Text

Transmittal of Revision 17 to the Technical Specification Bases
	ML16006A049
Person / Time
Site:	Clinton
Issue date:	12/21/2015
From:	Stoner T; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	U-604257
	Download: ML16006A049 (39)
	v • d • e

~Exeton Generationo Clinton Power Station 8401 Power Road Clinton, IL 61727 U-604257 10 CFR 50.36 December 21, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Transmittal of Revision 17 to the Clinton Power Station Technical Specification Bases In accordance with Clinton Power Station (CPS) Technical Specification 5.5.11, 'T'echnical Specification (TS) Bases Control Program," Exelon Generation Company, LLC (EGC) is transmitting the revised pages constituting Revision 17 to the CPS TS Bases. The changes associated with TS 5.5.11 require updates to the TS Bases to be submitted to the NRC at a frequency consistent with 10 CFR 50.71, "Maintenance of records, making of reports,"

paragraph (e).

There are no regulatory commitments in this letter.

Should you have any questions concerning this information, please contact Mr. Dale A Shelton, Regulatory Assurance Manager, at (217) 937-2800.

Theodore R. Stoner Site Vice President Clinton Power Station J LP/cas - Revision 17 Bases Page Listing - Revision 17 Bases Pages cc:

Regional Administrator, NRC Region Ill NRC Senior Resident Inspector, Clinton Power Station L

NRC Project Manager, NRR - Clinton Power Station

U-604257 Revision 17 Bases Page Listing B 3.4-44 B 3.4-47 B 3.4-47a B 3.4-47b B 3.4-49 B 3.4-52 B 3.4-52a B 3.4-52b B 3.5-5 B 3.5-10 B 3.5-10a B 3.5-l0b B 3.5-15 B 3.5-20a B 3.5-22 B 3.5-24 B 3.5-24a B 3.5-24b B 3.6-40 B 3.6-42 B 3.6-43 B 3.6-43a B 3.6-43b B 3.6-57 B 3.6-58b B 3.6-59 B 3.7-4 B 3.7-5 B 3.9-26 B 3.9-28 B 3.9-28a B 3.9-28b B 3.9-29 B 3.9-32 B 3.9-33 B 3.9-34

U-604257 Revision 17 Bases Pages

RHR Shutdown Cooling System--Hot Shutdown B 3.4.9 BASES LCO(continued) or local) in the shutdown cooling mode for removal of decay heat.

In MODE 3, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy.

Operation of one subsystem can maintain or reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required.

Management of gas voids is important to RER Shutdown Cooling System OPERABILITY.

Note 1 permits both RHR shutdown cooling subsystems and recirculation pumps to be shut down for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

Note 2 allows one RER shutdown cooling subsystem to be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of surveillance tests.

These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR System in an inoperable status during the performance.

This is permitted because the core heat'generation can be low enough and the heatup rate slow enough to allow some changes to the RER subsystems or other operations requiring RHR flow interruption and loss of redundancy.

APPLICABILITY In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RER cut in permissive pressure, this LCO is not applicable.

Operation of the RHR System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the shutdown cooling piping.

Decay heat removal at reactor pressures greater than or equal to the RHR cut in permissive pressure is typically accomplished by condensing the steam in the main condenser.

Additionally, in MODE 2 below this pressure, the OPERABILITY requirements for the Emergency Core Cooling Systems (ECCS)

(LCD 3.5.1, "ECCS--

Operating't )

do not allow placing the RHR shutdown cooling subsystem into operation.

In MODE 3 with reactor steam dome pressure below the RER cut in permissive pressure (i.e.,

the actual pressure at which the interlock resets) the RBR System may be operated in the shutdown cooling mode to remove decay heat to reduce or maintain coolant temperature.

Otherwise, a recirculation pump is required to be in operation.

(continued)

CLINTON B 3.4-44 CLINON 3.-44Revision No.

17-1

RHR Shutdown Cooling System--Hot Shutdown B 3.4.9 BASES ACTIONS B.l, B.2, and B.3 (continued)

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR shutdown cooling subsystem or recirculation pump),

the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method.

The once per hour Completion Time is deemed appropriate.

SURVEILLANCE SR 3.4.9.1 REQUIREMENTS This Surveillance verifies that one RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant.

The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability.

The Surveillance Frequency is controlled under the S~rveillance Frequency Control Program.!

This Surveillance is modified by a Note allowing sufficient time to align the RHR System for shutdown cooling operation after clearing the pressure interlock that isolates the system, or for placing a recirculation pump in operation.

