Text

Submittal of TSTF-431, Revision 1, Change in Technical Specifications End States (BAW-2441).
	ML063100074
Person / Time
Site:	Technical Specifications Task Force
Issue date:	11/03/2006
From:	Crowthers M, Infanger P, Sparkman W, Woods B; BWR Owners Group, PWR Owners Group, Technical Specifications Task Force
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TSTF-06-26
	Download: ML063100074 (122)
	v • d • e

TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY November 3, 2006 TSTF-06-26 PROJ0753 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

TSTF-431, Revision 1, "Change in Technical Specifications End States (BAW-2441)"

Dear Sir or Madam:

Enclosed for NRC review is Revision 1 of TSTF-431, "Change in Technical Specifications End States (BAW-2441)." Revision 0 was not submitted to the NRC for review.

This Traveler supports Nuclear Energy Institute (NEI) Risk Informed Technical Specification Task Force (RITSTF) Initiative 1, "Technical Specification Required Actions Preferred End States."

We request that NRC review of the Traveler be granted a fee waiver pursuant to the provisions of 10 CFR 170.11. Specifically, the request is to support NRC generic regulatory improvements (risk management technical specifications), in accordance with 10 CFR 170.11(a)(1)(iii). This request is consistent with the NRC letter to A. R. Pietrangelo on this subject dated January 10, 2003.

The TSTF requests that the Traveler be made available under the Consolidated Line Item Improvement Process.

Should you have any questions, please do not hesitate to contact us.

Wesley Sparkman (PWROG/W) Michael Crowthers (BWROG)

Brian Woods (PWROG/CE) Paul Infanger (PWROG/B&W)

Enclosure cc: Tim Kobetz, Technical Specifications Branch, NRC Ross Telson, Technical Specifications Branch, NRC 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

BWOG-108, Rev. 0 TSTF-431, Rev. 1 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Change in Technical Specifications End States (BAW-2441)

NUREGs Affected: 1430 1431 1432 1433 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement: Improvement NRC Fee Status: Exempt Benefit: Shortens Outages Industry

Contact:

Paul Infanger, (352) 563-4796, paul.infanger@pgnmail.com 1.0 Description BAW-2441-A, Revision 2, "Risk Informed Justification for LCO End-State Changes," September 2006, modifies the technical specification (TS) end state for numerious Actions (i.e., the final Mode or other specified condition required to be entered by the Actions of the subject Specifications when the LCO is not met). The requested TS changes are to permit an end state of hot shutdown (Mode 4) rather than the cold shutdown (Mode 5) end state that is contained in the current TSs.

2.0 Proposed Change This Traveler implements the changes described in BAW-2441. The following Specifications are affected:

3.3.5, ESFAS Instrumentation 3.3.6, ESFAS Manual Initiation 3.4.6, RCS Loops - MODE 4 3.4.15,RCS Leakage Detection Instrumentation 3.5.4, BWST 3.6.1, Containment 3.6.2, Containment Air Locks 3.6.3, Containment Isolation Valves 3.6.4, Containment Pressure 3.6.5, Containment Air Temperature 3.6.6, Containment Spray and Cooling Systems 3.7.7, Component Cooling Water System 3.7.8, Service Water System 3.7.9, Ultimate Heat Sink 3.7.10, CREVS 3.7.11, CREATCS 3.8.1, AC Sources - Operating 3.8.4, DC Sources - Operating 3.8.7, Inverters - Operating 3.8.9, Distribution Systems - Operating 03-Nov-06 Traveler Rev. 3. Copyright (C) 2006, 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.

BWOG-108, Rev. 0 TSTF-431, Rev. 1

3.0 Background

BAW-2441-A, Revision 2, "Risk Informed Justification for LCO End-State Changes," September 2006, modifies the technical specification (TS) end state for numerious Actions (i.e., the final Mode or other specified condition required to be entered by the Actions of the subject Specifications when the LCO is not met). The requested TS changes are to permit an end state of hot shutdown (Mode 4) rather than the cold shutdown (Mode 5) end state that is contained in the current TSs.

4.0 Technical Analysis BAW-2441 presents recommendations for replacing cold shutdown (MODE 5) Required Actions with hot shutdown (MODE 4) Required Actions for a number of Specifications. Preventing plant challenges during shutdown conditions has been, and continues to be, an important aspect of ensuring safe operation of the plant.

Past events demonstrate that risk of core damage associated with entry into, and operation in, shutdown cooling is not negligible and should be considered when a plant is required to shutdown. Therefore, the Technical Specifications should encourage plant operation in which the steam generators are available for heat removal whenever practical, and require reliance on shutdown cooling only when it is a risk beneficial alternative to other actions. BAW-2441 justifies remaining in hot shutdown for the subject Specifications.

This Traveler is consistent with the proposed changes described in BAW-2441 and the justification provided in that Topical Report is applicable to this Traveler.

Licensees adopting this change must commit to following the industry-developed implementation guidance for this Traveler. The guidance document stipulates that the requirements of 10 CFR 50.65(a)(4) apply and that risk will be managed when utilizing the end state Technical Specifications changes made by this Traveler.

Risk assessment and management will follow the guidance of Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance at Nuclear Power Plants," which endorses NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Section 11 guidance for implementation of 10 CFR 50.65(a)(4).

03-Nov-06 Traveler Rev. 3. Copyright (C) 2006, 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.

BWOG-108, Rev. 0 TSTF-431, Rev. 1 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 modifies the end state (e.g., mode or other specified condition) which the Required Actions specify must be entered if compliance with the LCO is not restored. Required Actions are not an initiator of any accident previously evaluated. Therefore, the proposed changes do not affect the probability of any accident previously evaluated. BAW-2441 demonstrates that the proposed changes in the required end state do not significantly increase the consequences of any accidents previously evaluated.

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

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

Response: No.

The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new requirements. The changes do not alter assumptions made in the safety analysis.

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

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

Response: No.

BAW-2441 demonstrates that the changed end states represent a condition of equal or lower risk than the original end states.

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

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

03-Nov-06 Traveler Rev. 3. Copyright (C) 2006, 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.

BWOG-108, Rev. 0 TSTF-431, Rev. 1 5.2 Applicable Regulatory Requirements/Criteria Required Actions are not specified by any regulatory requirement or criteria. The Limiting Conditions for Operation, which are based on accident analysis assumptions and regulatory requirements are not affected by this change. Therefore, no regulatory requirements or criteria are affected by this change.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed change 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 area, 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 effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

7.0 References

1. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

Revision History OG Revision 0 Revision Status: Closed Revision Proposed by: BWOG Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 27-Jul-04 Owners Group Comments Withdrawn pending revision of the Topical Report.

Owners Group Resolution: Withdrawn Date:

TSTF Revision 1 Revision Status: Active Revision Proposed by: BWOG Revision

Description:

References to the Topical Report, BAW-2441-A, were updated. Various editorial corrections were made.

Pages were remarked on Revision 3.1 of the NUREG-1430.

03-Nov-06 Traveler Rev. 3. Copyright (C) 2006, 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.

BWOG-108, Rev. 0 TSTF-431, Rev. 1 TSTF Revision 1 Revision Status: Active Owners Group Review Information Date Originated by OG: 19-Sep-06 Owners Group Comments (No Comments)

Owners Group Resolution: Approved Date: 19-Oct-06 TSTF Review Information TSTF Received Date: 20-Oct-06 Date Distributed for Review 20-Oct-06 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 03-Nov-06 NRC Review Information NRC Received Date: 03-Nov-06 Affected Technical Specifications Ref. 3.3.5 Bases ESFAS Instrumentation Action 3.3.5.B ESFAS Instrumentation Action 3.3.5.B Bases ESFAS Instrumentation Ref. 3.3.6 Bases ESFAS Manual Initiation Action 3.3.6.B ESFAS Manual Initiation Action 3.3.6.B Bases ESFAS Manual Initiation Ref. 3.4.6 Bases RCS Loops - MODE 4 Action 3.4.6.A RCS Loops - MODE 4 Action 3.4.6.A Bases RCS Loops - MODE 4 Ref. 3.4.15 Bases RCS Leakage Detection Instrumentation Action 3.4.15.C RCS Leakage Detection Instrumentation 03-Nov-06 Traveler Rev. 3. Copyright (C) 2006, 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.

BWOG-108, Rev. 0 TSTF-431, Rev. 1 Action 3.4.15.C Bases RCS Leakage Detection Instrumentation Ref. 3.5.4 Bases BWST Action 3.5.4.A BWST Action 3.5.4.A Bases BWST Action 3.5.4.B BWST Change

Description:

Relabled D Action 3.5.4.B BWST Change

Description:

New Action Action 3.5.4.B Bases BWST Change

Description:

New Action Action 3.5.4.B Bases BWST Change

Description:

Relabled D Action 3.5.4.C BWST Change

Description:

Relabled E Action 3.5.4.C BWST Change

Description:

New Action Action 3.5.4.C Bases BWST Change

Description:

New Action Action 3.5.4.C Bases BWST Change

Description:

Relabled E Ref. 3.6.1 Bases Containment Action 3.6.1.B Containment Action 3.6.1.B Bases Containment SR 3.6.1.2 Bases Containment Ref. 3.6.2 Bases Containment Air Locks Action 3.6.2.D Containment Air Locks Action 3.6.2.D Bases Containment Air Locks Ref. 3.6.3 Bases Containment Isolation Valves Action 3.6.3.D Bases Containment Isolation Valves Action 3.6.3.E Containment Isolation Valves Action 3.6.3.E Bases Containment Isolation Valves 03-Nov-06 Traveler Rev. 3. Copyright (C) 2006, 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.

BWOG-108, Rev. 0 TSTF-431, Rev. 1 SR 3.6.3.1 Bases Containment Isolation Valves SR 3.6.3.6 Bases Containment Isolation Valves Ref. 3.6.4 Bases Containment Pressure Action 3.6.4.B Containment Pressure Action 3.6.4.B Bases Containment Pressure Ref. 3.6.5 Bases Containment Air Temperature Action 3.6.5.B Containment Air Temperature Action 3.6.5.B Bases Containment Air Temperature Ref. 3.6.6 Bases Containment Spray and Cooling Systems Action 3.6.6.B Containment Spray and Cooling Systems Action 3.6.6.B Bases Containment Spray and Cooling Systems Action 3.6.6.F Containment Spray and Cooling Systems Action 3.6.6.F Bases Containment Spray and Cooling Systems SR 3.6.6.4 Bases Containment Spray and Cooling Systems Ref. 3.7.7 Bases CCW System Action 3.7.7.B CCW System Action 3.7.7.B Bases CCW System Ref. 3.7.8 SWS Action 3.7.8.B SWS Action 3.7.8.B Bases SWS Ref. 3.7.9 Bases UHS Action 3.7.9.A Bases UHS Change

Description:

New Action Action 3.7.9.B UHS Change

Description:

New Action Action 3.7.9.B UHS Change

Description:

Relabeled C Action 3.7.9.B Bases UHS Change

Description:

Relabeled C 03-Nov-06 Traveler Rev. 3. Copyright (C) 2006, 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.

