for performing this test after qpening or reseating a valve.

The leakage limit is to be me! at the RCS pressure associated with MODES 1 and 2. This leakage testing at high differential pressures with stable not possible in the MODES with lower pressures.

CEOG STS B 3.4.14-5 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 RCS PIV Leakage B 3.4.14 BASES SURVEILLANCE REQUlREMENTS (continued)

Entry into the necessary differential pressures and conditions to allow for performance of this Surveillance. The allows this provision is complimentary to the Frequency of prior MODE 2 whenever the unit has been testing has not been performed in the previous 9 Surveillance is not required to be performed on SDC System is aligned to the RCS in the shutdown coolin$ mode of operation. PlVs contained in the SDC shutdown cooling flow path must be leakage rate tested after SDC is secured and stable unit conditions and the necessary differential pressures are established.

I I

SR 3.4.14.2 and SR 3.4.14,B Verifying that the SDC autoclbsure interlocks are OPERABLE ensures that RCS pressure will not the SDC system beyond 125% of its design pressure of [600] psig. The interlock setpoint that prevents the valves from being opened is

< [425] psig to open the valv This setpoint ensures the SDC design pressure will not be the SDC relief valves will not lift. The 18 month need to perform these Surveillances outage. The 18 month of the design The SRs are modified by ~ o t ' eallowing s the SDC autoclosure function to be disabled when using the System suction relief valves for cold overpressure protection in aclcordance with SR 3.4.12.7.

REFERENCES 1. 10 CFR 50.2.

2. 10 CFR 50.55a(c).

3. 10 CFR 50, Appendix A, section V, GDC 55.

4. WASH-1400 (NUREG-7$/014), Appendix V, October 1975.

5. NUREG-0677, May 1980.

I

6. [ Document containing lisq of PIVs. ]

7.

I

8. 10 CFR 50.55a(g). I

~

I I

CEOG STS Rev. 3.0, 03/31/04~

TSTF-479, Rev. 0 ECCS - operating, B 3.5.21 BASES SURVEILLANCE REQUIREMENTS (continued) sealing, or securing. A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve automatically repositions within the proper ktroke time. This Surveillance does not require any testing or valve npanipulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct I

position.

The 31 day Frequency is appropriate because the valves are operated under procedural control and an improper valve position would only affect a single train. This Frequenoy has been shown to be acceptable through operating experience.

SR 3.5.2.3 With the exception of systems in operation, the ECCS pumps are normally in a standby, nonoperating mode. As such, flow path piping has the potential to develop void$ and pockets of entrained gases.

Maintaining the piping from the ECCS pumps to the RCS full of water ensures that the system will @rform properly, injecting its full capacity into the RCS upon demand. This will also prevent water hammer, pump cavitation, and pumping of noncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vegsel following an SlAS or during SDC. The 31 day Frequency takes into fonsideration the gradual nature of gas accumulation in the ECCS piplng and the adequacy of the procedural controls governing system operation.

Periodic surveillance te pumps to detect gross degradation caused by impeller stru or other hydraulic component problems is required by the ASME Code. This type of testing may be accompl uring the pump developed head at only one point of the pump curve. This verifies both that the measured performance is tolerance of the original pump baseline at the test flow is greater than or equal to the derformance as I

necessary to satisfy the requirements.

CEOG STS B 3.5.2-8 Rev. 3.0, 03/31/0L I

TSTF-479, Rev. 0 ECCS - Operating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued)

Discharge head at test of charging pump performance ASME Code. A quarterly Such inservice inspections detect componedt degradation and incipient failures.

SR 3.5.2.6, SR 3.5.2.7, a n d S ~3.5.2.8 These SRs demonstrate thateach automatic ECCS valve actuates to the required position on an actual or simulated SIAS and on an RAS, that each ECCS pump starts on ryceipt of an actual or simulated SIAS, and that the LPSl pumps stop on receipt of an actual or simulated RAS. This Surveillance is not required ffr valves that are locked, sealed, or otherwise secured in the reqrired position under administrative controls.

The 18 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for unplanned trahsients if the Surveillances were performed with the reactor at power. Tqe 18 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipmen . The actuation logic is tested as part of the t

Engineered Safety Feature Actuation System (ESFAS) testing, and equipment performance is rnbnitored as part of the lnservice Testing I

Program.

Realignment of valves in the flow path on an SIAS is necessary for proper ECCS performance. The safety injection valves have stops to position them properly so that flow is testricted to a ruptured cold leg, ensuring that the other cold legs receiqe at least the required minimum flow. This SR is not required for units w(th flow limiting orifices. The 18 month Frequency is based on the s me factors as those stated above for SR 3.5.2.6, SR 3.5.2.7, and CEOG STS B 3.5.2-9 Rev. 3.0, 03131/0~

TSTF-479, Rev. 0 Containment Spray and Cooling Systems (Atmospheric and Dual),

B 3.6.6AI BASES SURVEILLANCE REQUIREMENTS (continued)

Operating each containment cooling train fan unit for r 15 minutes ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also $nsures that blockage, fan or motor failure, 01 excessive vibration can be dytected and corrective action taken. The 31 day Frequency of this SR was developed considering the known reliability of the fan units and controls, the two train redundancy available, and the low probability of a significant degradation of the containment cooling train occurring betweph surveillances and has been shown to be acceptable through operating experience.

Verifying a service water flow rate of 2 [2000] gpm to each cooling unit provides assurance that the (iesign flow rate assumed in the safety analyses will be achieved (Rqf. 2). Also considered in selecting this Frequency were the known r liability of the Cooling Water System, the two train redundancy, and th low probability of a significant degradation of flow occurring between suhreillances.