The Note takes exception to the requirements of the Surveillance being met (i.e., forced coolant circulation is not required for this initial 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months period),

which also allows entry into the Applicability of this Specification in accordance with SR 3.0.4 since the Surveillance will not be "not met" at the time of entry into the Applicability.

SR 3.4.9.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases.

Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RER shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations.

The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove (continued)

CLINTON B 3.4-47 CLINTN B 34-47Revision No.

17-1

RHR Shutdown Cooling System--Hot Shutdown B 3.4.9 BASES SURVEILLANCE SR 3.4.9.2 (continued)

REQUIREMENTS during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump),

the Surveillance is not met.

If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e.,

the system is sufficiently filled with water),

the Surveillance may be declared met.

Accumulatedlgas should be eliminated or brought within theI acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety.

For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

This SR is modified by a Note that states the SR is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is less than the RHR cut in permissive pressure.

In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering the Applicability.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

(continued)

CLINTON B 3.4-47a CLINON 3.447aRevision No.* 17-1

RI-R Shutdown Cooling System--Hot Shutdown B 3.4.9 BASES (continued)

REFERENCES

1.

USAR, Section 5.4.7.

CLINTON B 3.4-47b CLINON 3.447bRevision No.

17-1

ERHR Shutdown Cooling System--Cold Shutdown B 3.4.10 BASES LCO(continued) local) in the shutdown cooling mode for removal of decay heat.

In MODE 4, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy.

Operation of one subsystem can maintain and reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required.

Management of gas voids is important to ERR Shutdown Cooling System OPERABILITY.

Note 1 permits both ERHR shutdown cooling subsystems and recirculation pumps to be shut down for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

Note 2 allows one RER shutdown cooling subsystem to be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of surveillance tests.

These tests may be on the affected ERHR System or on some other plant system or component that necessitates placing the ERR System in an inoperable status during t~e performance.

This is permitted because the core heat gen ration can be low enough and the heatup rate slow enough to allow some changes to the ERHR subsystems or other operations requiring EHR flow interruption and loss of redundancy.

Note 3 permits both ERR shutdown cooling subsystems and recirculation pumps to be shut down during performance of inservice leak testing and during hydrostatic testing.

This is permitted because RCS pressures and temperatures are being closely monitored during this testing as required by LCD 3.4.11, "ECS Pressure and Temperature (P/T)

Limits."

APPLICABILITY In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the ERR cut in permissive pressure, this LCD is not applicable.

Operation of the ERR System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the shutdown cooling piping.

Decay heat removal at reactor pressures greater than or equal to the ERR cut in permissive pressure is typically accomplished by condensing the steam in the main condenser.

Additionally, in MODE 2 below this pressure, the OPERABILITY requirements for the Emergency Core Cooling Systems (ECCS)

(LCD 3.5.1, "ECCS--

Operating")

do not allow placing the ERR shutdown cooling subsystem into operation.

(continued)

CLINTON B 3.4-49 CLINON 3.-49Revision No.

17-1

RHR Shutdown Cooling System--Cold Shutdown B 3.4.10 BASES SURVEILLANCE SR 3.4.10.1 (continued)

REQUIREMENTS decay heat removal capability.

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

SR 3.4.10.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases.

Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHE shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations.

The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump),

the Surveillance is not met.

If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e.,

the system is sufficiently filled with water),

the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or (continued)

CLINTON B 3.4-52 CLINON 3.-52Revision No.

17-1

RHR Shutdown Cooling System--Cold Shutdown B 3.4.10 BASES SURVEILLANCE SR 3.4.10.2 (continued)

REQUIREMENTS personnel safety.

For these locations alternative methods (e.g., operating parameters, remote monitoring) may he used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracy of the method used for monitoring the susceptible locations and trending of the results should he sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary hy location susceptible to gas accumulation.

REFEREkJCES

1.

USAR, Section 5.4.7.

CLINTON B 3.4-52a CLINON 3.452aRevision No.

17-1

This page intentionally left blank.

CLINTON B 3.4-52b CLINON 3.452bRevision No.

17-1

EOCS---Operating B 3.5.1 BASES (continued)

LCO Each ECCS injection/spray subsystem and seven ADS valves are required to be OPERABLE.

The BOOS injection/spray subsystems are the three LPCI subsystems, the LPCS System, and the HPOS System.

The BOOS injection/spray subsystems are further subdivided into the following groups:

a)

The low pressure BOOS injection/spray subsystems are the LPOS System and the three LPOI subsystems; b)

The BOOS injection subsystems are the three LPCI subsystems; and c)

The EOOS spray subsystems are the HPOS System and the LPOS System.

Management of gas voids is important to EOCS injection/spray subsystem OPERABILITY.