BWOG-108, Rev. 0 TSTF-431, Rev. 1 Action 3.7.9.B Bases UHS Change

Description:

New Action Action 3.7.9.C UHS Change

Description:

Relabeled D Action 3.7.9.C Bases UHS Change

Description:

Relabeled D Ref. 3.7.10 Bases CREVS Action 3.7.10.C CREVS Action 3.7.10.C Bases CREVS SR 3.7.10.3 Bases CREVS Ref. 3.7.11 Bases CREATCS Action 3.7.11.B CREATCS Action 3.7.11.B Bases CREATCS SR 3.8.1 Bases AC Sources - Operating Ref. 3.8.1 Bases AC Sources - Operating Action 3.8.1.G AC Sources - Operating Action 3.8.1.G Bases AC Sources - Operating SR 3.8.1.5 Bases AC Sources - Operating SR 3.8.1.6 Bases AC Sources - Operating SR 3.8.1.9 Bases AC Sources - Operating SR 3.8.1.10 Bases AC Sources - Operating SR 3.8.1.11 Bases AC Sources - Operating SR 3.8.1.14 Bases AC Sources - Operating SR 3.8.1.15 Bases AC Sources - Operating SR 3.8.1.16 Bases AC Sources - Operating SR 3.8.1.17 Bases AC Sources - Operating SR 3.8.1.18 Bases AC Sources - Operating SR 3.8.1.20 Bases AC Sources - Operating 03-Nov-06 Traveler Rev. 3. Copyright (C) 2006, 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.

BWOG-108, Rev. 0 TSTF-431, Rev. 1 Ref. 3.8.4 Bases DC Sources - Operating Action 3.8.4.D DC Sources - Operating Action 3.8.4.D Bases DC Sources - Operating SR 3.8.4.1 Bases DC Sources - Operating SR 3.8.4.2 Bases DC Sources - Operating SR 3.8.4.3 Bases DC Sources - Operating Ref. 3.8.7 Bases Inverters - Operating Action 3.8.7.B Inverters - Operating Action 3.8.7.B Bases Inverters - Operating Ref. 3.8.9 Bases Distribution Systems - Operating Action 3.8.9.D Distribution Systems - Operating Action 3.8.9.D Bases Distribution Systems - Operating 03-Nov-06 Traveler Rev. 3. Copyright (C) 2006, 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-431, Rev. 1 ESFAS Instrumentation 3.3.5 3.3 INSTRUMENTATION 3.3.5 Engineered Safety Feature Actuation System (ESFAS) Instrumentation LCO 3.3.5 Three channels of ESFAS instrumentation for each Parameter in Table 3.3.5-1 shall be OPERABLE in each ESFAS train.

APPLICABILITY: According to Table 3.3.5-1.

ACTIONS

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

Separate Condition entry is allowed for each Parameter.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Parameters A.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months with one channel inoperable.

B. One or more Parameters B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months with two or more channels inoperable. AND OR Required Action and associated Completion Time not met.

BWOG STS 3.3.5-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 ESFAS Instrumentation 3.3.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.2.1 --------------NOTE--------------

Only required for RCS Pressure - Low setpoint.

Reduce RCS pressure 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

< [1800] psig.

AND B.2.2 --------------NOTE--------------

Only required for RCS Pressure - Low Low setpoint.

Reduce RCS pressure 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

< [900] psig.

AND B.2.3 --------------NOTE--------------

Only required for Reactor Building Pressure High setpoint and High High setpoint.

Be in MODE 54. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months BWOG STS 3.3.5-2 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 ESFAS Manual Initiation 3.3.6 3.3 INSTRUMENTATION 3.3.6 Engineered Safety Feature Actuation System (ESFAS) Manual Initiation LCO 3.3.6 Two manual initiation channels of each one of the ESFAS Functions below shall be OPERABLE:

a. High Pressure Injection,

b. Low Pressure Injection,

[ c. Reactor Building (RB) Cooling, ]

[ d. RB Spray, ]

e. RB Isolation, and

[ f. Control Room Isolation. ]

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when associated engineered safeguard equipment is required to be OPERABLE.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more ESFAS A.1 Restore channel to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Functions with one OPERABLE status.

channel inoperable.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months BWOG STS 3.3.6-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 RCS Loops - MODE 4 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Loops - MODE 4 LCO 3.4.6 Two loops consisting of any combination of RCS loops and decay heat removal (DHR) loops shall be OPERABLE and one loop shall be in operation.

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

All reactor coolant pumps (RCPs) may be removed from operation for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months per 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period for the transition to or from the DHR System, and all RCPs and DHR pumps may be de-energized for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period for any other reason, provided:

a. No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1 and

b. Core outlet temperature is maintained at least 10°F below saturation temperature.

APPLICABILITY: MODE 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required loop A.1 Initiate action to restore a Immediately inoperable. second loop to OPERABLE status.

AND A.2 --------------NOTE--------------

Only required if one DHR loop is OPERABLE.

Be in MODE 5. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months BWOG STS 3.4.6-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 RCS Loops - MODE 4 3.4.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Two required loops B.1 Suspend operations that Immediately inoperable. would cause introduction of coolant into the RCS with OR boron concentration less than required to meet SDM Required loop not in of LCO 3.1.1.

operation.

AND B.2 Initiate action to restore one Immediately loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify required DHR or RCS loop is in operation. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.6.2 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated 7 days power available to each required pump.

BWOG STS 3.4.6-2 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a. One containment sump monitor and

b. One containment atmosphere radioactivity monitor (gaseous or particulate).

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required containment A.1 --------------NOTE--------------

sump monitor Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months inoperable. after establishment of steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND A.2 Restore required 30 days containment sump monitor to OPERABLE status.

B. Required containment B.1.1 Analyze grab samples of Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months atmosphere radioactivity the containment monitor inoperable. atmosphere.

OR BWOG STS 3.4.15-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.1.2 --------------NOTE--------------

Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND B.2 Restore required 30 days containment atmosphere radioactivity monitor to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND C.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months D. Both required monitors D.1 Enter LCO 3.0.3. Immediately inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of required containment 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months atmosphere radioactivity monitor.

SR 3.4.15.2 Perform CHANNEL FUNCTIONAL TEST of required 92 days containment atmosphere radioactivity monitor.

BWOG STS 3.4.15-2 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 BWST 3.5.4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.4 Borated Water Storage Tank (BWST)

LCO 3.5.4 The BWST shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. BWST boron A.1 Restore BWST to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months concentration not within OPERABLE status.

limits.

OR BWST water temperature not within limits.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. BWST water C.1 Restore BWST to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months temperature not within OPERABLE status.

limits.

BD. BWST inoperable for D.1 Restore BWST to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reasons other than OPERABLE status.

Condition A or C.

CE. Required Action and CE.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition C or D AND not met.

CE.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BWOG STS 3.5.4-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment 3.6.1 3.6 CONTAINMENT SYSTEMS 3.6.1 Containment LCO 3.6.1 Containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment inoperable. A.1 Restore containment to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.1 Perform required visual examinations and leakage In accordance rate testing except for containment air lock testing, with the in accordance with the Containment Leakage Rate Containment Testing Program. Leakage Rate Testing Program SR 3.6.1.2 [ Verify containment structural integrity in In accordance accordance with the Containment Tendon with the Surveillance Program. Containment Tendon Surveillance Program ]

BWOG STS 3.6.1-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Air Locks 3.6.2 3.6 CONTAINMENT SYSTEMS 3.6.2 Containment Air Locks LCO 3.6.2 [Two] containment air lock[s] shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

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

1. Entry and exit is permissible to perform repairs on the affected air lock components.

2. Separate Condition entry is allowed for each air lock.

3. Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when air lock leakage results in exceeding the overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more -------------------NOTES------------------

containment air locks 1. Required Actions A.1, A.2, with one containment air and A.3 are not applicable if both lock door inoperable. doors in the same air lock are inoperable and Condition C is entered.

2. Entry and exit is permissible for 7 days under administrative controls [if both air locks are inoperable].

A.1 Verify the OPERABLE door 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is closed in the affected air lock.

AND BWOG STS 3.6.2-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Air Locks 3.6.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2 Lock the OPERABLE door 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months closed in the affected air lock.

AND A.3 --------------NOTE--------------

Air lock doors in high radiation areas may be verified locked closed by administrative means.

Verify the OPERABLE door Once per 31 days is locked closed in the affected air lock.

B. One or more -------------------NOTES------------------

containment air locks 1. Required Actions B.1, B.2, with containment air lock and B.3 are not applicable if both interlock mechanism doors in the same air lock are inoperable. inoperable and Condition C is entered.

2. Entry and exit of containment is permissible under the control of a dedicated individual.

B.1 Verify an OPERABLE door 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is closed in the affected air lock.

AND BWOG STS 3.6.2-2 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Air Locks 3.6.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.2 Lock an OPERABLE door 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months closed in the affected air lock.

AND B.3 --------------NOTE--------------

Air lock doors in high radiation areas may be verified locked closed by administrative means.

Verify an OPERABLE door Once per 31 days is locked closed in the affected air lock.

C. One or more C.1 Initiate action to evaluate Immediately containment air locks overall containment inoperable for reasons leakage rate per LCO 3.6.1.

other than Condition A or B. AND C.2 Verify a door is closed in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months the affected air lock.

AND C.3 Restore air lock to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND D.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months BWOG STS 3.6.2-3 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Isolation Valves 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO 3.6.3 Each containment isolation valve shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

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

1. Penetration flow paths [except for 48 inch purge valve penetration flow paths] may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for system(s) made inoperable by containment isolation valves.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A. ------------NOTE------------ A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Only applicable to penetration flow path by penetration flow paths use of at least one closed with two [or more] and de-activated automatic containment isolation valve, closed manual valve, valves. blind flange, or check valve

with flow through the valve secured.

One or more penetration flow paths with one AND containment isolation valve inoperable [for reasons other than purge valve leakage not within limit].

BWOG STS 3.6.3-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2 -------------NOTES--------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

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

Verify the affected Once per 31 days for penetration flow path is isolation devices isolated. outside containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment BWOG STS 3.6.3-2 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. ------------NOTE------------ B.1 Isolate the affected 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Only applicable to penetration flow path by penetration flow paths use of at least one closed with two [or more] and de-activated automatic containment isolation valve, closed manual valve, valves. or blind flange.

One or more penetration flow paths with two [or more] containment isolation valves inoperable [for reasons other than purge valve leakage not within limit].

C. ------------NOTE------------ C.1 Isolate the affected 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Only applicable to penetration flow path by penetration flow paths use of at least one closed with only one and de-activated automatic containment isolation valve, closed manual valve, valve and a closed or blind flange.

system.

AND One or more penetration flow paths with one containment isolation valve inoperable.

BWOG STS 3.6.3-3 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.2 -------------NOTES--------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

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

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

D. [ One or more D.1 Isolate the affected 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months penetration flow paths penetration flow path by with one or more use of at least one [closed containment purge and de-activated automatic valves not within purge valve, closed manual valve, valve leakage limits. or blind flange].

AND BWOG STS 3.6.3-4 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.2 -------------NOTES--------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

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

Verify the affected Once per 31 days for penetration flow path is isolation devices isolated. outside containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment AND D.3 Perform SR 3.6.3.6 for the Once per [ ] days ]

resilient seal purge valves closed to comply with Required Action D.1.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND E.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months BWOG STS 3.6.3-5 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Pressure 3.6.4 3.6 CONTAINMENT SYSTEMS 3.6.4 Containment Pressure LCO 3.6.4 Containment pressure shall be [-2.0] psig and [+3.0] psig.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment pressure A.1 Restore containment 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months not within limits. pressure to within limits.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1 Verify containment pressure is within limits. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months BWOG STS 3.6.4-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Air Temperature 3.6.5 3.6 CONTAINMENT SYSTEMS 3.6.5 Containment Air Temperature LCO 3.6.5 Containment average air temperature shall be [130]°F.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment average air A.1 Restore containment 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months temperature not within average air temperature to limit. within limit.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 Verify containment average air temperature is within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit.