Verifying that the containment spray header piping is full of water to the

[I001 ft level minimizes the tithe required to fill the header. This ensures 1

that spray flow will be admitt d to the containment atmosphere within the time frame assumed in the c ntainment analysis. The 31 day Frequency is based on the static nature pf the fill header and the low probability of a significant degradation of water level in the piping occurring between surveillances. ]

SR 3.6.6A.5 I Verifying that each containmeht spray pump's developed head at the flow test point is greater than or eeual to the required developed head ensures that spray pump performancg has not degraded during the cycle. Flow and differential pressure ts of centrifugal pump performance required by he ASME Code (Ref. 7). Since the containment spray p e tested with flow through the spray headers, they are testqd on recirculation flow. This test confirms CEOG STS B 3.6.6A-8 Rev. 3.0, 03/31/0f

TSTF-479, Rev. 0 I

Containment Spray and Cooling Systems (Atmospheric and dual)^

B 3.6.6A BASES REFERENCES 1. 10 CFR 50, Appendix A, GDC 38, GDC 39, GDC 40, GDC 41, GDC 42, and GDC 43.

2. FSAR, Section [ 1.

3. FSAR, Section [ 1.

4. FSAR, Section [ 1.

5. FSAR, Section [ 1.

6. CE NPSD-1045-A, "CEC)G Joint Application Report for Modification to the Containment Spra), System Technical Specifications,"

CEOG STS B 3.6.6A-10 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.68 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.68.5 Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performancq has not degraded during the cycle. Flow and differential pressure ts of centrifugal pump performance required e ASME Code (Ref. 6). Since the containment spray tested with flow through the spray headers, they are tested on recirculation flow. This test confirms one point on the pump desigh curve and is indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend perfortdance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservic@Testing Program.

These SRs verify each autorrlatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation signal. This Surveillance is not required for valves that are ldcked, sealed, or otherwise secured in the required position under admihistrative controls. The [I81 month Frequency is based on the need to perform these Surveillances under the conditions that apply during q plant outage and the potential for an unplanned transient if the Suheillances were performed with the reactor i

at power. Operating experie be has shown that these components usually pass the Surveillances when performed at the [I81 month Frequency. Therefore, the Fpquency was concluded to be acceptable from a reliability standpoint.

The surveillance of containmbht sump isolation valves is also required by SR 3.5.2.5. A single surveilldnce may be used to satisfy both requirements. I This SR verifies each contaidment cooling train actuates upon receipt of I

an actual or simulated actuat Qn signal. The [ I 81 month Frequency is based on engineering judgm nt and has been shown to be acceptable through operating experienc See SR 3.6.68.6 and SR 3.6.68.7, above, for further discussion of the asis for the 1181 month Frequency.

I CEOG STS B 3.6.68-8 1 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 Containment Spray qnd Cooling Systems (Atmospheric and Dual)

B 3.6.68 BASES SURVEILLANCE REQUIREMENTS (continued)

With the containment spray i$let valves closed and the spray header drained of any solution, low qressure air or smoke can be blown through test connections. Performance of this SR demonstrates that each spray 1

nozzle is unobstructed and p Ovides assurance that spray coverage of the containment during an accid ht is not degraded. Due to the passive design of the nozzle, a test a [the first refueling and at] 10 year intervals is considered adequate to detect obstruction of the spray nozzles.

REFERENCES 1. 10 CFR 50, ~ ~ ~ e nA,dGDC i x 38, GDC 39, GDC 40, GDC 41, GDC 42, and GDC 43.

2. FSAR, Section [ 1.

3. FSAR, Sections [ 1.

4. FSAR, Section [ 1.

5. FSAR, Section [ 1. ,

CEOG STS Rev. 3.0, 03/31/04~

TSTF-479, Rev. 0 Vacuum Relief Valves (Dual)

B 3.6.12 BASES ACTIONS (continued)

B.1 and B.2 If the vacuum relief line cannot be restored to OPERABLE status within the required Completion ~ i m ethe, plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 ' ithin 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within i

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Com letion Times are reasonable, based on operating experience, to rea H the required plant conditions from full power conditions in an order1 manner and without challenging plant systems.

SURVEILLANCE SR 3.6.12.1 REQUIREMENTS This SR references the lnseryice Testing Program, which establishes the requirement that inservice te of the ASME Code CI pumps and valves in accordance wit the ASME Boiler and Code and applicable Addenda (Ref. 2). Therefore, by the Inservice Testing Program. I REFERENCES 1. FSAR, Section [6.2].

CEOG STS Rev. 3.0, 03/31/04 ~

TSTF-479, Rev. 0 MSSV:

B 3.7.'

BASES ACTIONS (continued) 109.2 = Ratio of MSSV relieving capacity at 110% steam generator design pressure to calculated steam flow rate at 100% RTP + $% instrument uncertainty expressed as a percentage (spe text above).

9.8 = Band betweed the maximum THERMAL POWER and the variable ovedower trip setpoint ceiling (Table 3.7.1-1).

The operator should limit themaximum steady state power level to some value slightly below this setpflnt to avoid an inadvertent overpower trip.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion ~ i m e f oRequired r Action A.l is a reasonable time period to reduce power level and is based on the low probability of an event occurring during this p$riod that would require activation of the MSSVs. An additional 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months is allowed in Required Action A.2 to reduce the setpoints. The C$npletion Time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months for Required Action A.2 is based on a reagonable time to correct the MSSV inoperability, the time required to perform the power reduction, operating experience in resetting all chfinnels of a protective function, and on the low probability of the occurrepce of a transient that could result in steam generator overpressure during this period.

6.1 and 6.2 If the MSSVs cannot be restored to OPERABLE status in the associated Completion Time, or if one oq more steam generators have less than two MSSVs OPERABLE, the unit must be placed in a MODE in which the LC0 does not apply. To achi~qvethis status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , gnd in MODE 4 within [I21 hours. The allowed Completion Times at$ reasonable, based on operating experience, to reach the reqqired unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.1.I REQUIREMENTS This SR verifies the OPERAE/ILITY of the MSSVs by the verification of each MSSV lift setpoints th the Inservice Testing Program. The ASME Co ef. 4), requires that safety and relief valve tests be perfor ance with ANSIIASME OM-1-1987 (Ref. 5). Accordipg to Reference 5, the following tests are required for MSSVs:

CEOG STS Rev. 3.0, 0313110~

TSTF-479, Rev. 0 MSSVs B 3.7.1 BASES SURVEILLANCE REQUIREMENTS (continued)

a. Visual examination, I

b. Seat tightness determingtjon, I

c. Setpoint pressure determination (lift setting),

d. Compliance with owner1$seat tightness criteria, and

e. Verification of the balancing device integrity on balanced valves.