With less than the required number of BOOS subsystems OPERABLE during a limiting design basis LOOA concurrent with the worst case single failure, the limits specified in 10 OFR 50.46 (Ref.

10) could potentially be exceeded.

All BOOS subsystems must therefore be OPERABLE to satisfy the single failure criterion required by 10 OFR 50.46 (Ref.

10).

IPCI subsystems may be considered OPERABLE during alignment and operation for decay heat removal when below the actual RHR cut in permissive pressure in MODE 3, if capable of being manually realigned (remote or local) to the LPOI mode and not otherwise inoperable.

At these low pressures and decay heat levels, a reduced complement of BOOS subsystems should provide the required core cooling, thereby allowing operation of RER shutdown cooling when necessary.

APPLICABILITY All BOOS subsystems are required to be OPERABLE during MODES I, 2,

and 3 when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping.

In MODES 2 and 3, the ADS function is not required when pressure is

150 psig because the low pressure EOOS subsystems (LPOS and LPOI) are capable of providing flow into the RPV below this pressure.

BOOS requirements for MODES 4 and 5 are specified in LCOG 3.5.2, "lECCS--Shutdown."

(continued)

CLINTON B 3.5-5 OLITONB 35-5Revision No.

17-1

ECCS -O4perating B 3.5.1 BASES (continued)

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS The ECCS injection/spray subsystem flow path piping and components have the potential to develop voids and pockets of entrained gases.

Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS injection/spray subsystems and may also prevent a water

hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of ECCS injection/spray subsystem locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations.

The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The ECCS injection/spray subsystem is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump),

the Surveillance is not met.

If it is determined by subsequent evaluation that the ECCS injection/spray subsystems are not rendered inoperable by the accumulated gas (i.e.,

the system is sufficiently filled with water),

the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS injection/spray subsystem locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety.

For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum (continued)

CLINTON B 3.5-10 CLINON 3.-10Revision No.

17-1

ECCS -O4perating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.1 (continued)

REQUIREMENTS potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

SR 3.5.1.2 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing.

A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves potentially capable of being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

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

This SR is modified by two Notes.

Note 1 allows LPCI subsystems to be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the RHR cut in permissive pressure in MODE 3, if capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable.

This allows operation in the RHR shutdown cooling mode during MODE 3 if necessary.

Note 2 exempts system vent flow paths opened under administrative control.

The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room.

This individual will have a method to rapidly close the system vent flow path if directed.

(continued)

CLINTON B 3.5-i0a CLINON 3.5l~aRevision No.

17-1

ECCS -- Operating B 3.5.1 This page intentionally left blank.

CLINTON B 3.5-10b CLINON 3.5lobRevision No.

17-1

ECCS -- Shutdown B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

AND REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM B 3.5.2 ECCS--Shutdown BASES BACKGROUND A description of the High Pressure Core Spray (HPCS)

System, Low Pressure Core Spray (LPCS)

System, and low pressure coolant injection (LPCI) mode of the Residual Heat Removal (RHR)

System is provided in the Bases for LCD 3.5.1, "ECCS--Operating."

APPLICABLE ECCS performance is evaluated for the entire spectrum of SAFETY ANALYSES break sizes for a postulated loss of coolant accident (LOCA)

The long term cooling analysis following a design basis LOCA (Ref.

1) demonstrates that only one ECCS injection/spray subsystem is required, post LOCA, to maintain the peak cladding temperature below the allowable limit.

It is reasonable to assume, based on engineering judgement, that while in MODES 4 and 5, one ECCS injection/spray subsystem can maintain adequate reactor vessel water level.

To provide redundancy, a minimum of two ECCS subsystems are required to be OPERABLE in MODES 4 and 5.

The ECCS satisfy Criterion 3 of the NRC Policy Statement.

LCO Two ECCS injection/spray subsystems are required to be OPERABLE.

The ECCS injection/spray subsystems are defined as the three LPCI subsystems, the LPCS System, and the HPCS System.

The LPCS System and each LPCI subsystem consist of one motor driven pump,

piping, and valves to transfer water from the suppression pool to the reactor pressure vessel (RPV)

The HPCS System consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or RCIC storage tank to the RPV.

Management of gas voids is important to ECCS injection/spray subsystem OPERABILITY.

One LPCI subsystem (A or B) may be aligned for decay heat removal in MODE 4 or 5 and considered OPERABLE for the ECCS

function, if it can be manually realigned (remote or local) to the LPCI mode and is not otherwise inoperable.

Because of low pressure and low temperature conditions in MODES 4 (continued)

CLINTON B 3.5-15 CLINON 3.-15Revision No.