BWOG STS 3.6.5-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Spray and Cooling Systems 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray and Cooling Systems LCO 3.6.6 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment spray [7] days train inoperable. train to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 45. 6084 hours0.0704 days 1.69 hours 0.0101 weeks 0.00231 months C. One [required] C.1 Restore [required] 7 days containment cooling containment cooling train to train inoperable. OPERABLE status.

D. One containment spray D.1 Restore containment spray 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months train and one [required] train to OPERABLE status.

containment cooling train inoperable. OR D.2 Restore [required]

containment cooling train to OPERABLE status.

BWOG STS 3.6.6-1 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 Containment Spray and Cooling Systems 3.6.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two [required] E.1 Restore one [required] 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months containment cooling containment cooling train to trains inoperable. OPERABLE status.

F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition C or D AND not met.

F.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months G. Two containment spray G.1 Enter LCO 3.0.3. Immediately trains inoperable.

OR Any combination of three or more trains inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power 31 days operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

SR 3.6.6.2 Operate each [required] containment cooling train 31 days fan unit for 15 minutes.

BWOG STS 3.6.6-2 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 CCW System 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Component Cooling Water (CCW) System LCO 3.7.7 Two CCW trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CCW train A.1 -------------NOTES--------------

inoperable. 1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources -

Operating," for emergency diesel generator made inoperable by CCW.

2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops

- MODE 4," for decay heat removal made inoperable by CCW.

Restore CCW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months BWOG STS 3.7.7-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 SWS 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Service Water System (SWS)

LCO 3.7.8 Two SWS trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SWS train A.1 -------------NOTES--------------

inoperable. 1. [ Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating,"

for emergency diesel generator made inoperable by SWS. ]

2. [ Enter Applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops

- MODE 4," for decay heat removal made inoperable by SWS. ]

Restore SWS train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months BWOG STS 3.7.8-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 UHS 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS)

LCO 3.7.9 The UHS shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. [ One or more cooling A.1 Restore cooling tower 7 days ]

towers with one cooling fan(s) to OPERABLE tower fan inoperable. status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

REVIEWER'S NOTE----- CB.1 Verify water temperature of Once per hour]

The [ ]°F is the maximum the UHS is [90]°F allowed UHS temperature averaged over the previous value and is based on 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period.

temperature limitations of the equipment that is relied upon for accident mitigation and safe shutdown of the unit.

CB. [ Water temperature of the UHS > [90]°F and

[ ]°F.

DC. [ Required Action DC.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and associated Completion Time of AND Condition CA or B not met. DC.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BWOG STS 3.7.9-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 UHS 3.7.9 CONDITION REQUIRED ACTION COMPLETION TIME OR ]

UHS inoperable [for reasons other than Condition A or CB].

BWOG STS 3.7.9-2 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 CREVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Ventilation System (CREVS)

LCO 3.7.10 Two CREVS trains shall be OPERABLE.

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

The control room boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, and 4, [5, and 6],

[During movement of [recently] irradiated fuel assemblies].

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREVS train A.1 Restore CREVS train to 7 days inoperable. OPERABLE status.

B. Two CREVS trains B.1 Restore control room 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable due to boundary to OPERABLE inoperable control room status.

boundary in MODE 1, 2, 3, or 4.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months BWOG STS 3.7.10-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 CREVS 3.7.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. [ Required Action and D.1 --------------NOTE---------------

associated Completion Place in emergency mode if Time of Condition A not automatic transfer to met during movement of emergency mode

[recently] irradiated fuel inoperable.

assemblies. -------------------------------------

Place OPERABLE CREVS Immediately train in emergency mode.

OR D.2 Suspend movement of Immediately ]

[recently] irradiated fuel assemblies.

E. [ Two CREVS trains E.1 Suspend movement of Immediately ]

inoperable during [recently] irradiated fuel movement of [recently] assemblies.

irradiated fuel assemblies.

F. Two CREVS trains F.1 Enter LCO 3.0.3. Immediately inoperable during MODE 1, 2, 3, or 4 for reasons other than Condition B.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREVS train for [ 10 continuous 31 days hours with the heaters operating or (for system without heaters) 15 minutes].

BWOG STS 3.7.10-2 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 CREATCS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Temperature Control System (CREATCS)

LCO 3.7.11 Two CREATCS trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4, [5, and 6],

[During movement of [recently] irradiated fuel assemblies].

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREATCS train A.1 Restore CREATCS train to 30 days inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met in MODE 1, 2, 3, or 4. B.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months C. [ Required Action and C.1 Place OPERABLE Immediately associated Completion CREATCS train in Time of Condition A not operation.

met during movement of

[recently] irradiated fuel OR assemblies.

C.2 Suspend movement of Immediately ]

[recently] irradiated fuel assemblies.

D. [ Two CREATCS trains D.1 Suspend movement of Immediately ]

inoperable during [recently] irradiated fuel movement of [recently] assemblies.

irradiated fuel assemblies.

BWOG STS 3.7.11-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 CREATCS 3.7.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two CREATCS trains E.1 Enter LCO 3.0.3. Immediately inoperable during MODE 1, 2, 3, or 4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Verify each CREATCS train has the capability to [18] months remove the assumed heat load.

BWOG STS 3.7.11-2 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System,

b. Two diesel generators (DGs) each capable of supplying one train of the onsite Class 1E AC Electrical Power Distribution System, and

[ c. Automatic load sequencers for Train A and Train B. ]

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

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

LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One [required] offsite A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months circuit inoperable. OPERABLE [required]

offsite circuit. AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 Declare required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from with no offsite power discovery of no offsite available inoperable when power to one train its redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND BWOG STS 3.8.1-1 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore [required] offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE status.

B. One [required] DG B.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. OPERABLE [required]

offsite circuit(s). AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required feature(s) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the inoperable discovery of DG inoperable when its Condition B redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND B.3.1 Determine OPERABLE [24] hours DG(s) is not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for [24] hours OPERABLE DG(s).

AND B.4 Restore [required] DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

BWOG STS 3.8.1-2 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two [required] offsite C.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable. inoperable when its discovery of redundant required Condition C feature(s) is inoperable. concurrent with inoperability of redundant required feature(s)

AND C.2 Restore one [required] 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

D. One [required] offsite -------------------NOTE--------------------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, AND "Distribution Systems - Operating,"

when Condition D is entered with no One [required] DG AC power source to any train.

inoperable. ------------------------------------------------

D.1 Restore [required] offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months circuit to OPERABLE status.

OR D.2 Restore [required] DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

E. Two [required] DGs E.1 Restore one [required] DG 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months inoperable. to OPERABLE status.

BWOG STS 3.8.1-3 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

REVIEWER'S NOTE----- F.1 Restore [required] [12] hours ]

[ This Condition may be [automatic load sequencer]

deleted if the unit design is to OPERABLE status.

such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads following a loss of offsite power independent of, or coincident with, a Design Basis Event.

F. One [required]

[automatic load sequencer] inoperable.

G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion Time of Condition A, B, AND C, D, E, or [F] not met.

G.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months H. Three or more [required] H.1 Enter LCO 3.0.3. Immediately AC sources inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated 7 days power availability for each [required] offsite circuit.

BWOG STS 3.8.1-4 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One [or two] battery A.1 Restore battery terminal 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months charger[s on one train] voltage to greater than or inoperable. equal to the minimum established float voltage.

AND A.2 Verify battery float current Once per [12] hours

[2] amps.

AND A.3 Restore battery charger[s] 7 days to OPERABLE status.

[ B. One [or two] batter[y][ies B.1 Restore batter[y][ies] to [2] hours ]

on one train] inoperable. OPERABLE status.

C. One DC electrical power C.1 Restore DC electrical [2] hours subsystem inoperable power subsystem to for reasons other than OPERABLE status.

Condition A [or B].

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion Time not met. AND D.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months BWOG STS 3.8.4-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Inverters - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE.

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

[ [One/two] inverter[s] may be disconnected from [its/their] associated DC bus for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform an equalizing charge on [its/their]

associated [common] battery provided:

a. The associated AC vital bus(es) [is/are] energized from [its/their]

[Class 1E constant voltage source transformers] [inverter using internal AC source] and

b. All other AC vital buses are energized from their associated OPERABLE inverters. ]

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One [required] inverter A.1 --------------NOTE---------------

inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any vital bus de-energized.

Restore inverter to 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months BWOG STS 3.8.7-1 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC --------------------NOTE-------------------

electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC trains made inoperable by inoperable power distribution subsystems.

A.1 Restore AC electrical power 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months distribution subsystem(s) to OPERABLE status.

B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months buses inoperable. subsystem(s) to OPERABLE status.

C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power power distribution distribution subsystems subsystem(s) to inoperable. OPERABLE status.

BWOG STS 3.8.9-1 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND D.2 Be in MODE 45. 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months E. Two or more electrical E.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to 7 days

[required] AC, DC, and AC vital bus electrical power distribution subsystems.

BWOG STS 3.8.9-2 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 ESFAS Instrumentation B 3.3.5 BASES ACTIONS (continued)

A.1 Condition A applies when one channel becomes inoperable in one or more Parameters. If one ESFAS channel is inoperable, placing it in a tripped condition leaves the system in a one-out-of-two condition for actuation. Thus, if another channel were to fail, the ESFAS instrumentation could still perform its actuation functions. This action is completed when all of the affected output relays and block timers are tripped. This can normally be accomplished by tripping the affected bistables or tripping the individual output relays and block timers. [At this unit, the specific output relays associated with each ESFAS instrumentation channel are listed in the following document:]

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is sufficient time to perform the Required Action.

B.1, B.2.1, B.2.2, and B.2.3 Condition B applies when Required Action A.1 is not met within the required Completion Time or when one or more parameters have more than one inoperable channel. If Condition B applies, the unit must be brought to a MODE in which the overall plant risk is minimized the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and, for the RCS Pressure - Low Setpoint, to < [1800] psig, for the RCS Pressure - Low Low Setpoint, to

< [900] psig, and for the RB Pressure High Setpoint and High High Setpoint, to MODE 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 5). In MODE 4 the energy in the RCS is lower resulting in a lower risk of an event occurring which would require the ESFAS instrumentation. The ESFAS functions can be manually initiated if needed. In MODE 4, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state.

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 All ESFAS Parameters listed in Table 3.3.5-1 are subject to CHANNEL REQUIREMENTS CHECK, CHANNEL FUNCTIONAL TEST, CHANNEL CALIBRATION, and response time testing. The operational bypasses associated with each ESFAS instrumentation channel are also subject to these SRs to ensure OPERABILITY of the ESFAS instrumentation channel.

BWOG STS B 3.3.5-14 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 ESFAS Instrumentation B 3.3.5 BASES SURVEILLANCE REQUIREMENTS (continued) actuation setpoint value at the sensor to the point at which the end device is actuated. Thus, this SR encompasses the automatic actuation logic components covered by LCO 3.3.7 and the operation of the mechanical ESF components.

Response time tests are conducted on an [18] month STAGGERED TEST BASIS. Testing of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel.