The ANSIJASME Standard r quires that all valves be tested every 1

5 years, and a minimum of 2 % of the valves be tested every 24 months.

The ASME Code specifies thp activities and frequencies necessary to satisfy the requirements. Tablh 3.7.1-2 allows a + [3]%setpoint tolerance for OPERABILITY; however, the valves are reset to + 1% during the Surveillance to allow for drift.I This SR is modified by a Not? that allows entry into and operation in MODE 3 prior to performing the SR. This is to allow testing of the MSSVs at hot conditions. The MSSqs may be either bench tested or tested in situ at hot conditions using ah'assist device to simulate lift pressure. If the MSSVs are not tested at (lot conditions, the lift setting pressure shall be corrected to ambient conc(itions of the valve at operating temperature and pressure.

I REFERENCES 1. FSAR, Section 15.21.

2. ASME, Boiler and ~ressukeVessel Code,Section III, Article NC-7000, Class 2 Comppnents.

I

3. FSAR, Section [15.2].

CEOG STS B 3.7.1-5 Rev. 3.0, 03/31/04 1

TSTF-479, Rev. 0 MSlVs B 3.7.2 BASES ACTIONS (continued)

D.l and D.2 If the MSlVs cannot be restoied to OPERABLE status, or closed, within the associated Completion Tjrhe, the unit must be placed in a MODE in which the LC0 does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within

[I21 hours. The allowed ~ o d p ~ e t i o Times n are reasonable, based on operating experience, to react4 the required unit conditions from MODE 2 conditions in an orderly manqer and without challenging unit systems.

I SURVEILLANCE SR 3.7.2.1 1 REQUIREMENTS r

This SR verifies that the clos re time of each MSlV is s [4.6] seconds.

The MSlV isolation time is assumed in the accident and containment analyses. This SR is normally performed upon returning the unit to operation following a refuelingi outage. The MSlVs should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generatin$ power. As b

power, they are exempt from the ASME Cod requirements during operatio in MODES 1 an The Frequency for this SR is in accordance with the lnservice Testing Program.

This test is conducted in MO E 3, with the unit at operating temperature and pressure. This SR is by a Note that allows entry into and operation in MODE 3 prior to the SR. This allows a delay of testing until MODE 3, in orde conditions consistent with those under which the accep was generated.

actuation signal. This is normally performed upon returning the plant to operation outage. The Frequency of MSlV testing is every month Frequency for testing is based on the has shown that these performed at the reliability standpoint.

CEOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 BASES REFERENCES 1. FSAR, Section [10.3].

2. FSAR, Section [6.2].

3. FSAR, Section [15.1.5].

CEOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 MFlVs [and [MFIV] Bypass Valves]

B 3.7.3 BASES ACTIONS (continued)

C.l and TC.21 If the MFlVs and their bypas valves cannot be restored to OPERABLE status, closed, or isolated in ~e associated Completion Time, the unit must be placed in a MODE i Which the LC0 does not apply. To achieve SURVEILLANCE 1

this status, the unit must be Ibced in at least MODE 3 within 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s[,

and in MODE 4 within [I21 h 3rs]. The allowed Completion Times are reasonable, based on operat rlg experience, to reach the required unit conditions from full power co ditions in an orderly manner and without challenging unit systems. 1 SR 3.7.3.1 REQUIREMENTS d

This SR ensures the verificat Qnof each MFIV [and [MFIV] bypass valve]

is 5 [7] seconds. The MFlV i olation time is assumed in the accident and f

containment analyses. This ,urveillance is normally performed upon returning the unit to operatio following a refueling outage. The MFlVs should not be tested at powe since even a part stroke exercise increases the risk of a valve closure wit the unit generating power. As these not tested at pow r, they are exempt from the ASME code?

(Ref. 2) requiremdrjts during operation in MODES 1 and 2.

The Frequency is in accordalce with the lnservice Testing Program.

This SR verifies that each M#V [and [MFIV] bypass valve] can close on i

an actual or simulated actuat On signal. This Surveillance is normally performed upon returning thq plant to operation following a refueling outage.

The Frequency months. The [I81 month Frequency for testing is cycle. Operating experience has shown components usually pass the Surveillance when [ I 81 month Frequency. Therefore, this Frequency is reliability standpoint.

REFERENCES 1. FSAR, Section [10.4.7]. ~ I I

~

CEOG STS B 3.7.3-4 Rev. 3.0, 03/31/04~

I

TSTF-479, Rev. 0 AFW System B 3.7.5 BASES ACTIONS (continued)

W~thone AFW train inoperable, action must be taken to immediately P

restore the inoperable train t OPERABLE status or to immediately verify, by administrative means, the OPERABILITY of a second train. LC0 3.0.3 is not applicable, as it could prce the unit into a less safe condition.

In MODE 4, either the reactojsoolant pumps or the SDC loops can be used to provide forced circul tion as discussed in LC0 3.4.6, "RCS Loops

- MODE 4." ?

SURVEILLANCE SR 3.7.5.1 REQUIREMENTS Verifying the correct alignmepi for manual, power operated, and automatic valves in the AFWwater and steam supply flow paths provides r

assurance that the proper flo , paths exist for AFW operation. This SR does not apply to valves that 4re locked, sealed, or otherwise secured in position, since these valves r/re 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 $isaligned, such as check valves. This Surveillance does not require any testing or valve manipulations; rather, it involves verification that thosk valves capable of potentially being mispositioned are in the corr46t position.

I The 31 day Frequency is bas'ed on engineering judgment, is consistent with the procedural controls dOverning valve operation, and ensures correct valve positions.

Verifying that each AFW pu developed head at the flow test point is greater than or equal to the developed head ensures that AFW pump performance has not during the cycle. Flow and differential head are normal tests of pump performance required by

( r e t h e ASME cod4 (Ref. 2). Because it is undesirable to introduce cold AFW into the dteam generators while they are operating, this testing is performed on rt$$ircul%ionflow. This test confirms one -

point on the pump design and is indicative of overall performance.