17-1

ECCS -- Shutdown B 3.5.2 BASES SURVEILLANCE SR 3.5.2.4 (continued)

REQUIREMENTS in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveiliance Frequency Controi Program.

In MODES 4 and 5, the RHR System may operate in the shutdown cooiing mode to remove decay heat and sensibie heat from the reactor.

Therefore, RHR valves that are required for LPCI subsystem operation may be aligned for decay heat removal.

This SR is modified by two Notes.

Note 1 allows one LPCI subsystem of the RHR System to be considered OPERABLE for the ECCS function if all the required valves in the LPCI flow path can be manually realigned (remote or local) to allow injection into the RPV and the system is not otherwise inoperable.

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

Note 2 exempts system vent flow paths opened under adm~inistrative control.

The administrative control should be pr~oceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room.

This individual will have a method to rapidly close the system vent flow path if directed.

REFERENCES

1.

USAR, Section 6.3.3.

2.

Calculation IP-0-0049.

3.

Calculations 01HP09/10/II and IP-C-0042.

4.

Calculations 01LP08/II/14 and IP-C-0043.

5.

Calculations 01RH19/20/22/26 and IP-C-0041.

CLINTON B 3.5-20a CLINON 3.520aRevision No.

17-1

RCIC System B 3.5.3 BASES BACKGROUND The RCIC pump is provided with a minimum flow bypass line, (continued) which discharges to the suppression pool.

The valve in this line automatically opens to prevent pump damage due to overheating when other discharge line valves are closed.

To ensure rapid delivery of water to the RPV and to minimize water hammer effects, the RCIC System discharge line "keep fill" system is designed to maintain the pump discharge line filled with water.

APPLICABLE The function of the RCIC System is to respond to transient SAFETY ANALYSES events by providing makeup coolant to the reactor.

The RCIC System is not an Engineered Safety Feature and no credit is taken in the safety analysis for RCIC System operation.

The RCIC System satisfies Criterion 4 of the NRC Policy Statement.

LCO The OPERABILITY of the RCIC System provides adequate core cooling such 4hat actuation of any of the ECCS subsystems is~

not required in the event of RPV isolation accompanied by a loss of feedwater flow.

The RCIC System has sufficient capacity to maintain RPV inventory during an isolation event.

Management of gas voids is important to RCIC System OPERABILITY.

APPLICABILITY The RCIC System is required to be OPERABLE in MODE 1, and MODES 2 and 3 with reactor steam dome pressure > 150 psig since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized.

In MODES 2 and 3 with reactor steam dome pressure

150 psig, and in MODES 4 and 5, RCIC is not required to be OPERABLE since the ECCS injection/spray subsystems can provide sufficient flow to the vessel.

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC system.

There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

(continued)

CLINTON B 3.5-22 CLINON 3.-22Revision No.

17-1

ROTC System B 3.5.3 BASES (continued)

SURVEILLANCE SR 3.5.3.1 REQUIREMENTS The RCTC System flow path piping and components have the potential to develop voids and pockets of entrained gases.

Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ROTC System and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RCIC System locations susceptible to gas accumulation is based on a self-assessment of the piping configuration to identify where gases may accumulate and remain even after the system is filled and vented, and to identify vulnerable potential degassing flow paths.

The review is supplemented by verification that installed high-point vents are actually at the system high points, including field verification to ensure pipe shapes and construction tolerances have not inadvertently created additional high points.

Susceptible locations depend on plant and system configuratilon, such as stand-by versus operating conditions.

The ROIC System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump),

the Surveillance is not met.

If it is determined by subsequent evaluation that the ROIC Systems are not rendered inoperable by the accumulated gas (i.e.,

the system is sufficiently filled with water),

the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ROTC System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety.

For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximhum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance

interval.

(continued)

CLINTON B 3.5-24 CLINON 3.-24Revision No.

17-1

ROIC System B 3.5.3 BASES SURVEILLANCE SR 3.5.3.1 (continued)

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

SR 3.5.3.2 Verifying the correct alignment for manual, power operated, and automatic valves in the RCIC flow path provides assurance that the proper flow path will exist for RCIC 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.

A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

For the RCIC System, this SR also includes the steam flow path for the turbine and the flow controller position.

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

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control.

The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room.

This individual will have a method to rapidly close the system vent flow path if directed.

(continued)

CLINTON B 3.5-24a CLINON 3.524aRevision No.

17-1

RCIC System B 3.5.3 This page intentionally left blank.

CLINTON B 3.5-24b CLINON 3.524bRevision No.