Therefore, staggered testing results in response time verification of these devices every [18] months. The 18 month test Frequency is based on unit operating experience, which shows that random failures of instrumentation components causing serious response time degradation but not channel failure are infrequent occurrences.

REFERENCES 1. FSAR, Chapter [7].

2. 10 CFR 50.49.

3. [Unit Specific Setpoint Methodology.]

4. FSAR, Chapter [14].

5. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

BWOG STS B 3.3.5-17 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 ESFAS Manual Initiation B 3.3.6 BASES ACTIONS (continued)

A.1 Condition A applies when one manual initiation channel of one or more ESFAS Functions becomes inoperable. Required Action A.1 must be taken to restore the channel to OPERABLE status within the next 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is based on unit operating experience and administrative controls, which provide alternative means of ESFAS Function initiation via individual component controls. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is consistent with the allowed outage time for the safety systems actuated by ESFAS.

B.1 and B.2 Required Action B.1 and Required Action B.2 apply if Required Action A.1 cannot be met within the required Completion Time. If Required Action A.1 cannot be met within the required Completion Time, the unit must be brought to a MODE in which the overall plant risk is minimizedLCO does not apply. To achieve this status, the unit 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 4 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 1). In MODE 4 the energy in the RCS is lower resulting in a lower risk of an event occurring which would require the ESFAS instrumentation. The ESFAS functions can be manually initiated via the individual component controls if needed. In MODE 4, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. The allowed Completion Times are reasonable, based on operating experience, to reach the required MODES from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.3.6.1 REQUIREMENTS This SR requires the performance of a CHANNEL FUNCTIONAL TEST of the ESFAS manual initiation. This test verifies that the initiating circuitry is OPERABLE and will actuate the end device (i.e., pump, valves, etc.).

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit BWOG STS B 3.3.6-3 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 ESFAS Manual Initiation B 3.3.6 outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. This Frequency is demonstrated to be sufficient, based on operating experience, which shows these components usually pass the Surveillance when performed on the [18] month Frequency.

REFERENCES 1. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.None.

BWOG STS B 3.3.6-4 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 RCS Loops - MODE 4 B 3.4.6 BASES ACTIONS A.1 If only one required RCS loop or DHR loop is OPERABLE and in operation, redundancy for heat removal is lost. Action must be initiated to restore a second loop to OPERABLE status. Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 1). In MODE 4 the Steam Generators are available for heat removal via natural circulation. In MODE 4, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

A.2 If restoration is not accomplished and a DHR loop is OPERABLE, the unit must be brought to MODE 5 within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Bringing the unit to MODE 5 is a conservative action with regard to decay heat removal. With only one DHR loop OPERABLE, redundancy for decay heat removal is lost and, in the event of a loss of the remaining DHR loop, it would be safer to initiate that loss from MODE 5 rather than MODE 4.

The Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable, based on operating experience, to reach MODE 5 in an orderly manner and without challenging plant systems.

This Required Action is modified by a Note which indicates that the unit must be placed in MODE 5 only if a DHR loop is OPERABLE. With no DHR loop OPERABLE, the unit is in a condition with only limited cooldown capabilities. Therefore, the actions are to be concentrated on the restoration of a DHR loop, rather than a cooldown of extended duration.

B.1 and B.2 If two required RCS or DHR loops are inoperable or a required loop is not in operation, except during conditions permitted by the Note in the LCO section, all operations involving introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action to restore one RCS or DHR loop to OPERABLE status and operation must be initiated. The required margin to criticality must not be reduced in this type of operation.

Suspending the introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to ensure continued safe operation. With coolant added BWOG STS B 3.4.6-3 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 RCS Loops - MODE 4 B 3.4.6 without forced circulation, unmixed coolant could be introduced to the core, however, coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

The immediate Completion Times reflect the importance of maintaining operation for decay heat removal. The action to restore must continue until one loop is restored to operation.

BWOG STS B 3.4.6-4 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 RCS Loops - MODE 4 B 3.4.6 BASES SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This Surveillance requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of the required DHR or RCS loop in operation to ensure forced flow is providing decay heat removal. Verification includes flow rate, temperature, or pump status monitoring. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval has been shown by operating practice to be sufficient to regularly assess RCS loop status. In addition, control room indication and alarms will normally indicate loop status.

SR 3.4.6.2 Verification that each required pump is OPERABLE ensures that an additional RCS or DHR loop can be placed in operation if needed to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to each required pump. Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability. The Frequency of 7 days is considered reasonable in view of other administrative controls and has been shown to be acceptable by operating experience.

This SR is modified by a Note that states the SR is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

REFERENCES 1. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.None.

BWOG STS B 3.4.6-5 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS (continued)

B.1.1, B.1.2, and B.2 With required gaseous or particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is required. Either grab samples of the containment atmosphere must be taken and analyzed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information. With a sample obtained and analyzed or a water inventory balance performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the reactor may be operated for up to 30 days to allow restoration of at least one of the radioactivity monitors.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishing steady state operation (stable temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and [RCP seal injection and return flows]). The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established. The 30 day Completion Time recognizes at least one other form of leak detection is available.

C.1 and C.2 If a Required Action of Condition A or B cannot be met within the required Completion Time, the unit must be brought to a MODE in which the overall plant risk is minimizedLCO does not apply. To achieve this status, the unit 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the RCS pressure is lower and the risk of significant RCS leakage is reduced. In MODE 4, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. 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.

D.1 With both required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

BWOG STS B 3.4.15-4 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 RCS Leakage Detection Instrumentation B 3.4.15 BASES SURVEILLANCE SR 3.4.15.1 REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. The check gives reasonable confidence that each channel is operating properly. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.15.2 SR 3.4.15.2 requires the performance of a CHANNEL FUNCTIONAL TEST of the required containment atmosphere radioactivity monitor. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 92 days considers instrument reliability, and operating experience has shown it proper for detecting degradation.

SR 3.4.15.3 and SR 3.4.15.4 These SRs require the performance of a CHANNEL CALIBRATION for each of the required RCS leakage detection instrumentation channels.

The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of [18] months is a typical refueling cycle and considers channel reliability. Again, operating experience has proven this Frequency is acceptable.

REFERENCES 1. 10 CFR 50, Appendix A, Section IV, GDC 30.

2. Regulatory Guide 1.45.

3. FSAR, Section [ ] .

4. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

BWOG STS B 3.4.15-5 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 BWST B 3.5.4 BASES LCO The BWST exists to ensure that an adequate supply of borated water is available to cool and depressurize the containment in the event of a DBA; to cool and cover the core in the event of a LOCA, thereby ensuring the reactor remains subcritical following a DBA; and to ensure an adequate level exists in the containment sump to support ECCS and containment spray pump operation in the recirculation MODE. To be considered OPERABLE, the BWST must meet the limits for water volume, boron concentration, and temperature established in the SRs.

APPLICABILITY In MODES 1, 2, 3, and 4, the BWST OPERABILITY requirements are dictated by the ECCS and Containment Spray System OPERABILITY requirements. Since both the ECCS and Containment Spray System must be OPERABLE in MODES 1, 2, 3, and 4, the BWST must be OPERABLE to support their operation.

Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops -

MODE 5, Loops Not Filled," respectively. MODE 6 core cooling requirements are addressed by LCO 3.9.4, "DHR and Coolant Circulation

- High Water Level," and LCO 3.9.5, "DHR and Coolant Circulation - Low Water Level."

ACTIONS A.1 With either the BWST boron concentration or borated water temperature not within limits, the condition must be corrected within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In this condition, neither the ECCS nor the Containment Spray System can perform its design functions. Therefore, prompt action must be taken to restore the tank to OPERABLE status or to place the plant in a MODE in which the overall plant risk is minimized these systems are not required.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit to restore the temperature or boron concentration to within limits was developed considering the time required to change boron concentration or temperature and assuming that the contents of the tank are still available for injection.

B.1 and B.2 If the BWST boron concentration is not restored to within limits within the associated Completion Time, the plant must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 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. Reference 2 demonstrated that it is acceptable to remain in MODE 4 in this condition because the boron concentration limit is based on MODE 1 events and there is additional SHUTDOWN MARGIN available for events initiated in MODE 4.

BWOG STS B 3.5.4-4 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 BWST B 3.5.4 C.1 With BWST water temperature not within limits, it must be returned to within limits within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . If the temperature is not within limits, the ECCS and Containment Spray systems may not be able to perform their respective design functions; therefore, prompt action must be taken to restore the tank to OPERABLE status. The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore the BWST water temperature to within limits was developed considering the time required to change water temperature and that the contents of the tank are still available for injection.

DB.1 With the BWST inoperable for reasons other than Condition A or C (e.g.,

water volume), levels must be restored to within required limits within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In this condition, neither the ECCS nor the Containment Spray System can perform its design functions. Therefore, prompt action must be taken to restore the tank to OPERABLE status or to place the plant in a MODE in which the BWST is not required. The allowed Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore the BWST to OPERABLE status is based on this condition simultaneously affecting multiple redundant trains.

BWOG STS B 3.5.4-5 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 BWST B 3.5.4 BASES ACTIONS (continued)

EC.1 and EC.2 If the BWST cannot be restored to OPERABLE status within the associated Completion Times of Condition C or D Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 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 3.5.4.1 REQUIREMENTS Verification every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that the BWST water temperature is within the specified temperature band ensures that the boron will not precipitate; the fluid will not freeze; the fluid temperature entering the reactor vessel will not be colder than assumed in the reactor vessel stress analysis; and the fluid temperature entering the reactor vessel will not be hotter than assumed in the LOCA analysis. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is sufficient to identify a temperature change that would approach either temperature limit and has been shown to be acceptable through operating experience.

The SR is modified by a Note that requires the Surveillance to be performed only when ambient air temperatures are outside the operating temperature limits of the BWST. With ambient temperatures within this band, the BWST temperature should not exceed the limits.

SR 3.5.4.2 Verification every 7 days that the BWST contained volume is within the required range ensures that a sufficient initial supply is available for injection and to support continued ECCS pump operation on recirculation.

Since the BWST volume is normally stable and provided with a low level alarm, a 7 day Frequency has been shown to be appropriate through operating experience.

BWOG STS B 3.5.4-6 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 BWST B 3.5.4 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.4.3 Verification every 7 days that the boron concentration of the BWST fluid is within the required band ensures that the reactor will remain subcritical following a LOCA. Since the BWST volume is normally stable, a 7 day sampling Frequency is appropriate and has been shown to be acceptable through operating experience.

REFERENCES 1. FSAR, Section [6.1].

2. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

BWOG STS B 3.5.4-7 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment B 3.6.1 BASES LCO (continued)

Individual leakage rates specified for the containment air lock (LCO 3.6.2)

[and purge valves with resilient seals (LCO 3.6.3)] are not specifically part of the acceptance criteria of 10 CFR 50, Appendix J. Therefore, leakage rates exceeding these individual limits only result in the containment being inoperable when the leakage results in exceeding the overall acceptance criteria of 1.0 La.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material into containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment. The requirements for containment during MODE 6 are addressed in LCO 3.9.3, "Containment Penetrations."

ACTIONS A.1 In the event containment is inoperable, containment 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 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining containment during MODES 1, 2, 3, and 4. This time period also ensures the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal.