Such inservice tests OPERABILITY, trend performance, and by indicating abnormal discussed in the ASME this requirement.

This SR is modified by a Not ' indicating that the SR should be deferred until suitable test conditions {re established. This deferral is required because there is an insufficiept steam pressure to perform the test.

CEOG STS Rev. 3.0, 03131104i

TSTF-479, Rev. 0 AFW System B 3.7.5 BASES SURVEILLANCE REQUlREMENTS (continued)

................................... R@I/ EWER'S NOTE---------------....................

pump rather than AFW for st rtup and shutdown. 1 Some plants may not routine y use the AFW for heat removal in MODE 4.

The second justification is pr vided for plants that use a startup feedwater

+-----------------------------------------------------------

I SR 3.7.5.5 I I f

This SR ensures that the AF System is properly aligned by verifying the flow path to each steam gen riator prior to entering MODE 2 operation, after 30 days in any combination of MODE 5 or 6, or defueled. I OPERABILITY of AFW flow paths must be verified before sufficient core heat is generated that would require the operation of the AFW System during a subsequent shutdov,h. The Frequency is reasonable, based on engineering judgment, and other administrative controls to ensure that flow paths remain OPERABLP. To further ensure AFW System alignment, the OPERABILITY 'of the flow paths is verified following I extended outages to determihe that no misalignment of valves has I occurred. This SR ensures thht the flow path from the CST to the steam REFERENCES 1. FSAR, Section [10.4.9].

4 generators is properly aligne {by requiring a verification of minimum flow capacity of 750 gpm at 1270 si. (This SR is not required by those units I that use AFW for normal sta up and shutdown.)

I I I

CEOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 AC Sources - Operating1 B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The 31 day Frequency is adequate to assure that a sufficient supply of fuel oil is available, since lo4 level alarms are provided and unit operatorsl would be aware of any large uses of fuel oil during this period. I Microbiological fouling is a mbjor cause of fuel oil degradation. There are numerous bacteria that can drpw in fuel oil and cause fouling, but all must have a water environm$nt in order to survive. Removal of water from the fuel oil day [and endine mounted] tanks once every [31] days eliminates the necessary envitonment for bacterial survival. This is the most effective means of contrblling microbiological fouling. In addition, it eliminates the potential for wpter entrainment in the fuel oil during DG operation. Water may come [tom any of several sources, including condensation, ground water, rgin water, contaminated fuel oil, and from breakdown of the fuel oil by Qqcteria. Frequent checking for and removal of accumulated water minimi#ps fouling and provides data regarding the watertight integrity of the fuelqil system. The Surveillance Frequencies are established by Guide 1.137 (Ref. 10). This SR is for preventive maintenance. :~resence of water does not necessarily represent failure of this the accumulated water is removed during the performance This Surveillance demon~trad~s that each required fuel oil transfer pump operates and transfers fuel o/lfrom its associated storage tank to its associated day tank. This is hbquired to support continuous operation of standby power sources. hid Furveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not bbstructed, and the controls and control systems for automatic fuel trdnsfer systems are OPERABLE.

[ The Frequency for this SR is variable, depending on individual system The 1921 day Frequency for pumps as contained in the the design of fuel transfer systems is or must be started oil in the day CEOG STS B 3.8.1-17 I Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This Surveillance demonstraks that the DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper s4)ed within the specified time when the DGs are started simultaneously.

The 10 year Frequency is consistent with the recommendations of Regulatory Guide 1.108 ( ~ e f9).

This SR is modified by a Not$. The reason for the Note is to minimize wear on the DG during testin , For the purpose of this testing, the DGs must be started from standbfconditions, that is, with the engine coolant and oil continuously circulatep, and temperature maintained consistent with manufacturer recommer7dations.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. FSAR, Chapter [8].

3. Regulatory Guide 1.9, R b . [3].

4. FSAR, Chapter [6].

5. FSAR, Chapter [15].

6. Regulatory Guide 1.93, qev. [ 1, [date].

7. Generic Letter 84-15.

8. 10 CFR 50, Appendix A, GDC 18.

9. Regulatory Guide 1.lO8,Rev. [I], [August 19771.

10. Regulatory Guide 1.137, Fev. [ 1, [date].

11. ANSI C84.1-1982.

12.

CEOG STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 5.5 Programs and Manuals 5.5.7 lnservice Testina Program (continued) m?b&!nd P&M~"(Q~

se Code and applicab e Required Frequencies for Addenda terminology for performing inservice testing inservice testing activities activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days

b. The provisions of SR 3.0.2 are ~lpplicableto the above required Frequencie~forperforming inservice testing activities,

c. The provisions of SR 3.0.3 are applicable to inservice testing activities, and 5.5.8 Ventilation Filter Testing Proaram (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in [Regulatory Guide 1, and in accordance with [Regulatory Guide 1.52, Revision 2, ASME N510-1989, and AG-I].

a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-19891 at the system flowrate specified below

[* lo%].

ESF Ventilation System Flowrate BWRM STS 5.5-5 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 BASES SURVEILLANCE REQUIREMENTS (continued)

A manual actuation of each [required] S/RV is performed to verify that, mechanically, the valve is funktioning properly and no blockage exists in the valve discharge line. This can be demonstrated by the response of the turbine control valves or bypass valves, by a change in the measured steam flow, or by any other method suitable to verify steam flow.

Adequate reactor steam dome pressure must be available to perform this test to avoid damaging the valve. Also, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the S/RVs divert steam flow upon opening.

1 Sufficient time is therefore all wed after the required pressure and flow are achieved to perform this t st. Adequate pressure at which this test is to be performed is [920] psig (the pressure recommended by the valve manufacturer). Adequate stehm flow is represented by [at least 1.25 turbine bypass valves open, 01total steam flow 2106 Iblhr]. Plant startup is allowed prior to performing \his test because valve OPERABILITY and the setpoints for overpressure,protection are verified, per ASME Code 1

requirements, prior to valve in tallation. Therefore, this SR is modified by a Note that states the Surveill nce is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam p'ressure 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 allowe(.l for manual actuation after the required pressure is reached is sufficieot to achieve stable conditions for testing and provides a reasonable time to complete the SR. If a valve fails to actuate due only to the failure of the solenoid but is capable of opening on overpressure, the safety function of the S/RV is considered OPERABLE.

