View source for CNRO-2022-00015, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling Using the Consolidated Line-Item Improvement Process

{{Adams
| number = ML22146A189
| issue date = 05/26/2022
| title = Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling Using the Consolidated Line-Item Improvement Process
| author name = Couture P
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000416, 05000458
| license number = NPF-029, NPF-047
| contact person = 
| case reference number = CNRO-2022-00015
| document type = Letter type:CNRO, Technical Specification, Amendment
| page count = 35
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Phil Couture Senior Manager Fleet Regulatory Assurance - Licensing 601-368-5102 CNRO-2022-00015                                                                          10 CFR 50.90 May 26, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

==Subject:==
Application to Revise Technical Specifications to Adopt TSTF-580, "Provide Exception From Entering MODE 4 With No Operable RHR Shutdown Cooling" using the Consolidated Line-Item Improvement Process Grand Gulf Nuclear Station, Unit 1 NRC Docket Nos. 50-416 Renewed Facility Operating License No. NPF-29 River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for Grand Gulf Nuclear Station, Unit 1 (GGNS) and River Bend Station, Unit 1 (RBS).
Entergy requests adoption of TSTF-580, "Provide Exception from Entering MODE 4 With No Operable RHR Shutdown Cooling." The proposed change provides a TS exception to entering Mode 4 if both Residual Heat Removal (RHR) shutdown cooling subsystems are inoperable.
The enclosure provides a description and assessment of the proposed changes. Attachments 1.a. and 1.b. provide the existing TS pages marked up to show the proposed changes.
Attachments 2.a. and 2.b. provide revised (clean) TS pages. Attachments 3.a. and 3.b. provide existing TS Bases pages marked to show revised text associated with the proposed changes and is provided for information only.
Entergy requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within six months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 90 days.
There are no regulatory commitments made in this submittal.
Entergy Operations, Inc., 1340 Echelon Parkway, Jackson, MS 39213

CNRO-2022-00015 Page 2 of 3 Should you have any questions or require additional information, please contact please contact Phil Couture, Sr. Manager, Fleet Regulatory Assurance, at 601-368-5102.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), a copy of this application, with attachments, is being provided to the designated Mississippi and Louisiana State Officials.
I declare under penalty of perjury; the foregoing is true and correct.
Executed on May 26, 2022.
Respectfully, Philip              Digitally signed by Philip Couture Couture             Date: 2022.05.26 10:02:53 -05'00' Phil Couture PC/jac

==Enclosure:==
Description and Assessment of the Proposed Change Attachments to 

==Enclosure:==

1.a. Technical Specification Page Markups, Grand Gulf Nuclear Station, Unit 1 1.b. Technical Specification Page Markups, River Bend Station, Unit 1 2.a. Retyped Technical Specification Pages, Grand Gulf Nuclear Station, Unit 1 2.b. Retyped Technical Specification Pages, River Bend Station, Unit 1 3.a. Markup of Technical Specification Bases Pages (For Information Only),
Grand Gulf Nuclear Station, Unit 1 3.b. Markup of Technical Specification Bases Pages (For Information Only),
River Bend Station, Unit 1

CNRO-2022-00015 Page 3 of 3 cc:   NRC Region IV Regional Administrator NRC Senior Resident Inspector - GGNS NRC Senior Resident Inspector - RBS NRC Project Manager - GGNS NRC Project Manager - RBS State Health Officer, Mississippi Department of Health Louisiana Department of Environmental Quality

Enclosure CNRO-2022-00015 Description and Assessment of the Proposed Change

CNRO-2022-00015 Enclosure Page 1 of 5 TABLE OF CONTENTS 1.0     

==SUMMARY==
DESCRIPTION ........................................................................................... 2 2.0     ASSESSMENT ............................................................................................................... 2 2.1   Applicability of Safety Evaluation .................................................................................... 2 2.2   Variations ........................................................................................................................ 2

==3.0     REGULATORY ANALYSIS==
 ............................................................................................ 2 3.1   No Significant Hazards Consideration Analysis.............................................................. 2 3.2   Conclusions .................................................................................................................... 4

==4.0     ENVIRONMENTAL CONSIDERATION==
 ......................................................................... 4

==5.0     REFERENCES==
 ............................................................................................................... 4 6.0     ATTACHMENTS ............................................................................................................ 4

CNRO-2022-00015 Enclosure Page 2 of 5 DESCRIPTION AND ASSESSMENT OF THE PROPOSED CHANGE 1.0      