B.1 and B.2 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the overall plant risk is minimized LCO 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). The release of stored energy to the Reactor Building in the event of an accident in MODE 4 is substantially less than the energy release assumed due to an accident at power. Therefore, the challenge to containment systems is substantially reduced. The analysis in Reference 4 assumed that the equipment hatch remains closed in MODE 4. Because of the reduction in RCS pressure and temperature in MODE 4, the likelihood of an event is also reduced. In addition, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE

5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant BWOG STS B 3.6.1-3 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 Containment B 3.6.1 BASES SURVEILLANCE SR 3.6.1.1 REQUIREMENTS Maintaining the containment OPERABLE requires compliance with the visual examinations and leakage rate test requirements of the Containment Leakage Rate Testing Program. The containment concrete visual examinations may be performed during either power operation, e.g., performed concurrently with other containment inspection-related activities such as tendon testing, or during a maintenance or refueling outage. The visual examinations of the steel liner plate inside containment are performed during maintenance or refueling outages since this is the only time the liner plate is fully accessible.

Failure to meet air lock and purge valve with resilient seal leakage limits specified in LCO 3.6.2 and LCO 3.6.3 does not invalidate the acceptability of these overall leakage determinations unless their contribution to overall Type A, B, and C leakage causes that to exceed limits. As left leakage prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test is required to be < 0.6 La for combined Type B and C leakage, and [< 0.75 La for Option A] [ 0.75 La for Option B] for overall Type A leakage. At all other times between required leakage rate tests, the acceptance criteria is based on an overall Type A leakage limit of 1.0 La. At 1.0 La the offsite dose consequences are bounded by the assumptions of the safety analysis. SR Frequencies are as required by the Containment Leakage Rate Testing Program. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.

SR Frequencies are as required by the Containment Leakage Rate Testing Program. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.

REVIEWERS NOTE-----------------------------------

Regulatory Guide 1.163 and NEI 94-01 include acceptance criteria for as-left and as-found Type A leakage rates and combined Type B and C leakage rates, which may be reflected in the Bases.

[ SR 3.6.1.2 For ungrouted, post tensioned tendons, this SR ensures that the structural integrity of the containment will be maintained in accordance with the provisions of the Containment Tendon Surveillance Program.

Testing and Frequency are in accordance with the ASME Code,Section XI, Subsection IWL (Ref. 54), and applicable addenda as required by 10 CFR 50.55a. ]

BWOG STS B 3.6.1-5 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 Containment B 3.6.1 BASES REFERENCES 1. 10 CFR 50, Appendix J, Option [A][B].

2. FSAR, Sections [14.1 and 14.2].

3. FSAR, Section [5.6].

4. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

54. ASME Code,Section XI, Subsection IWL.

BWOG STS B 3.6.1-6 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 Containment Air Locks B 3.6.2 BASES ACTIONS (continued)

D.1 and D.2 If the inoperable containment air lock cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the overall plant risk is minimized LCO 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 45 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). The release of stored energy to the Reactor Building in the event of an accident in MODE 4 is substantially less than the energy release assumed due to an accident at power. Therefore, the challenge to containment air locks is substantially reduced. Because of the reduction in RCS pressure and temperature in MODE 4, the likelihood of an event is also reduced. In addition, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE

5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. 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 3.6.2.1 REQUIREMENTS Maintaining containment air locks OPERABLE requires compliance with the leakage rate test requirements of the Containment Leakage Rate Testing Program. This SR reflects the leakage rate testing requirements with regard to air lock leakage (Type B leakage tests). The acceptance criteria were established during initial air lock and containment OPERABILITY testing. The periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overall containment leakage rate. The Frequency is required by the Containment Leakage Rate Testing Program.

The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. This is considered reasonable, since either air lock door is capable of providing a fission product barrier in the event of a DBA. Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria which is applicable to SR 3.6.1.1. This ensures that air lock leakage is properly accounted for in determining the combined Type B and C containment leakage rate.

SR 3.6.2.2 BWOG STS B 3.6.2-6 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Air Locks B 3.6.2 The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment OPERABILITY. Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment. Periodic testing of this interlock demonstrates BWOG STS B 3.6.2-7 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Air Locks B 3.6.2 BASES SURVEILLANCE REQUIREMENTS (continued) that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is not normally challenged when the containment air lock door is used for entry and exit (procedures require strict adherence to single door opening), this test is only required to be performed every 24 months. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage, and the potential for loss of containment OPERABILITY if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency. The 24 month Frequency is based on engineering judgment and is considered adequate given that the interlock is not challenged during the use of the airlock.

REFERENCES 1. 10 CFR 50, Appendix J, Option [A][B].

2. FSAR, Sections [14.1 and 14.2].

3. FSAR, Section [5.6].

4. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

BWOG STS B 3.6.2-8 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued)

Required Action does not require any testing or valve manipulation.

Rather, it involves verification that those isolation devices outside containment and potentially capable of being mispositioned are in the correct position. For the isolation devices inside containment, the time period specified as "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.

For the containment purge valve with resilient seal that is isolated in accordance with Required Action D.1, SR 3.6.3.6 must be performed at least once every [ ] days. This provides assurance that degradation of the resilient seal is detected and confirms that the leakage rate of the containment purge valve does not increase during the time the penetration is isolated. The normal Frequency for SR 3.6.3.6, 184 days, is based on an NRC initiative, Generic Issue B-20 (Ref. 78). Since more reliance is placed on a single valve while in this Condition, it is prudent to perform the SR more often. Therefore, a Frequency of once per [ ] days was chosen and has been shown acceptable based on operating experience.

Required Action D.2 is modified by two Notes. Note 1 applies to isolation devices located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned. ]

E.1 and E.2 If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the overall plant risk is minimizedLCO 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). The release of stored energy to the Reactor Building in the event of an accident in MODE 4 is substantially less than the energy release assumed due to an accident at power. Therefore, the challenge to containment isolation valves is substantially reduced. Because of the BWOG STS B 3.6.3-9 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Isolation Valves B 3.6.3 reduction in RCS pressure and temperature in MODE 4, the likelihood of an event is also reduced. In addition, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. 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.

BWOG STS B 3.6.3-10 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE [ SR 3.6.3.1 REQUIREMENTS Each [48] inch containment purge valve is required to be verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurious opening of a containment purge valve. Detailed analysis of the purge valves failed to conclusively demonstrate their ability to close during a LOCA in time to limit offsite doses. Therefore, these valves are required to be in the sealed closed position during MODES 1, 2, 3, and 4. A containment purge valve that is sealed closed must have motive power to the valve operator removed. This can be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator. In this application, the term "sealed" has no connotation of leak tightness. The Frequency is a result of an NRC initiative, Generic Issue B-24 (Ref. 97), related to containment purge valve use during unit operations. In the event purge valve leakage requires entry into Condition D, the Surveillance permits opening one purge valve in a penetration flow path to perform repairs. ]

SR 3.6.3.2 This SR ensures that the minipurge valves are closed as required or, if open, open for an allowable reason. If a purge valve is open in violation of this SR, the valve is considered inoperable. If the inoperable valve is not otherwise known to have excessive leakage when closed, it is not considered to have leakage outside of limits. The SR is not required to be met when the minipurge valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open. The minipurge valves are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The 31 day Frequency is consistent with other containment isolation valve requirements discussed in SR 3.6.3.3.

SR 3.6.3.3 This SR requires verification that each containment isolation manual valve and blind flange located outside containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the containment boundary is within BWOG STS B 3.6.3-11 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued)

The Note allows valves and blind flanges located in high radiation areas to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the access to these areas is typically restricted during MODES 1, 2, 3, and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small.

SR 3.6.3.5 Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses.

[The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program or 92 days.]

SR 3.6.3.6 For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, Option

[A][B] is required to ensure OPERABILITY. Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types. Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment), a Frequency of once per 184 days was established as part of the NRC resolution of Generic Issue B-20, "Containment Leakage Due to Seal Deterioration" (Ref. 78).

Additionally, this SR must be performed within 92 days after opening the valve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (greater than that occurring to a valve that has not been opened). Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened.

BWOG STS B 3.6.3-13 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Isolation Valves B 3.6.3 BASES REFERENCES 1. 10 CFR 20.

2. FSAR, Section [5.6].

3. FSAR, Sections [14.1 and 14.2].

4. FSAR, Section [5.3].

5. FSAR, Section [5.3].

6. Standard Review Plan 6.2.4.

7. Generic Issue B-2420.

8. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

98. Generic Issue B-2420.

BWOG STS B 3.6.3-15 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Pressure B 3.6.4 BASES BACKGROUND (continued) containment backpressure is calculated in a manner designed to conservatively minimize, rather than maximize, the containment pressure response in accordance with 10 CFR 50, Appendix K (Ref. 2).

Containment pressure satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO Maintaining containment pressure less than or equal to the LCO upper pressure limit ensures that, in the event of a DBA, the resultant peak containment accident pressure will remain below the containment design pressure. Maintaining containment pressure greater than or equal to the LCO lower pressure limit ensures that the containment will not exceed the design negative differential pressure following the inadvertent actuation of the Containment Spray System.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. Since maintaining containment pressure within design basis limits is essential to ensure initial conditions assumed in the accident analysis are maintained, the LCO is applicable in MODES 1, 2, 3, and 4.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, maintaining containment pressure within the limits of the LCO is not required in MODES 5 and 6.

ACTIONS A.1 When containment pressure is not within the limits of the LCO, containment pressure must be restored to within these limits within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The Required Action is necessary to return operation to within the bounds of the containment analysis. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is consistent with the ACTIONS of LCO 3.6.1, "Containment," which requires that containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

B.1 and B.2 If containment pressure cannot be restored within limits within the required Completion Time, the plant must be brought to a MODE in which the overall plant risk is minimizedLCO 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). The release of stored energy to the Reactor Building in the event of an accident in MODE 4 is substantially less than the energy release assumed due to an accident at power. Therefore, the BWOG STS B 3.6.4-2 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Pressure B 3.6.4 challenge to the containment systems due to an increase in containment pressure is substantially reduced. Because of the reduction in RCS pressure and temperature in MODE 4, the likelihood of an event is also reduced. In addition, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state.

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.

BWOG STS B 3.6.4-3 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Pressure B 3.6.4 BASES SURVEILLANCE SR 3.6.4.1 REQUIREMENTS Verifying that containment pressure is within limits ensures that operation remains within the limits assumed in the containment analysis. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency of this SR was developed after taking into consideration operating experience related to trending of containment pressure variations during the applicable MODES. Furthermore, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal containment pressure condition.

REFERENCES 1. FSAR, Section [14.2].

2. 10 CFR 50, Appendix K.

3. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

BWOG STS B 3.6.4-4 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Air Temperature B 3.6.5 BASES LCO During a DBA, with an initial containment average air temperature less than or equal to the LCO temperature limit, the resultant accident temperature profile assures that the containment structural temperature is maintained below its design temperature and that required safety related equipment will continue to perform its function.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, maintaining containment average air temperature within the limit is not required in MODE 5 or 6.

ACTIONS A.1 When containment average air temperature is not within the limit of the LCO, it must be restored within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This Required Action is necessary to return operation to within the bounds of the containment analysis. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is acceptable considering the sensitivity of the analysis to variations in this parameter and provides sufficient time to correct minor problems.