The 1181 month on a STAGGERED TEST BASIS Frequency ensures that each solenoid for each SIRV iS alternately tesjed. The 18 month Frequency was developed ba$ed on the S/RV tests required by the ASME Boiler and Pressure Ve;ssel ~ o d < w T j ( ~ e f .3). Operating experience has shown that these components usually pass the Surveillance when performed bt the 18 month Frequency. Therefore, the Frequency was concluded to t$e acceptable from a reliability standpoint.

I REFERENCES 1. FSAR, Section [5.2.2.2.4]1

2. FSAR, Section [15].

BWRl4 STS B 3.4.3-4 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 RCS PIV ~eakage~

B 3.4.5 BASES ACTIONS (continued) 6.1 and B.2 If leakage cannot be reduced or the system isolated, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brou'ght to MODE 3 within $ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . ~ h i action f may reduce the leakage and also reduces the potential for a LOCA outside the containment. The Completion Times are reasonable, based on operating experience, to achieve the required plant coriditions from full power conditions in an orderly manner and without cdallonging plant systems.

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS Performance of leakage testinb on each RCS PIV is required to verify that leakage is below the specified limit and to identify each leaking valve.

The leakage limit of 0.5 gpm per inch of nominal;alve diameter up to 5 gpm maximum applies to eqch valve. Leakage testing requires a stable pressure condition. For the two FWs in series, the leakage requirement applies to each valve individu+lly and not to the combined leakage across both valves. If the PlVs are nqt individually leakage tested, one valve may have failed completely a d not be detected if the other valve in 3

series meets the leakage req irement. In this situation, the protection provided by redundant valves would be lost.

The 18 month the lnservice Testing Program is requirement and is based an outage and the potential for an unplanned trajsient if the Surveillance were performed with the reactor at power.

This SR is modified by a Notethat states the leakage Surveillance is not required to be performed in MODE 3. Entry into MODE 3 is permitted for leakage testing at high differeotial pressures with stable conditions not possible in the lower MODES.'

REFERENCES 1. 10 CFR 50.2.

2. 10 CFR 50.55a(c).

3. 10 CFR 50, Appendix A, 6DC 55.

I I

BWRI4 STS B 3.4.5-4 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 RCS PIV Leakag6 B 3.4.5 BASES REFERENCES (continued) 4.

5. NUREG-0677, May 1980;

6. FSAR, Section [ ] .

BWR/4 STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 ECCS - Operating 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The specified Frequency is once during reactor startup before THERMAL POWER is > 25% RTP. How+ver, this SR is modified by a Note that states the Surveillance is only required to be performed if the last performance was more than 31 days ago. Therefore, implementation of this Note requires this test to be performed during reactor startup before exceeding 25% RTP. Verification during reactor startup prior to reaching z 25% RTP is an exception to tho normal Inservice Testing Program generic valve cycling Frequenpy of 92 days, but is considered acceptable due to the demonstrated reliability of these valves. If the valve is inoperable and in the open position, the associated LPCl subsystem must be declared inoperable.

SR 3.5.1.7, SR 3.5.1.8, and $R 3.5.1.9 The performance requirements of the low pressure ECCS pumps are determined through application of the 10 CFR 50, Appendix K criteria rveillance is performed (in accordance with the requjrements for the ECCS pumps) to verify that elop the flow rates required by the respective analyses. The low pressure 6CCS pump flow rates ensure that adequate core cooling is provided to sat/sfy the acceptance criteria of Reference 10. The pump floq rates are verified against a system head equivalent to the RPV pressure expected during a LOCA. The total system pump outlet pressure ik adequate to overcome the elevation head pressure between the pump srction and the vessel discharge, the piping friction losses, and RPV presspre present during a LOCA. These values may be established during prdoperational testing.

The flow tests for the HPCl Sy,stemare performed at two different pressure ranges such that system capability to provide rated flow is tested at both the higher and lower operating ranges of the system.

Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the HPCl System divertg steam flow. Reactor steam pressure must be r [920] psig to perform SR 3.5.1.8 and 1 [I501 psig to perform SR 3.5.1.9. Adequate steam flow is represented by [at least 1.25 turbine bypass valves open, or total steam flow r lo6 Iblhr]. Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these tests. Reactor startup is/ allowed prior to performing the low pressure Surveillance test because the reactor pressure is low and the BWR/4 STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 LLS Valves B 3.6.1.6 BASES SURVEILLANCE REQUIREMENTS (continued) manufacturer). Also, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the LLS valves divert steam flow upon opening. Adequate steam flow is represented by [at least 1.25 turbine bypass valves open, or total steam flow r lo6 Iblhr]. The [I81 month Frequency was based on the S/RV tests required by the ASME Boiler and Pressure Vessel Code, (Ref. 2). The Frequency of 18 months on a STAGGERED IS ensures that each solenoid for each S/RV is alternately tested. Operating experience has shown that these components usually pass the Surveillance when performed at the [I81 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

Since steam pressure is required to perform the Surveillance, however, and steam may not be available during a unit outage, the Surveillance may be performed during the startup following a unit outage. Unit startup is allowed prior to performing the test because valve OPERABILITY and the setpoints for overpressure protection are verified by Reference 2 prior to valve installation. After adequate reactor steam dome pressure and flow are reached, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed to prepare for and perform the test.

The LLS designated S/RVs are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to verify that the mechanical portions (i.e., solenoids) of the LLS function operate as designed when initiated either by an actual or simulated automatic initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.3.7 overlaps this SR to provide complete testing of the safety

' function.

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

This SR is modified by a Note that excludes valve actuation. This prevents a reactor pressure vessel pressure blowdown.