17-1

RHR Containment Spray System B 3.6.1.7 BASES APPLICABLE The analysis demonstrates that with containment spray SAFETY ANALYSES operation the containment pressure remains within design (continued) limits.

The RHR Containment Spray System satisfies Criterion 3 of the NRC Policy Statement.

LCO In the event of a Design Basis Accident (DBA),

a minimum of one RHR containment spray subsystem is required to mitigate potential bypass leakage paths and maintain the primary containment peak pressure below design limits.

To ensure that these requirements are met, two RER containment spray subsystems must be OPERABLE.

Therefore, in the event of an

accident, at least one subsystem is OPERABLE assuming the worst case single active failure.

An RHR containment spray subsystem is OPERABLE when the pump, the heat exchanger, and associated piping, valves, instrumentation, and controls are OPERABLE.

Management of gas voids is important to RHR Containment Spray System OPERABILITY.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause pressurization of primary containment.

In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES.

Therefore, maintaining RER containment spray subsystems OPERABLE is not required in MODE 4 or 5.

ACTIONS A.I With one RHR containment spray subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days.

In this Condition, the remaining OPERABLE RER containment spray subsystem is adequate to perform the primary containment cooling function.

Eowever, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment cooling capability.

The 7 day Completion Time was chosen in light of the redundant RHR containment capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

(continued)

CLINTON B 3.6-40 CLINON 3.-40Revision No.

17-1

RHR Containment Spray System B 3.6.1.7 BASES (continued)

SURVEILLANCE SR 3.6.1.7.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR containment spray mode flow path provides assurance that the proper flow paths will exist for system operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these were verified to he 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 heing mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

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

Two Notes have been added to this SR.

The first Note allows RHR containment spray subsystems to he considered OPERABLE during alignment to and operation in t

e RHR shutdown cooling mode when below the RHR cut in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

At these low pressures and decay heat levels (the reactor is shut down in MODE 3),

a reduced complement of suhsystems should provide the required containment pressure mitigation function thereby allowing operation of an RHR shutdown cooling ioop when necessary.

The second Note exempts system vent flow paths opened under administrative control.

The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room.

This individual will have a method to rapidly close the system vent flow path if directed.

SR 3.6.1.7.2 Verifying each RHR pump develops a flow rate Ž 3800 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that pump performance has not degraded below the required flow rate during the cycle.

It is tested in the pool cooling mode to demonstrate pump OPERABILITY without spraying down equipment in primary containment.

Although this SR is satisfied by running the pump in the suppression pool cooling mode, the test procedures that satisfy this SR include appropriate acceptance criteria to account for the higher pressure requirements resulting from aligning the RER System in the containment spray mode.

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

(continued)

CLINTON B 3.6-42 CLINON 3.-42Revision No.

17-1

RHR Containment Spray System B 3.6.1.7 BASES SURVEILLANCE SR 3.6.1.7.3 REQUIREMENTS (continued)

This SR verifies that each RHR containment spray subsystem automatic valve actuates to its correct position upon receipt of an actual or simulated automatic actuation signal.

Actual spray initiation is not required to meet this SR.

The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.3.5 overlaps this SR to provide complete testing of the safety function.

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

SR 3.6.1.7.4 This Surveillance is performed following activities that could result in nozzle blockage to verify that the spray nozzles are not obstructed and that flow will be provided when required.

Such activities may include loss of foreign material control (of if it cannot be assured),

following a major configuration change, or following an inadvertent actuation of containment spray.

This Surveillance is normally performed by an air or smoke flow test.

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

SR 3.6.1.7.5 RER Containment Spray System piping and components have the potential to develop voids and pockets of entrained gases.

Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RI-R containment spray subsystems and may also prevent water hammer and pump cavitation.

Selection of RER Containment Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations.

The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RER Containment Spray System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume (continued)

CLINTON B 3.6-43 Revision No.

17-1

RHR Containment Spray System B 3.6.1.7 BASES SURVEILLANCE SR 3.6.1.7.5 (continued)

REQUIREMENTS at the suction or discharge of a pump),

the Surveillance is not met.

If it is determined by subsequent evaluation that the ERR Containment Spray System is not rendered inoperable by the accumulated gas (i.e.,

the system is sufficiently filled with water),

the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Containment Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or lenvironmental conditions, the plant configuratpon, or personnel safety.

For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES

1.

USAR, Section 6.2.1.1.5.

2.

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

3.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

4.

USAR, Section 5.4.7 CLINTON B 3.6-43a CLINON 3.643aRevision No.

17-1

This page intentionally left blank.

CLINTONB36-b B 3.6-43b Revision No.