==SUMMARY==
DESCRIPTION Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for Grand Gulf Nuclear Station, Unit 1 (GGNS) and River Bend Station, Unit 1 (RBS), for adoption of TSTF-580, "Provide Exception from Entering MODE 4 With No Operable RHR Shutdown Cooling." The proposed change provides a Technical Specifications (TS) exception to entering Mode 4 if both required Residual Heat Removal (RHR) shutdown cooling subsystems are inoperable.
2.0      ASSESSMENT 2.1      Applicability of Safety Evaluation Entergy has reviewed the U.S. Nuclear Regulatory Commission (NRC) safety evaluation (SE) for TSTF-580 provided to the Technical Specifications Task Force in a {{letter dated|date=July 11, 2021|text=letter dated July 11, 2021}} (Reference 1). This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-580. As described herein, Entergy, has concluded that the justifications presented in TSTF-580 and the safety evaluation prepared by the NRC staff are applicable to GGNS and RBS, and justify this amendment for the incorporation of the changes to the GGNS and RBS TS.
Adoption of this change is dependent on previous adoption of TSTF-566, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems." GGNS and RBS adoption of TSTF-566 was approved by the NRC on February 1, 2021, (Reference 2).
2.2      Variations Entergy is not proposing any variations from the TS changes described in TSTF-580 or the applicable parts of the NRC SE dated July 11, 2021.

==3.0      REGULATORY ANALYSIS==

3.1      No Significant Hazards Consideration Analysis Entergy requests adoption of TSTF-580, "Provide Exception from Entering MODE 4 With No Operable RHR Shutdown Cooling." The proposed change provides a Technical Specifications exception to entering Mode 4 if both Residual Heat Removal (RHR) shutdown cooling subsystems are inoperable.
Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:
: 1.      Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No

CNRO-2022-00015 Enclosure Page 3 of 5 The proposed change provides a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable. The RHR System in the shutdown cooling mode performs the important safety function of removing decay heat from the reactor coolant system during shutdown. The RHR System in the shutdown cooling mode is not an initiator of any accident previously evaluated or assumed to mitigate any accident previously evaluated. The design and function of the RHR System are not affected by the proposed change.
The proposed change would also exempt entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable and other operating modes of the RHR System are inoperable, such as Low Pressure Core Injection (LPCI) and RHR suppression pool cooling, and both subsystems of the support system for the RHR System heat exchangers, the Standby Service Water (SSW) System, are inoperable.
The TS for those RHR operating modes and the SSW System require entering Mode 4 when both required subsystems are inoperable. Those operating modes and systems are not initiators to any accident previously evaluated but are used to mitigate the consequences of an accident previously evaluated. However, the consequences of an accident previously evaluated resulting from remaining in Mode 3 versus Mode 4 when RHR shutdown cooling subsystems are inoperable are not significantly increased because there would be no dependable method to remove post-accident decay heat in Mode 4 if both required RHR shutdown cooling subsystems are inoperable.
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 proposed change provides a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable. The proposed change does not affect the design function or operation of the RHR System or the SSW System. No new equipment is being installed as a result of the proposed change. The proposed change affects the actions taken when both required RHR shutdown cooling subsystems are inoperable, so no new failure mechanisms are created.
Therefore, this change does not create the possibility of a new or different kind of accident from an accident previously evaluated.
: 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No The proposed change provides a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable. The proposed change does not change any specific values or controlling parameters that define margin in the design or licensing basis. No safety limits are affected by the proposed change. The proposed change applies when both required RHR shutdown cooling subsystems are inoperable, so no design or safety limits associated with the operation of the RHR System are affected.

CNRO-2022-00015 Enclosure Page 4 of 5 Therefore, this change does not involve a significant reduction in a margin of safety.
Based upon the reasoning presented above, Entergy concludes that the requested change involves no significant hazards consideration, as set forth in 10 CFR 50.92(c), Issuance of Amendment.
3.2      Conclusions 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 issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

==4.0      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 Part 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.