B W / 4 STS B 3.6.1.6-3 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 LLS Valves B 3.6.1.6 BASES 1 I

REFERENCES 1. FSAR, Section [5.5.17].

BWR/4 STS B 3.6.1.6-4 Rev. 3.0, 03/31/04(

i

TSTF-479, Rev. 0 RHR Suppression Pool CoolingI B 3.6.2.3 BASES ACTIONS (continued)

C.1 and C.2 If the Required Action and asqociated Completion Time cannot be met, the plant must be brought to a MODE in which the LC0 does not apply.

To achieve this status, the plapt 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 pn operating experience, to reach the required plant conditions fromfull power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.2.3.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR sluppression pool cooling mode flow path provides assurance that the ptoper flow path exists for system 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, sealidg, or securing. A valve is also allowed to be in the nonaccident position~providedit can be aligned to the accident position within the time assum~edin the accident analysis. This is acceptable since the RHR suppression pool cooling mode is manually initiated. This SR does not re9uire any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the corre4t position. This SR does not apply to valves that cannot be inadvertbntly misaligned, such as check valves.

The Frequency of 31 days is justified because the valves are operated under procedural control, impiopetr valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the subsystem is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.

Verifying that each RHR pump develops a flow rate r [7700] gpm while operating in the suppression Goo1 cooling mode with flow through the associated heat exchanger ensures that pump performance has not degraded during the cycle. Flbw is f centrifugal pump performance required by ASME Cod (Ref. 2). This test confirms one point on the puqp design curve, and the results are indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trgnd performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is i

[in accordance with the lnservice Testing Program or 92 days]. 1

~

B W / 4 STS B 3.6.2.3-3 Rev. 3.0, 03/31/041 I

TSTF-479, Rev. 0 RHR Suppression Pool Cooling B 3.6.2.3 BASES REFERENCES 1. FSAR, Section [6.2].

BWRl4 STS Rev. 3.0, 03131104~

TSTF-479, Rev. 0 RHR Suppression Pool Sprayi B 3.6.2.4 BASES ACTIONS (continued)

C. 1 and C.2 If the inoperable RHR suppression pool spray subsystem cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LC0 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 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.

SURVEILLANCE SR 3.6.2.4.7 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool spray mode flow path provides assurance that the proper flow paths will exist for system operation. This SR does not tlpply 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 is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool cooling mode is manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the subsystem is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.

Verifying each RHR pump develops a flow rate 1 [400] gpm while operating in the suppression pool spray mode with flow through the heat exchanger ensures that pump performance has not degraded during the cycle. Flow is a normal test of centrifugal pump performance required by w m t h e ASME Code (Ref. 2). This test confirms one point on BWRI4 STS B 3.6.2.4-3 Rev. 3.0, 0313110~

TSTF-479, Rev. 0 I

RHR Suppression Pool Spray1 B 3.6.2.4' BASES SURVEILLANCE REQUIREMENTS (continued) the pump design curve and is indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is [in accordance with the Inservice Testing Program, but the Frequency must not exceed 92 days].

REFERENCES 1. FSAR, Section [6.2].

2.

BVVR14 STS Rev. 3.0, 03/31/0

TSTF-479, Rev. 0 AC Sources - operating1 B 3.8.11 BASES SURVEILLANCE REQUIREMENTS (continued)

Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel oil day [and engine mounted] tanks once every [31] days eliminates the necessary environment for bacterial survival. This is the most effective means of controlling tnicrobiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by blcteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel Oil system. The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref. 10). This SR is for preventive maintenance. The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance.

This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. It is reqjired to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.

[ The Frequency for this SR is variable, depending on individual system design, with up to a 1921day interval. The 1921 day Frequency corresponds to the testing requirements for pumps as contained in the ASME Boiler and Pressure Vessel c o d e @ $ k f ? @ ( ~ e f .13); however, the design of fuel transfer systems is such that pumps operate automatically or must be started rnanually in order to maintain an adequate volume of fuel oil in the day [and engine mounted] tanks during or following DG testing. In such a case, a 31 day Frequency is appropriate. Since proper operation of fuel transfer systems is an inherent part of DG OPERABICITY, the Frequency of this SR should be modified to reflect individual designs. ]

See SR 3.8.1.2.

BWW4 STS B 3.8.1-17 Rev. 3.0, 03/31/01

TSTF-479, Rev. 0 I

AC Sources - Operating B 3.8.1, BASES REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

FSAR, Section [8.2].

Regulatory Guide 1.9.

FSAR, Chapter [6].

FSAR, Chapter [15].

Regulatory Guide 1.93.

Generic Letter 84-15.

10 CFR 50, Appendix A, GDC 18.

Regulatory Guide 1. I08.

Regulatory Guide 1.137.

ANSI C84.1, 1982.

FSAR, Section [6.3].

14. IEEE Standard 308.

BVVRI4 STS B 3.8.1-34 Rev. 3.0, 03131104~

TSTF-479, Rev. 0 Programs and ~ a n u a l s 5.5 5.5 Programs and Manuals 5.5.4 Radioactive Effluent Controls Program (continued)

j. Limitations on the annual dose or dose commitment to any member of the public, beyond the site boundary, due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Radioactive Effluent Controls Program surveillance frequency.

5.5.5 Com~onentCyclic or Transient Limit

\

This program provides controls to track the FSAR, Section [ 1, cyclic and transient occurrences to ensure that oomponents are maintained within the design limits.

[ Pre-Stressed Concrete Containment Tendon Surveillance Prosram This program provides controls for monitoring any tendon degradation in pre-stressed concrete containments, including effectiveness of its corrosion protection medium, to ensure containment structural integrity. The program shall include baseline measurements prior to initial operations. The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with [Regulatory Guide .35,Revision 3, 19901.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Tendon Surveillance Program inspection frequencies. ]

lnservice Testinq Proaram This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 components. The program shall include the following:

BWR/6 STS 5.5-4 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 Programs and Manuak 5.e 5.5 Programs and Manuals 5.5.7 Inservice Testinq Program (continued)

Required Frequencies for Addenda terminology for performing inservice testing inservice testing activities activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 davs Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days F/cqLA c"! c w

b. The provisions of SR 3.0.2 are applicable to the above required xpec,'fikJ f.2.