17-1

RER Suppression Pool Cooling B 3.6.2.3 BASES APPLICABLE SAFETY ANALYSES (continued)

The RER Suppression Pool Cooling System satisfies Criterion 3 of the NRC Policy Statement.

LCO During a DBA, a minimum of one RHR suppression pool cooling subsystem is required to maintain the primary containment peak pressure and temperature below the design limits (Ref.

1).

To ensure that these requirements are met, two RER suppression pool cooling subsystems must be OPERABLE.

Therefore, in the event of an accident, at least one subsystem is

OPERABLE, assuming the worst case single active failure.

An RHR suppression pool cooling subsystem is OPERABLE when the pump, heat exchanger, and associated piping, valves, instrumentation, and controls are OPERABLE.

Management of gas voids is important to RHR Suppression Pool Cooling System OPERABILITY.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of 1

radioactive material to primary c ntainment and cause a heatup and pressurization of primary containment.

In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES.

Therefore, the RER Suppression Pool Cooling System is not required to be OPERABLE in MODE 4 or 5.

ACTIONS A.I With one RER suppression pool cooling subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days.

In this Condition, the remaining RHR suppression pool cooling subsystem is adequate to perform the primary containment cooling function.

However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment cooling capability.

The 7 day Completion Time is acceptable in light of the redundant RBR suppression pool cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

(continued)

CLINTON B 3.6-57 CLINTN B 36-57Revision No.

17-1

RHR Suppression Pool Cooling B 3.6.2.3 BASES SURVEILLANCE SR 3.6.2.3.2 REQUIREMENTS (continued)

Verifying each RHR pump develops a flow rate Ž 4550 gpm, with flow through the associated heat exchanger to the suppression pool, ensures that pump performance has not degraded during the cycle.

Flow is a normal test of centrifugal pump performance required by ASME (Ref.

3).

This test confirms one point on the pump design curve, and the results are indicative of overall performance.

Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance.

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

With regard to RHR pump flow rate values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value with respect to instrument uncertainties.

This requires additional margin to be added to the limit to compensate for instrument uncertainties for implementation in the associated plant procedures.

(Ref.

5)"

SR 3.6.2.3.3 RBR Suppression Pool Cooling System piping and components have the potential to develop voids and pockets of entrained gases.

Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RER suppression pooi cooling subsystems and may also prevent water hammer and pump cavitation.

Selection of RBR Suppression Pool Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations.

The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Suppression Pool Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump),

the Surveillance is not met.

If it is determined by subsequent evaluation that the RHR Suppression Pool Cooling System is not rendered inoperableby the accumulated gas (i.e.,

the system is sufficiently filled with water),

the Surveillance may ho (continued)

CLINTON B 3.6-58b CLINON 3.658bRevision No.

17-1

RHR Suppression Pool Cooling B 3.6.2.3 BASE S SURVEILLANCE SR 3.6.2.3.3 (continued)

REQU IREMENT S declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Suppression Pool Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety.

For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracy of the meth d used for monitoring the susceptible locations and trendi Ag of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES

1.

USAR, Section 6.2.

2.

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

3.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

4.

USAR, Section 5.4.7.

5.

Calculations OlRH2O/22/25 and IP-C-0041.

CLINTON B 3.6-59 CLINTN B 36-59Revision No.

17-1

Division 1 and 2 SX Subsystems and UHS B 3.7.1 BABES (continued)

ACTIONS A.l If the UHS is inoperable (i.e.,

the UHS water volume is not within the limit), action must be taken to restore the inoperable UHS to OPERABLE status within 90 days.

The 90 day Completion Time is reasonable considering the time required to restore the required UH-S volume, the margin contained in the available heat removal capacity, and the low probability of a DBA occurring during this period.

B.l If the Division 1 or 2 SX subsystem is inoperable, it must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

With the unit in this condition, the remaining OPERABLE Division 1 or 2 SX subsystem is adequate to perform the heat removal function.

However, the overall reliability is reduced because a single failure in the OPERABLE Division 1 or 2 SX subsystem could result in loss of the SX function.

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 capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

Condition B is modified by a Note.

The Note indicates that this Condition is not applicable during replacement of the Division 2 SX pump during the Division 2 SX system outage window from October 26 through November 8,

2015.

The Required Action is modified by two Notes indicating that the applicable Conditions of LCO 3.8.1, "AC Sources--

Operating," and LCO 3.4.9, "Residual Heat Removal (RHR)

Shutdown Cooling System--Hot Shutdown," be entered and the Required Actions taken if the inoperable SX subsystem results in an inoperable DG or RER shutdown cooling subsystem, respectively.