B.1 and B.2 If the containment average air temperature cannot be restored to within its limit within the required Completion Time, the plant must be brought to a MODE in which the overall plant risk is minimizedLCO 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 1). The release of stored energy to the Reactor Building in the event of an accident in MODE 4 is substantially less than the energy release assumed due to an accident at power. Therefore, the challenge to the containment systems due to an increase in containment temperature is substantially reduced. Because of the reduction in RCS pressure and temperature in MODE 4, the likelihood of an event is also reduced. In addition, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5.

However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. 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.

BWOG STS B 3.6.5-2 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Air Temperature B 3.6.5 BASES SURVEILLANCE SR 3.6.5.1 REQUIREMENTS Verifying that containment average air temperature is within the LCO limit ensures that containment operation remains within the limit assumed for the containment analyses. In order to determine the containment average air temperature, an arithmetic average is calculated, using measurements taken at locations within the containment selected to provide a representative sample of the overall containment atmosphere.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency of this SR is considered acceptable based on observed slow rates of temperature increase within containment as a result of environmental heat sources (due to the large volume of containment). Furthermore, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal containment temperature condition.

REFERENCES 1. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.None.

BWOG STS B 3.6.5-3 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Containment Spray and Cooling Systems B 3.6.6 BASES ACTIONS A.1 With one containment spray train inoperable, action must be taken to restore it to OPERABLE status within [7] days. In this condition, the remaining OPERABLE containment spray train is adequate to perform the heat removal function. However, the overall reliability is reduced because a single failure to the remaining containment spray train could result in loss of spray function. The [7] day Completion Time is reasonable to perform corrective maintenance on the inoperable containment spray train. The [7] day Completion Time is based on the findings of the deterministic and probabilistic analysis in Reference 5. Reference 5 concluded that extending the Completion Time to [7] days for an inoperable containment spray train proves plant operational flexibility while simultaneously reducing overall plant risk. This is because the risks incurred by having the containment spray train unavailable for a longer time at power will be substantially offset by the benefits associated with avoiding unnecessary plant transitions and by reducing risk during plant shutdown operations.

B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the overall plant risk is minimizedLCO 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 45 within 6084 hours0.0704 days 1.69 hours 0.0101 weeks 0.00231 months .

Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 6). The release of stored energy to the Reactor Building in the event of an accident in MODE 4 is substantially less than the energy release assumed due to an accident at power. Therefore, the challenge to the containment systems is substantially reduced. Because of the reduction in RCS pressure and temperature in MODE 4, the likelihood of an event is also reduced. In addition, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state.

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.

The extended interval to reach MODE 45 allows additional time to attempt restoration of the containment spray train and is reasonable when considering the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

C.1 BWOG STS B 3.6.6-5 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 Containment Spray and Cooling Systems B 3.6.6 With one of the required containment cooling trains inoperable, the inoperable containment cooling train must be restored to OPERABLE status within 7 days. The components in this degraded condition provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. The 7 day Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of a DBA occurring during this period.

BWOG STS B 3.6.6-6 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 Containment Spray and Cooling Systems B 3.6.6 BASES ACTIONS (continued)

D.1 and D.2 With one containment spray and one [required] containment cooling train inoperable, one of the required containment cooling trains 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 provide iodine removal capabilities and are capable of providing at least 100% of the heat 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 capabilities afforded by combinations of the Containment Spray System and Containment Cooling System, the iodine removal function of the Containment Spray System, and the low probability of a DBA occurring during this period.

E.1 With two of the required containment cooling trains inoperable, one of the required containment cooling trains 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 (both spray trains are OPERABLE or else Condition G is entered) provide iodine removal capabilities and are capable of providing at least 100% of the heat 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 capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of a DBA occurring during this period.

F.1 and F.2 If the Required Actions and associated Completion Times of Condition C, D, or E of this LCO are not met, the plant must be brought to a MODE in which the overall plant risk is minimizedLCO 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 6). The release of stored energy to the Reactor Building in the event of an accident in MODE 4 is substantially less than the energy release assumed due to an accident at power. Therefore, the challenge to the containment systems is substantially reduced. Because of the reduction in RCS pressure and temperature in MODE 4, the likelihood of an event is also reduced. In addition, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5.

However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. The allowed Completion Times are BWOG STS B 3.6.6-7 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 Containment Spray and Cooling Systems B 3.6.6 reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

G.1 With two containment spray trains or any combination of three or more containment spray and containment cooling trains inoperable, the unit is in a condition outside the accident analysis. Therefore, LCO 3.0.3 must be entered immediately.

BWOG STS B 3.6.6-8 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 Containment Spray and Cooling Systems B 3.6.6 BASES SURVEILLANCE SR 3.6.6.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the containment spray flow path provides assurance that the proper flow paths will exist for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these were verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This 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.

SR 3.6.6.2 Operating each [required] containment cooling train fan unit for 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 a significant degradation of the containment cooling trains occurring between surveillances and has been shown to be acceptable through operating experience.

SR 3.6.6.3 Verifying that each [required] containment cooling train provides an essential raw water cooling flow rate of [1780] 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.

SR 3.6.6.4 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 by the ASME Code (Ref. 76). Since the Containment Spray System pumps cannot be tested with flow through the BWOG STS B 3.6.6-9 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 Containment Spray and Cooling Systems B 3.6.6 BASES 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.

6. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

76. ASME Code for Operation and Maintenance of Nuclear Power Plants.

BWOG STS B 3.6.6-11 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 CCW System B 3.7.7 BASES ACTIONS (continued)

B.1 and B.2 If the CCW train cannot be restored to OPERABLE status in the associated Completion Time, the unit must be placed in a MODE in which the overall plant risk is minimizedLCO 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 5 4 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). The stored energy in the RCS that must be removed by the CCW System in the event of an accident in MODE 4 is substantially less than the energy assumed due to an accident at power.

Therefore, the heat loads on the CCW System are substantially reduced.

Because of the reduction in RCS pressure and temperature in MODE 4, the likelihood of an event is also reduced. In addition, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5.

However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. 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 3.7.7.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the CCW flow to individual components may render those components inoperable, but does not affect the OPERABILITY of the CCW System.

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

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

SR 3.7.7.2 BWOG STS B 3.7.7-3 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 CCW System B 3.7.7 BASES SURVEILLANCE REQUIREMENTS (continued) controls. 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 that these components usually pass the Surveillance when performed at the

[18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

SR 3.7.7.3 This SR verifies proper automatic operation of the CCW pumps on an actual or simulated actuation signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation. 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 that these components usually pass the Surveillance when performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

REFERENCES 1. FSAR, Section [9.2.2].

2. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

BWOG STS B 3.7.7-5 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 SWS B 3.7.8 BASES ACTIONS (continued)

OPERABLE SWS train could result in loss of SWS function. Required Action A.1 is modified by two Notes. The first Note indicates that the applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources -

Operating," should be entered if an inoperable SWS train results in an inoperable EDG. The second Note indicates that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4,"

should be entered if an inoperable SWS train results in an inoperable DHR train. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this period.

B.1 and B.2 If the SWS train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the overall plant risk is minimizedLCO 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). The stored energy in the RCS that must be removed by the SWS in the event of an accident in MODE 4 is substantially less than the energy assumed due to an accident at power.

Therefore, the heat loads on the SWS are substantially reduced.

Because of the reduction in RCS pressure and temperature in MODE 4, the likelihood of an event is also reduced. In addition, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5.

However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. 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 3.7.8.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the SWS flow path provides assurance that the proper flow paths exist for SWS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to locking, sealing, or securing. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves.

BWOG STS B 3.7.8-3 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 SWS B 3.7.8 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.8.2 The SR verifies proper automatic operation of the SWS valves. The SWS is a normally operating system that cannot be fully actuated as part of the normal testing. This SR is not required for valves 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 a unit 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

[18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

SR 3.7.8.3 The SR verifies proper automatic operation of the SWS pumps on an actual or simulated actuation signal. The SWS is a normally operating system that cannot be fully actuated as part of normal testing during normal operation. The [18] 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. Operating experience has shown that these components usually pass the Surveillance when performed at an [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

REFERENCES 1. FSAR, Section [9.2.1].

2. FSAR, Section [6.2].

3. FSAR, Section [6.3].

4. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

BWOG STS B 3.7.8-5 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 UHS B 3.7.9 BASES APPLICABLE The UHS is the sink for heat removal from the reactor core following all SAFETY accidents and anticipated operational occurrences in which the unit is ANALYSES cooled down and placed on [decay heat removal]. Its maximum post accident heat load occurs approximately 20 minutes after a design basis loss of coolant accident (LOCA). Near this time, the unit switches from injection to recirculation and the containment cooling systems are required to remove the core decay heat.

The operating limits are based on conservative heat transfer analyses for the worst case LOCA. Reference 1 provides the details of the assumptions used in the analysis. These assumptions include: worst expected meteorological conditions, conservative uncertainties when calculating decay heat, and the worst case failure (e.g., single failure of a manmade structure). The UHS is designed in accordance with Regulatory Guide 1.27 (Ref. 2), which requires a 30 day supply of cooling water in the UHS.

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

LCO The UHS is required to be OPERABLE and is considered OPERABLE if

[it contains a sufficient volume of water at or below the maximum temperature] that would allow the SWS to operate for at least 30 days following the design basis LOCA without the loss of net positive suction head (NPSH), and without exceeding the maximum design temperature of the equipment served by the SWS. To meet this condition, the UHS temperature should not exceed [90]°F, and the level should not fall below

[562] ft [mean sea level] during normal unit operation.

APPLICABILITY In MODES 1, 2, 3, and 4, the UHS is a normally operating system that is required to support the OPERABILITY of the equipment serviced by the UHS and is required to be OPERABLE in these MODES.

In MODES 5 and 6, the OPERABILITY requirements of the UHS are determined by the systems it supports.

ACTIONS [ A.1 If one or more cooling towers have one fan inoperable (i.e., at least up to one fan per cooling tower is OPERABLEinoperable), action must be taken to restore the inoperable cooling tower fan(s) to OPERABLE status within 7 days.

The 7 day Completion Time is reasonable, based on the low probability of an accident occurring during the 7 days that one cooling tower fan is inoperable in one or more cooling towers, the number of available systems, and the time required to complete the Required Action. ]

BWOG STS B 3.7.9-2 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 UHS B 3.7.9 BASES ACTIONS (continued)

B.1 and B.2 If the cooling tower fan cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to 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 .

Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). The stored energy in the RCS that must be removed by the UHS the event of an accident in MODE 4 is substantially less than the energy assumed due to an accident at power. Therefore, the heat load on the UHS is substantially reduced. Because of the reduction in RCS pressure and temperature in MODE 4, the likelihood of an event is also reduced. In addition, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state.

[ BC.1

REVIEWERS NOTE-----------------------------------

The [ ]°F is the maximum allowed UHS temperature value and is based on temperature limitations of the equipment that is relied upon for accident mitigation and safe shutdown of the unit.

With water temperature of the UHS > [90]°F, the design basis assumption associated with initial UHS temperature is bounded provided the temperature of the UHS averaged over the previous 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period is

[90]°F. With the water temperature of the UHS > [90]°F, long term cooling capability of the ECCS loads and DGs may be affected.

Therefore, to ensure long term cooling capability is provided to the ECCS loads when water temperature of the UHS is > [90]°F, Required Action CB.1 is provided to more frequently monitor the water temperature of the UHS and verify the temperature is [90]°F when averaged over the previous 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. The once per hour Completion Time takes into consideration UHS temperature variations and the increased monitoring frequency needed to ensure design basis assumptions and equipment limitations are not exceeded in this condition. If the water temperature of the UHS exceeds [90]°F when averaged over the previous 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period or the water temperature of the UHS exceeds [ ]°F, Condition DC must be entered immediately.]