Frequencievr performing inservice testing activities,

+he Zfi~~la T~Jhkv c. The provisions of SR 3.0.3 are applicable to inservice testing activities, and

d. Nothing in the ASME e shall be construed to supersede the req 5.5.8 Ventilation Filter Testing Pronram IVFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in [Regulatory Guide 1, and in accordance with [Regulatory Guide 1.52, Revision 2; ASME N510-1989; and AG-I].

a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-19891 at the system flowrate specified below

[* lo%]:

ESF Ventilation System Flowrate

b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-19891at the system flowrate specified below [* lo%]:

BWRI6 STS 5.5-5 Rev. 3.0, 0313110~

TSTF-479, Rev. 0 BASES SURVEILLANCE REQUIREMENTS (continued)

A manual actuation of each [required] SIRV is performed to verify that, mechanically, the valve is functioning properly and no blockage exists in the valve discharge line. This can be demonstrated by the response of the turbine control valves or bypass valves, by a change in the measured steam flow, or any other method suitable to verify steam flow. Adequate reactor steam dome pressure must be available to perform this test to avoid damaging the valve. Also, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the SIRVs divert steam flow upon opening.

Sufficient time is therefore allowed after the required pressure and flow are achieved to perform this test. Adequate pressure at which this test is to be performed is 950 psig (the pressure recommended by the valve manufacturer). Adequate steam flow is represented by [at least 1.25 turbine bypass valves open, or total steam flow 2 lo6 Iblhr]. Plant startup is allowed prior to performing this test because valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME requirements, prior to valve installation. Therefore, this SR is modified by a Note that states the Surveillance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 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 for manual actuation after the required pressure is reached is sufficient to achieve stable conditions for testing and provides a reasonable time to complete the SR. If the valve fails to actuate due only to the failure of the solenoid but is capable of opening or overpressure, the safety function of the SIRV is considered OPERABLE.

The [I81 month on a STAGGERED TEST BASIS Frequency ensures that each solenoid for each SIRV is alternately tested. The 18 month Frequency was developed based on the SIRV tests required by the ASME Boiler and Pressure Vessel ~ o d e ( m i > c ~ e 1). f . Operating experience has shown that these components usually pass the Surveillance when performed $t the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1.

2. FSAR, Section [5.2.5.5.3]. (Lnsvt1/

3. FSAR, Section [ I51.

BWR16 STS Rev. 3.0, 0313110~

TSTF-479, Rev. 0 RCS PIV Leakage1 B 3.4.6 BASES I ACTIONS (continued)

B.l and B.2 If leakage cannot be reduced or the system isolated, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to 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 . This action may reduce the leakage and also reduces the potential for a LOCA outside the containment. The Completion ~ i m e are s reasonable, based on operatinn experience, to achieve the required plant conditions from full power conditions in an I i

orderly manner and without challenging plant systems.

I SURVEILLANCE SR 3.4.6.1 REQUIREMENTS Performance of leakage testing on each RCS PIV is required to verify that leakage is below the specified limit and to identify each leaking valve.

The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition. For the two PlVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PlVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.

The 18 month Frequ y the lnservice Testing Program is within the ASME Co Frequency requirement and is based on the need to pe nce under the conditions that apply during an outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

Therefore, this SR is modified by a Note that states the leakage Surveillance is not required to be performed in MODE 3. Entry into MODE 3 is permitted for leakage testing at high differential pressures with stable conditions not possible in the lower MODES.

REFERENCES I. 10 CFR 50.2.

2. 10 CFR 50.55a(c).

3. 10 CFR 50, Appendix A, GDC 55.

4. @ , ! l , !and l F e BWR/6 STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 ECCS - Operatins B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued)

Verification every 31 days that ADS air receiver pressure is r [I501 psig assures adequate air pressure for reliable ADS operation. The accumulator on each ADS valve provides pneumatic pressure for valve actuation. The designed pneumatic supply pressure requirements for the accumulator are such that, following a failure of the pneumatic supply to the accumulator, at least two valve actuations can occur with the drywell at 70% of design pressure (Ref. 14). The ECCS safety analysis assumes only one actuation to achieve the depressurization required for operation of the low pressure ECCS. This minimum required pressure of [I501 psig is provided by the ADS Instrurpent Air Supply System. The 31 day Frequency takes into consideration administrative control over operation of the Instrument Air Supply System and alarms for low air pressure.

The performance requirements of'the ECCS pumps are determined through application of the 10 CFR 50, Appendix K, criteria (Ref. 8). This periodic Surveillance is performed (in accordance with the ASME code)

-requirements for the EICCS pumps) to verify that the ECCS pumps will develop the flow rates required by the respective analyses.

The ECCS pump flow rates erlsure that adequate core cooling is provided to satisfy the acceptance criteria of 10 CFR 50.46 (Ref. 10).

The pump flow rates are verified against a system head that is equivalent to the RPV pressure expected during a LOCA. The total system pump outlet pressure is adequate to'overcome the elevation head pressure between the pump suction and the vessel discharge, the piping friction losses, and RPV pressure present during LOCAs. These values may be established during pre-operational testing. A 92 day Frequency for this Surveillance is in accordance with the lnservice Testing Program requirements.

SR 3.5.1.5 The ECCS subsystems are required to actuate automatically to perform their design functions. This Surveillance test verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCS, LPCS, and LPCl will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequenae, automatic pump startup, and actuation 01 BWW6 STS B 3.5.1-9 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 LLS Valves B 3.6. I.6 BASES SURVEILLANCE REQUIREMENTS (continued)

Adequate steam flow is represented by [at least 1.25 turbine bypass valves open, or total steam flow r 1o6 Iblhr]. The [ I 81 month Frequency was developed based on the SIRV tests required by the ASME Boiler and Pressure Vessel ~ o d e m ~ e3). fThe . Frequency of [I81 months on a STAGGERED TEST BASIS ensures that each solenoid for each SIRV is alternately tested. Operating experience has shown these components usually pass the Surveillance when performed at the

[I81 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

Since steam pressure is required in order to perform the Surveillance, however, and steam may not be available during a unit outage, the Surveillance may be performed during the shutdown prior to or the startup following a unit outage. Unit startup is allowed prior to performing this test because valve OPERABIIJTY and the setpoints for overpressure protection are verified by Reference 3 prior to valve installation. After adequate reactor steam dome pressure and flow are reached, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months are allowed to prepare for and perform the test.