This is in accordance with LCO 3.0.6 and ensures the proper actions are taken for these components.

C.I During replacement of the Division 2 SX pump in the Division 2 SX system outage window from October 26 through November 8,

2015, the Division 2 SX subsystem is inoperable, and it must be restored to OPERABLE status within 7 days.

This Completion Time is based upon a risk-informed assessment that concluded that the associated risk with the system in the specified configuration is acceptable.

Condition C is modified by a Note.

The Note indicates that this Condition is only applicable during replacement of the (continued)

CLINTON B 3.7-4 CLITONB 37-4Revision No.

17-2

Division 1 and 2 SX Subsystems and UHS B 3.7.1 BA-S BS ACTIONS C.I (continued)

Division 2 SX pump during the Division 2 system outage window from October 26 through November 8, 2015.

Required Action 0.1 is modified by two Notes as described in Action B.l above.

D.I If the Required Action and associated Completion Time of Condition B or C is not met, the plant must be brought to a condition in which the overall plant risk is minimized.

To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref.

8) and because the time spent in MODE 3 to perform the necessary rep airs to restore the system to OPERABLE status will be shoi~t.

However, voluntary entry into MODE 4 may b* made as it is also an acceptable low-risk state.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Required Action D.I is modified by a Note that prohibits the application of LCO 3.0.4.a.

This Note clarifies the intent of the Required Action by indicating that it is not permissible under LCO 3.0.4.a to enter MODE 3 from MODE 4 with the LCD not met.

While remaining in MODE 3 presents an acceptable level of risk, it is not the intent of the Required Action to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordance with LCD 3.C.4.a.

However, where allowed, a risk assessment may be performed in accordance with LCD 3.0.4.b.

Consideration of the results of this risk assessment is required to determine the acceptability of entering MODE 3 from MODE 4 when this LCD is not met.

E.l and E.2 If the Required Action and associated Completion Time of Condition A or B are not met, or both Division 1 and 2 SX subsystems are inoperable, the unit must be placed in a MODE in which the LCD does not apply.

To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

(continued)

CLINTON B 3.7-5 CLITONB 37-5Revision No.

17-2

RHR--High Water Level B 3.9.8 BASES LCO(continued)

An OPERABLE RER shutdown cooling subsystem consists of an RHR pump, a heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path.

Management of gas voids is important to RHR Shutdown Cooling System OPERABILITY.

Additionally, each RHR shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat.

Operation (either continuous or intermittent) of one subsystem can maintain and reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required.

A Note is provided to allow a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months exception to shut down the operating subsystem every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

APPLICABILITY One RHR shutdown cooling subsystem must be OPERABLE in MODE 5, with irradiated fiel in the RPV and the water level

>22 ft 8 inches above the top of the RPV flange, to provide decay heat removal.

RHR System requirements in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS); Section 3.5, Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling (RCIC)

System; and Section 3.6, Containment Systems.

RHR Shutdown Cooling System requirements in MODE 5,

with the water level < 22 ft 8 inches above the RPV flange, are given in LCO 3.9.9, "Residual Heat Removal (RHR)--Low Water Level."

ACTIONS A.I1 With no RER shutdown cooling subsystem OPERABLE, an alternate method of decay heat removal must be established within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

In this condition, the volume of water above the RPV flange provides adequate capability to remove decay heat from the reactor core.

However, the overall reliability is reduced because loss of water level could result in reduced decay heat removal capability.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities.

Furthermore, verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

This will ensure continued heat removal capability.

(continued)

CLINTON B 3.9-26 CLINTN B 39-26Revision No.

17-1

RHR--High Water Level B 3.9.8 BASES ACTIONS 5.I, 5.2, B.3, B.4, and B.5 (continued) would not be expected to result in the immediate release of appreciable fission products to the containment atmosphere.

Actions must continue until all requirements of this Condition are satisfied.

C.l and C.2 If no RHR shutdown cooling subsystem is in operation, an alternate method of coolant circulation is required to be established within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The Completion Time is modified such that 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation.

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RER shutdown cooling subsystem),

the reactor

oolant temperature must be periodically monitcored to ensure proper functioning of the alternate method.

The once per hour Completion Time is deemed appropriate.

SURVEILLANCE SR 3.9.8.1 REQUIREMENTS This Surveillance demonstrates that the RHR shutdown cooling subsystem is in operation and circulating reactor coolant.

The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability.

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

SR 3.9.8.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases.

Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RER shutdown cooling subsystem(s) and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RBR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations.

The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove (continued)

CLINTON B 3.9-28 CLINON 3.-28Revision No.