BWOG STS B 3.7.9-3 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 UHS B 3.7.9

[ DC.1 and DC.2 If the Required Actions and Completion Time of Condition C[A or B] are not met, or the UHS is inoperable [for reasons other than Condition A or CB], the unit must be placed in a MODE in which the LCO 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 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 unit conditions from full power conditions in an orderly manner and without challenging unit systems. ]

SURVEILLANCE [ SR 3.7.9.1 REQUIREMENTS This SR verifies that adequate long term (30 days) cooling can be maintained. The level specified also ensures NPSH is available for operating the SWS pumps. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on operating experience related to the trending of the parameter variations during the applicable MODES. This SR verifies that the UHS water level is [ ] ft [mean sea level]. ]

BWOG STS B 3.7.9-4 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 UHS B 3.7.9 BASES SURVEILLANCE REQUIREMENTS (continued)

[ SR 3.7.9.2 This SR verifies that the SWS can cool the CCW System to at least its maximum design temperature within the maximum [ accident or normal heat loads for 30 days following a Design Basis Accident. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on operating experience related to the trending of the parameter variations during the applicable MODES. This SR verifies that the UHS average water temperature is [90]°F. ]

[ SR 3.7.9.3 Operating each cooling tower fan for [15] minutes ensures that all fans are OPERABLE and that all associated controls are functioning properly.

It also ensures that fan or motor failure, or excessive vibration, can be detected for corrective action. The 31 day Frequency is based on operating experience, known reliability of the fan units, the redundancy available, and the low probability of significant degradation of the UHS cooling tower fans occurring between surveillances. ]

REFERENCES 1. FSAR, Section [9.2.5].

2. Regulatory Guide 1.27.

3. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

BWOG STS B 3.7.9-5 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 CREVS B 3.7.10 BASES ACTIONS A.1 With one CREVS train inoperable, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREVS train is adequate to perform the control room radiation protection function. However, the overall reliability is reduced because a failure in the OPERABLE CREVS train could result in loss of CREVS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

B.1

REVIEWERS NOTE-----------------------------------

Adoption of Condition B is dependent on a commitment from the licensee to have written procedures available describing compensatory measures to be taken in the event of an intentional or unintentional entry into Condition B.

If the control room boundary is inoperable in MODE 1, 2, 3, or 4, the CREVS trains cannot perform their intended functions. Actions must be taken to restore an OPERABLE control room boundary within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

During the period that the control room boundary is inoperable, appropriate compensatory measures (consistent with the intent of GDC

19) should be utilized to protect control room operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of compensatory measures. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the control room boundary.

C.1 and C.2 In MODE 1, 2, 3, or 4, if the inoperable CREVS train or control room boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE in which the overall plant risk is minimizedLCO 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). The CREVS is utilized in the event the control room is isolated. The control room is isolated in the event of an accident, such as BWOG STS B 3.7.10-3 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 CREVS B 3.7.10 a loss of coolant accident. Because of the reduction in RCS pressure and temperature in MODE 4, the likelihood of an accident is also reduced. In addition, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. 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.

BWOG STS B 3.7.10-4 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 CREVS B 3.7.10 BASES SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once every month adequately checks this system. Monthly heater operations dry out any moisture that has accumulated in the charcoal because of humidity in the ambient air. [Systems with heaters must be operated for 10 continuous hours with the heaters energized. Systems without heaters need only be operated for 15 minutes to demonstrate the function of the system.]

The 31 day Frequency is based on the known reliability of the equipment and the two train redundancy available.

SR 3.7.10.2 This SR verifies that the required CREVS testing is performed in accordance with the [Ventilation Filter Testing Program (VFTP)]. The

[VFTP] includes testing HEPA filter performance, charcoal absorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal. Specific test frequencies and additional information are discussed in detail in the [VFTP].

SR 3.7.10.3 This SR verifies that [each CREVS train starts] [or the control room isolates] and operates on an actual or simulated actuation signal. The Frequency of [18] months is consistent with that specified in Reference 43.

SR 3.7.10.4 This SR verifies the integrity of the control room enclosure and the assumed inleakage rates of the potentially contaminated air. The control room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify that the CREVS is functioning properly. During the emergency mode of operation, the CREVS is designed to pressurize the control room [0.125] inches water gauge positive pressure, with respect to adjacent areas, to prevent unfiltered inleakage. The CREVS is designed to maintain this positive pressure with one train at a flow rate of [3300] cfm. This value includes [300] cfm of outside air. The Frequency of [18] months on a STAGGERED TEST BASIS is consistent with industry practice and other filtration SRs.

BWOG STS B 3.7.10-6 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 CREVS B 3.7.10 BASES REFERENCES 1. FSAR, Section [9.4].

2. FSAR, Chapter [15].

3. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

43. Regulatory Guide 1.52, Rev. [2].

BWOG STS B 3.7.10-7 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 CREATCS B 3.7.11 BASES LCO Two independent and redundant trains of the CREATCS are required to be OPERABLE to ensure that at least one is available, assuming a single failure disables the other train. Total system failure could result in the equipment operating temperature exceeding limits in the event of an accident.

The CREATCS is considered OPERABLE when the individual components that are necessary to maintain control room temperature are OPERABLE in both trains. These components include the cooling coils, water cooled condensing units, and associated temperature control instrumentation. In addition, the CREATCS must be OPERABLE to the extent that air circulation can be maintained.

APPLICABILITY In MODES 1, 2, 3, 4, [5, and 6,] and during movement of [recently]

irradiated fuel assemblies [i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)], the CREATCS must be OPERABLE to ensure that the control room temperature will not exceed equipment OPERABILITY requirements following isolation of the control room.

ACTIONS A.1 With one CREATCS train inoperable, action must be taken to restore OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CREATCS train is adequate to maintain the control room temperature within limits. However, the overall reliability is reduced because a failure in the OPERABLE CREATCS train could result in a loss of CREATCS function. The 30 day Completion Time is based on the low probability of an event occurring requiring control room isolation, the consideration that the remaining train can provide the required capabilities, and the alternate safety or nonsafety related cooling means that are available.

Concurrent failure of two CREATCS trains would result in the loss of function capability; therefore, LCO 3.0.3 must be entered immediately.

B.1 and B.2 In MODE 1, 2, 3, or 4, if the inoperable CREATCS train cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE in which the overall plant risk is minimizedLCO 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). The CREATCS is utilized in the event the control room is isolated. The control room is isolated in the event of an accident, such as BWOG STS B 3.7.11-2 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 CREATCS B 3.7.11 a loss of coolant accident. Because of the reduction in RCS pressure and temperature in MODE 4, the likelihood of an accident is also reduced. In addition, there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner without challenging unit systems.

BWOG STS B 3.7.11-3 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 CREATCS B 3.7.11 BASES ACTIONS (continued)

[ C.1 and C.2

[In MODE 5 or 6, or] during movement of [recently] irradiated fuel, if the inoperable CREATCS train cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREATCS train must be placed in operation immediately. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action C.1 is to immediately suspend activities that could release radioactivity that might require the isolation of the control room. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position. ]

[ D.1

[In MODE 5 or 6, or] during movement of [recently] irradiated fuel assemblies, with two CREATCS trains inoperable, action must be taken to immediately suspend activities that could release radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position. ]

E.1 If both CREATCS trains are inoperable in MODE 1, 2, 3, or 4, the CREATCS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.11.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the heat load assumed in the [safety analyses]. This SR consists of a combination of testing and calculations. An [18] month Frequency is appropriate, as significant degradation of the CREATCS is slow and is not expected over this time period.

REFERENCES 1. FSAR, Section [9.4].

2. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

BWOG STS B 3.7.11-4 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

According to Reference 6, with both DGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

[ F.1 The sequencer(s) is an essential support system to [both the offsite circuit and the DG associated with a given ESF bus]. [Furthermore, the sequencer is on the primary success path for most major AC electrically powered safety systems powered from the associated ESF bus.]

Therefore, loss of an [ESF bus sequencer] affects every major ESF system in the [division]. The [12] hour Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining sequencer OPERABILITY. This time period also ensures that the probability of an accident (requiring sequencer OPERABILITY) occurring during periods when the sequencer is inoperable is minimal.

This Condition is preceded by a Note that allows the Condition to be deleted if the unit design is such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads under any conditions. Implicit in this Note is the concept that the Condition must be retained if any sequencer failure mode results in the inability to start all or part of the safety loads when required, regardless of power availability, or results in overloading the offsite power circuit to a safety bus during an event thereby causing its failure. Also implicit in the Note is that the Condition is not applicable to any train that does not have a sequencer. ]

G.1 and G.2 If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the overall plant risk is minimizedLCO does not apply. To achieve this status, the unit 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 7). There are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5.

In particular, in MODE 4 the turbine driven emergency feedwater pump[s]

are available following a loss of AC sources to provide RCS cooling via the steam generators utilizing natural circulation. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state.

The allowed Completion Times are reasonable, based on operating BWOG STS B 3.8.1-12 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

BWOG STS B 3.8.1-13 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

H.1 Condition H corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and testing of all REQUIREMENTS important areas and features, especially those that have a standby function, in accordance with 10 CFR 50, Appendix A, GDC 18 (Ref. 98).

Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for demonstrating the OPERABILITY of the DGs are in accordance with the recommendations of Regulatory Guide 1.9 (Ref. 3), Regulatory Guide 1.108 (Ref. 109), and Regulatory Guide 1.137 (Ref. 1110), as addressed in the FSAR.

Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. The minimum steady state output voltage of [3740] V is 90% of the nominal 4160 V output voltage. This value, which is specified in ANSI C84.1 (Ref. 1211), allows for voltage drop to the terminals of 4000 V motors whose minimum operating voltage is specified as 90% or 3600 V. It also allows for voltage drops to motors and other equipment down through the 120 V level where minimum operating voltage is also usually specified as 90% of name plate rating.

The specified maximum steady state output voltage of [4756] V is equal to the maximum operating voltage specified for 4000 V motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating voltages.

The specified minimum and maximum frequencies of the DG are 58.8 Hz and 61.2 Hz, respectively. These values are equal to +/- 2% of the 60 Hz nominal frequency and are derived from the recommendations given in Regulatory Guide 1.9 (Ref. 3).

BWOG STS B 3.8.1-14 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by four Notes. Note 1 indicates that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 2 states that momentary transients because of changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit will not invalidate the test. Note 3 indicates that this Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations. Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DG start must precede this test to credit satisfactory performance.

SR 3.8.1.4 This SR provides verification that the level of fuel oil in the day tank [and engine mounted tank] is at or above the level at which fuel oil is automatically added. The level is expressed as an equivalent volume in gallons, and is selected to ensure adequate fuel oil for a minimum of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of DG operation at full load plus 10%.

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

SR 3.8.1.5 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 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 from breakdown of the fuel oil by bacteria. 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. 1110). This SR is for preventive maintenance. The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during the performance of this Surveillance.

BWOG STS B 3.8.1-17 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.6 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 corresponds to the testing requirements for pumps as contained in the ASME Code (Ref. 1312); 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. ]

SR 3.8.1.7 See SR 3.8.1.2.

[ SR 3.8.1.8 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 [18 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 [18 month] Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

BWOG STS B 3.8.1-18 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

b. Tripping its associated single largest post-accident load with the DG solely supplying the bus.