The LLS designed S/RVs are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to verify that the mechanical portions (i.e., solenoids) of the automatic LLS function operate as designed when initiated either by an actual or simulated automatic initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.5.4 overlaps this SR to provide complete testing of the safety function.

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

This SR is modified by a Note that excludes valve actuation. This prevents a reactor pressure vessel pressure blowdown.

BWRI6 STS Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 LLS Valves~

B 3.6.1.6, BASES REFERENCES [ 1. GESSAR-It, Appendix 3BA.8. ] 1

2. FSAR, Section [5.5.17].

BWRI6 STS B 3.6.1.6-4 Rev. 3.0, 03/31/04 1

TSTF-479, Rev. 0 RHR Containment Spray Systerr B 3.6.1.7 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.1.7.2 Verifying each RHR pump develops a flow rate 2 [5650] gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that pump performance has not degraded during the cycle. It is tested in the pool cooling mode to demonstrate pump OPERABILITY without spraying down equipment in primary containment. Flow is a normal test of centrifugal pump performance required by the ASME ~od<m-)(~ef. 2). This test confirms one point on the punip design curve and is indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performarice. [The Frequency of this SR is in accordance with the Inservice Testing Program or 92 days.]

This SR verifies that each RHR containment spray subsystem automatic valve actuates to its correct position upon receipt of an actual or simulated automatic actuation signal. Actual spray initiation is not required to meet this SR. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.3.6 overlaps this SR to provide complete testing of the safety function. The [I81 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 trarlsient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the

[I81 month Frequency. p here fore, the Frequency was concluded to be acceptable from a reliability standpoint.

This Surveillance is performed every 10 years to verify that the spray nozzles are not obstructed and that flow will be provided when required.

The 10 year Frequency is adequate to detect degradation in performance due to the passive nozzle design and its normally dry state and has been shown to be acceptable through operating experience.

REFERENCES 1. FSAR, Section [6.2.1.1.51.

BWR/6 STS B 3.6.1.7-4 Rev. 3.0, 03/31/0L

TSTF-479, Rev. 0 RHR Suppression Pool Cooling B 3.6.2.3 BASES ACTIONS (continued)

C.1 and C.2 If the Required Action and required Completion Time cannot be met, the plant must be brought to a MODE: in which the LC0 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.

SURVEILLANCE SR 3.6.2.3.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves, in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system 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 being locked, Sealed, or secured. A valve is also allowed to be in the nonaccident position, provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable, since the RHR suppression pool cooling mode is manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the subsystem is a manually initiated system. This Frequency has been shown to be acceptable, based on operating experience.

Verifying each RHR pump develops a flow rate 1 [7450] gpm, while operating in the suppression pool cooling mode with flow through the associated heat exchanger at least every 92 days, ensures that pump performance has not degraded during the cycle. Flow is a normal test of centrifugal pump performance required by AS ME^^ @ ( ~ e f 2).

This test confirms one point on the pump design curve, and the results are indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is

[in accordance with the Inservice Testing Program or 92 days].

BWR/6 STS B 3.6.2.3-3 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 RHR Suppression Pool Cooling B 3.6.2.3 BASES REFERENCES 1. FSAR, Section [6.2].

BWR/6 STS B 3.6.2.3-4 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The 31 day Frequency is adequate to assure that a sufficient supply of fuel oil is available, since low level alarms are provided and facility operators would be aware of any large uses of fuel oil during this period.

Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel oil day [and engine mounted] tanks once every [31] days eliminates the necessary environment for' bacterial survival. This is most effective means in controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking fbr and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies are established by Regulatory Guide 1.I37 (Ref. 10). This SR is for preventive maintenance. The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance.

This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. It is required to support the continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel traqsfer systems are OPERABLE.

[ The Frequency for this SR is variable, depending on individual system design, with up to a 92 day int$rvnl. The 92 day Frequency corresponds to the testing requiremen s contained in the ASME Boiler and Pressure Vessel Co (Ref. 12); however, the design of fuel transfer systems is such tHat pumps operate automatically or must be started manually in order to mqintain an adequate volume of fuel oil in the day [and engine mounted] tanks during or following DG testing. In such a case, a 31 day Frequency is appropriate. Since proper operation of fuel transfer systems is an inherent part of DG OPERABILITY, the Frequency of this SR should be modified to reflect individual designs. ]

BWRI6 STS B 3.8.1-17 Rev. 3.0, 03/31/04

TSTF-479, Rev. 0 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUlREMENTS (continued)

This Surveillance demonstrates that the DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the DGs are started simultaneously.

The 10 year Frequency is consistent with the recommendations of Regulatory Guide 1.I 08 (Ref. 9).

This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. FSAR, Chapter [8].

3. Regulatory Guide 1.9.

4. FSAR, Chapter [GI.

5. FSAR, Chapter [15].

6. Regulatory Guide 1.93.

7. Generic Letter 84-15, July 2, 1984.

8. 10 CFR 50, Appendix A, GDC 18.

9. Regulatory Guide 1. I08.

10. Regulatory Guide 1.I 37.

11. ANSI C84.1, 1982.

13. IEEE Standard 308.

BWRl6 STS Rev. 3.0, 03/31/04

TSTF-04-15, TSTF-479, Revision 0, Changes to Reflect Revision of 10 CFR 50.55a.

Contents

Text

SUBJECT:

Dear Mr. Boyce:

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1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

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TSTF-04-15, TSTF-479, Revision 0, Changes to Reflect Revision of 10 CFR 50.55a.

Text

SUBJECT:

Dear Mr. Boyce:

Contact:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

Description:

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