17-1

RER--High Water Level B 3.9.8 BASES SURVEILLANCE SR 3.9.8.2 (continued)

REQUIREMENTS during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump),

the Surveillance is not met.

If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e.,

the system is sufficiently filled with water),

the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acetnecriteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety.

For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES

1.

USAR, Section 5.4.7.

CLINTON B 3.9-28a CLINON 3.928aRevision No.

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This page intentionally left blank.

CLINTON CLINTONB 3.9-28b Revision No.

17-1

RHR--Low Water Level B 3.9.9 B 3.9 REFUELING OPERATIONS B 3.9.9 Residual Heat Removal (RER)--Low Water Level BASES BACKGROUND The purpose of the RHR System in MODE 5 is to remove decay heat and sensible heat from the reactor coolant, as required by GDC 34.

Each of the two shutdown cooling loops of the RER System can provide the required decay beat removal.

However, the shutdown cooling loops are single failure proof per GOC 34 only with Alternate Shutdown Cooling.

Each loop consists of one motor driven pump, a heat exchanger, and associated piping and valves.

Both loops have a common suction from the same recirculation loop.

Each pump discharges the reactor coolant, after it has been cooled by circulation through the respective heat exchanger, to the reactor via separate feedwater lines, to the upper containment pooi via a common single flow distribution sparger, or to the reactor via the low pressure coolant injection path.

The RHR heat exchangers transfer hent to the Shutdown Service Water System.

The RHR shutdown cooling mode is manually controlled.

APPLICABLE With the unit in MODE 5,

the RHR shutdown cooling subsystem SAFETY ANALYSES is not required to mitigate any events or accidents evaluated in the safety analyses.

The RUE System is required for removing decay heat to maintain the temperature of the reactor coolant.

Although the RER shutdown cooling subsystem does not meet a specific criterion of the NRC Policy Statement, it was identified in the NRC Policy Statement as an important contributor to risk reduction.

Therefore, the RHE shutdown cooling subsystem, with its common suction from reactor recirculation, is retained as a Specification.

LCO Tn MODE 5 with irradiated fuel in the reactor pressure vessel (RPV) and with the water level < 22 ft 8 inches above the RPV flange both RUR shutdown cooling subsystems must be OPERABLE.

An OPERABLE RER shutdown cooling subsystem consists of an RHE pump, a heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path.

Management of gas voids is important to RUE Shutdown Cooling System OPERABILITY.

(continued)

CLINTON B 3.9-29 CLINON 3.-29Revision No.

17-1

RHR--Low Water Level B 3.9.9 BASES ACTIONS B.l, B.2, B.3, and B.4 (continued) required component is inoperable, then it must be restored to OPERABLE status.

In this case, the Surveillances may need to be performed to restore the component to OPERABLE status.

In addition, at least one door in the upper containment personnel air lock must be closed.

The closed air lock door completes the boundary for control of potential radioactive releases.

With the appropriate administrative controls however, the closed door can he opened intermittently for entry and exit.

This allowance is acceptable due to the need for containment access and due to the slow progression of events which may result from inadequate decay heat removal.

Loss of decay heat removal would not be expected to result in the immediate release of appreciable fission products to the containment atmosphere.

Actions must continue until all requirements of this Condition are satisfied.

C.I and C.2 If no RHR shutdown cooling subsystem is in operation, an alternate method of coolant circulation is required to be established within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The Completion Time is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation.

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR Shutdown Cooling System),

the reactor coolant temperature must be periodically monitored to ensure proper function of the alternate method.

The once per hour Completion Time is deemed appropriate.

SURVEILLANCE SR 3.9.9.1 REQUIREMENTS This Surveillance demonstrates that one RHR shutdown cooling subsystem is in operation and circulating reactor coolant.

The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability.

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

SR 3.9.9.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases.

Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling (continued)

CLINTON B 3.9-32 CLINON 3.-32Revision No.

17-1

RHR--Low Water Level B 3.9.9 BASES SURVEILLANCE SR 3.9.9.2 (continued)

REQUIREMENTS subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations.

The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

T~e RHR Shutdown Cooling System is OPERABLE wher* it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump),

the Surveillance is not met.

If it is determined by subsequent evaluation that the RER Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e.,

the system is sufficiently filled with water),

the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety.

For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

(continued)

CLINTON B 3.9-33 CLINON 3.-33Revision No.

17-1

RHR--Low Water Level B 3.9.9 BASES SURVEILLANCE SR 3.9.9.2 (continued)

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES

1.

USAR, Section 5.4.7.

CLINTON B 3.9-34 CLINON 3.-34Revision No.