As required by IEEE-308 (Ref. 1413), the load rejection test is acceptable if the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15%

above synchronous speed, whichever is lower.

The time, voltage, and frequency tolerances specified in this SR are derived from Regulatory Guide 1.9 (Ref. 3) recommendations for response during load sequence intervals. The [3] seconds specified is equal to 60% of a typical 5 second load sequence interval associated with sequencing of the largest load. The voltage and frequency specified are consistent with the design range of the equipment powered by the DG.

SR 3.8.1.9.a corresponds to the maximum frequency excursion, while SR 3.8.1.9.b and SR 3.8.1.9.c are steady state voltage and frequency values to which the system must recover to following load rejection. The

[18 month] Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 109).

This SR is modified by two Notes. The reason for Note 1 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 MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR. Note 2 BWOG STS B 3.8.1-20 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.10 This Surveillance demonstrates the DG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits.

The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG will not trip upon loss of the load. These acceptance criteria provide DG damage protection. While the DG is not expected to experience this transient during an event and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.

The [18 month] Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 109) and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbation 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 MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

BWOG STS B 3.8.1-22 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of [0.9].

This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 2 allows the Surveillance to be conducted at a power factor other than [0.9]. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to [0.9] results in voltages on the emergency busses that are too high.

Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DC excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DC. In such cases, the power factor shall be maintained as close as practicable to

[0.9] without exceeding the DG excitation limits.

REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable,

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and

c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

SR 3.8.1.11 As required by Regulatory Guide 1.108 (Ref. 109), paragraph 2.a.(1), this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the non-essential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.

BWOG STS B 3.8.1-23 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The DG auto-start time of [10] seconds is derived from requirements of the accident analysis to respond to a design basis large break LOCA.

The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved.

The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads can not actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, high pressure injection systems are not capable of being operated at full flow, or decay heat removal (DHR) systems performing a DHR function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 109), paragraph 2.a.(1), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs 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. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial BWOG STS B 3.8.1-24 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.14 Regulatory Guide 1.108 (Ref. 109), paragraph 2.a.(3), requires demonstration once per 18 months that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,

[2] hours of which is at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

The load band is provided to avoid routine overloading of the DG.

Routine overloading may result in more frequent teardown inspections, in accordance with vendor recommendations, in order to maintain DG OPERABILITY.

The [18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 107), paragraph 2.a.(3), takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with expected fuel cycle lengths.

This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the power factor limit will not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. Note 3 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of

[0.9]. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 3 allows the Surveillance to be conducted at a power factor other than [0.9]. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to [0.9] results in voltages on the emergency busses that are too high.

Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such BWOG STS B 3.8.1-28 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) cases, the power factor shall be maintained as close as practicable to

[0.9] without exceeding the DG excitation limits. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g. post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.15 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within

[10 seconds]. The [10 second] time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA.

The [18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 109), paragraph 2.a.(5).

This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The load band is provided to avoid routine overloading of the DG. Routine overloads may result in more frequent teardown inspections, in accordance with vendor recommendations, in order to maintain DG OPERABILITY. The requirement that the diesel has operated for at least [2] hours at full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.

BWOG STS B 3.8.1-29 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.16 As required by Regulatory Guide 1.108 (Ref. 109), paragraph 2.a.(6), this Surveillance ensures that the manual synchronization and automatic load transfer from the DG to the offsite source can be made and the DG can be returned to ready to load status when offsite power is restored. It also ensures that the auto-start logic is reset to allow the DG to reload if a subsequent loss of offsite power occurs. The DG is considered to be in ready to load status when the DG is at rated speed and voltage, the output breaker is open and can receive and auto-close signal on bus undervoltage, and the load sequence timers are reset.

The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 109), paragraph 2.a.(6), and takes into consideration unit conditions required to perform the Surveillance.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

[ SR 3.8.1.17 Demonstration of the test mode override ensures that the DG availability under accident conditions will not be compromised as the result of testing and the DG will automatically reset to ready to load operation if a LOCA actuation signal is received during operation in the test mode. Ready to load operation is defined as the DG running at rated speed and voltage with the DG output breaker open. These provisions for automatic switchover are required by IEEE-308 (Ref. 1413), paragraph 6.2.6(2).

BWOG STS B 3.8.1-30 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The requirement to automatically energize the emergency loads with offsite power is essentially identical to that of SR 3.8.1.12. The intent in the requirement associated with SR 3.8.1.17.b is to show that the emergency loading was not affected by the DG operation in test mode. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the emergency loads to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The [18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 109), paragraph 2.a.(8), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR. ]

BWOG STS B 3.8.1-31 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.18 Under accident [and loss of offsite power] conditions loads are sequentially connected to the bus by the [automatic load sequencer]. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The [10]% load sequence time interval tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses.

The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 109), paragraph 2.a.(2), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

BWOG STS B 3.8.1-32 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) consistent with manufacturer recommendations for DGs. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment.

Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.20 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 1.108 (Ref. 109).

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.

BWOG STS B 3.8.1-34 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 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 [15].

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

7. Generic Letter 84-15.

8. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

98. 10 CFR 50, Appendix A, GDC 18.

109. Regulatory Guide 1.108, Rev. [1], [August 1977].

1110. Regulatory Guide 1.137, Rev. [ ], [date].

1211. ANSI C84.1-1982.

1312. ASME Code for Operation and Maintenance of Nuclear Power Plants.

1413. IEEE Standard 308-[1978].

BWOG STS B 3.8.1-35 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

C.1 Condition C represents one train with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected train. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is consistent with the allowed time for an inoperable DC distribution system train.

If one of the required DC electrical power subsystems is inoperable for reasons other than Condition A or B (e.g., inoperable battery charger and associated inoperable battery), the remaining DC electrical power subsystem has the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure could, however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

D.1 and D.2 If the inoperable DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the overall plant risk is minimizedLCO does not apply. To achieve this status, the unit 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). There are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5.

In particular, in MODE 4 the turbine driven emergency feedwater pump[s]

are available following a loss of DC sources to provide RCS cooling via the steam generators utilizing natural circulation. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state.

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 plant systems.

The Completion Time to bring the unit to MODE 5 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).

BWOG STS B 3.8.4-7 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state while supplying the continuous steady state loads of the associated DC subsystem. On float charge, battery cells will receive adequate current to optimally charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltage established by the battery manufacturer ([2.20] Vpc or [127.6] V at the battery terminals). This voltage maintains the battery plates in a condition that supports maintaining the grid life (expected to be approximately 20 years). The 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref. 98).

SR 3.8.4.2 This SR verifies the design capacity of the battery chargers. According to Regulatory Guide 1.32 (Ref. 109), the battery charger supply is recommended to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences.

The minimum required amperes and duration ensure that these requirements can be satisfied.

This SR provides two options. One option requires that each battery charger be capable of supplying [400] amps at the minimum established float voltage for [8] hours. The ampere requirements are based on the output rating of the chargers. The voltage requirements are based on the charger voltage level after a response to a loss of AC power. The time period if sufficient for the charger temperature to have stabilized and to have been maintained for at least [2] hours.

The other option requires that each battery charger be capable of recharging the battery after a service test coincident with supplying the largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur). This level of loading may not normally be available following the battery service test and will need to be supplemented with additional BWOG STS B 3.8.4-8 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current. The battery is recharged when the measured charging current is [2] amps.

The Surveillance Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance during these [18 month]

intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.

SR 3.8.4.3 A battery service test is a special test of the battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length should correspond to the design duty cycle requirements as specified in Reference 4.

The Surveillance Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.32 (Ref. 109) and Regulatory Guide 1.129 (Ref. 1110), which state that the battery service test should be performed during refueling operations, or at some other outage, with intervals between tests not to exceed [18 months].

This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test.

The reason for Note 2 is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated BWOG STS B 3.8.4-9 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned event that satisfy this SR.

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

2. Regulatory Guide 1.6, March 10, 1971.

3. IEEE-308-[1978].

4. FSAR, Chapter [8].

5. FSAR, Chapter [6].

6. FSAR, Chapter [15].

7. Regulatory Guide 1.93, December 1974.

8. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

98. IEEE-450-[1995].

109. Regulatory Guide 1.32, February 1977.

1110. Regulatory Guide 1.129, December 1974.

BWOG STS B 3.8.4-10 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Inverters - Operating B 3.8.7 BASES ACTIONS A.1 With a required inverter inoperable, its associated AC vital bus becomes inoperable until it is [manually] re-energized from its [Class 1E constant voltage source transformer or inverter using internal AC source].

For this reason, a Note has been included in Condition A requiring entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating." This ensures the vital bus is re-energized within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Required Action A.1 allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to fix the inoperable inverter and return it to service. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit is based upon engineering judgment, taking into consideration the time required to repair an inverter and the additional risk to which the unit is exposed because of the inverter inoperability. This has to be balanced against the risk of an immediate shutdown, along with the potential challenges to safety systems such a shutdown might entail. When the AC vital bus is powered from its constant voltage source, it is relying upon interruptible AC electrical power sources (offsite and onsite). The uninterruptible inverter source to the AC vital buses is the preferred source for powering instrumentation trip setpoint devices.

B.1 and B.2 If the inoperable devices or components cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the overall plant risk is minimizedLCO does not apply. To achieve this status, the unit 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). There are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5.

In particular, in MODE 4 the turbine driven emergency feedwater pump[s]

are available following a loss of vital AC sources (120 VAC instrument and control power) to provide RCS cooling via the steam generators utilizing natural circulation. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. 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 plant systems.

SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation of the BWOG STS B 3.8.7-3 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Inverters - Operating B 3.8.7 BASES REFERENCES 1. FSAR, Chapter [8].

2. FSAR, Chapter [6].

3. FSAR, Chapter [14].

4. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

BWOG STS B 3.8.7-5 Rev. 3.0, 03/31/04

TSTF-431, Rev. 1 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

Condition C represents one or more DC buses or distribution panels without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining trains and restoring power to the affected train.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that are without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable operations to continue,

b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions to restore power to the affected train, and

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

D.1 and D.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the overall plant risk is minimizedLCO does not apply. To achieve this status, the unit 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 45 within 1236 hours0.0143 days 0.343 hours 0.00204 weeks 4.70298e-4 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). There are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5.

In particular, in MODE 4 the turbine driven emergency feedwater pump[s]

are available following a loss of vital AC sources (120 VAC instrument and control power) to provide RCS cooling via the steam generators utilizing natural circulation. However, voluntary entry into MODE 5 may BWOG STS B 3.8.9-6 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 Distribution Systems - Operating B 3.8.9 be made as it is also an acceptable low-risk state. 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 plant systems.

BWOG STS B 3.8.9-7 Rev. 3.1, 12/01/05

TSTF-431, Rev. 1 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

E.1 Condition E corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost.

When more than one inoperable electrical power distribution subsystem results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.9.1 REQUIREMENTS This Surveillance verifies that the [required] AC, DC, and AC vital bus electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. The 7 day Frequency takes into account the redundant capability of the AC, DC, and AC vital bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES 1. FSAR, Chapter [6].

2. FSAR, Chapter [14].

3. Regulatory Guide 1.93, December 1974.

4. BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.

BWOG STS B 3.8.9-8 Rev. 3.1, 12/01/05

TSTF-06-26, Submittal of TSTF-431, Revision 1, Change in Technical Specifications End States (BAW-2441).

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