==5.0      REFERENCES==
: 1.        NRC letter to TSTF - "Final Safety Evaluations of Technical Specification Task Force Traveler TSTF 580, Revision 1, "Provide Exception from Entering MODE 4 with No Operable RHR Shutdown Cooling," (EPIC L-2020-PMP-0012,) (ML21188A283,) dated July 11, 2021
: 2.        NRC letter to Entergy - "Grand Gulf Nuclear Station, Unit 1 and River Bend Station, Unit 1 - Issuance of Amendments Re: Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-566, Revision 0, Revise Actions For Inoperable RHR Shutdown Cooling Subsystems (EPID L-2020-LLA-0010)," (ML21011A048,) dated February 1, 2021 6.0      ATTACHMENTS 1.a.      Technical Specification Page Markups, Grand Gulf Nuclear Station, Unit 1 1.b.      Technical Specification Page Markups, River Bend Station, Unit 1 2.a.      Retyped Technical Specification Pages, Grand Gulf Nuclear Station, Unit 1 2.b       Retyped Technical Specification Pages, River Bend Station, Unit 1

CNRO-2022-00015 Enclosure Page 5 of 5 3.a. Markup of Technical Specification Bases Pages (For Information Only),
Grand Gulf Nuclear Station, Unit 1 3.b. Markup of Technical Specification Bases Pages (For Information Only),
River Bend Station, Unit 1

Enclosure, Attachment 1.a CNRO-2022-00015 Technical Specification Page Markups, Grand Gulf Nuclear Station, Unit 1 (3 pages)

RHR Shutdown Cooling System  Hot Shutdown 3.4.9 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System  Hot Shutdown LCO 3.4.9                   Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.
                            -----------------------------------------NOTES------------------------------------------------
: 1.      Both RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours per                   8 hour period.
: 2.      One RHR shutdown cooling subsystem may be inoperable for up to 2 hours for performance of Surveillances.
APPLICABILITY:              MODE 3 with reactor steam dome pressure less than the RHR cut in permissive pressure.
ACTIONS
-------------------------------------------------------------NOTE----------------------------------------------------------
Separate Condition entry is allowed for each RHR shutdown cooling subsystem.
CONDITION                                  REQUIRED ACTION                             COMPLETION TIME A. One or two RHR shutdown                    A.1            Verify an alternate                  1 hour cooling subsystems                                      method of decay heat inoperable.                                             removal is available for             AND each inoperable RHR shutdown cooling                     Once per 24 hours subsystem.                           thereafter (continued)
GRAND GULF                                                  3.4-21                    Amendment No. 142, 175, 225 ,

RHR Shutdown Cooling System  Hot Shutdown 3.4.9 ACTIONS (continued)
CONDITION                     REQUIRED ACTION                       COMPLETION TIME B. Required Action and     B.1            Initiate action to restore      Immediately associated Completion                  RHR shutdown cooling Time of Condition A not                subsystem(s) to met.                                   OPERABLE status.
C. Two RHR shutdown        C.1            Verify an alternate             1 hour cooling subsystems                     method of decay heat AND inoperable.                            removal is available for each inoperable             Once per 24 hours RHR shutdown cooling            thereafter subsystem.
                             ---------------------NOTE-----------------
D. Required Action and LCO 3.0.3 and all other LCO associated Completion Required Actions requiring a MODE Time of Condition C not change to MODE 4 may be met.
suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.
D.1             Initiate action to restore     Immediately one RHR shutdown cooling subsystem to OPERABLE status.
(continued)
GRAND GULF                               3.4-22                    Amendment No. 142, 175, 225,

RHR Shutdown Cooling System  Hot Shutdown 3.4.9 ACTIONS (continued)
CONDITION                 REQUIRED ACTION                 COMPLETION TIME EC. No RHR shutdown cooling  EC.1   Initiate action to restore  Immediately subsystem in operation.         one RHR shutdown cooling subsystem or one AND                             recirculation pump to operation.
No recirculation pump in operation.               AND EC.2   Verify reactor coolant      1 hour from discovery circulation by an           of no reactor coolant alternate method.           circulation AND Once per 12 hours thereafter AND EC.3   Monitor reactor coolant     Once per hour temperature and pressure.
GRAND GULF                         3.4- 22A              Amendment No.

Enclosure, Attachment 1.b CNRO-2022-00015 Technical Specification Page Markups, River Bend Station, Unit 1 (3 pages)

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 3.4    REACTOR COOLANT SYSTEM (RCS) 3.4.9     Residual Heat Removal (RHR) Shutdown Cooling SystemHot Shutdown LCO 3.4.9                   Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.
                            -------------------------------------------NOTES--------------------------------------------
: 1.      Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours per 8 hour period.
: 2.      One RHR shutdown cooling subsystem may be inoperable for up to 2 hours for performance of Surveillances.
APPLICABILITY:                      MODE 3 with reactor steam dome pressure less than the RHR cut in permissive pressure.
ACTIONS
------------------------------------------------------NOTE---------------------------------------------------------------
Separate Condition entry is allowed for each RHR shutdown cooling subsystem.
CONDITION                                 REQUIRED ACTION                          COMPLETION TIME A. One or two RHR                          A.1          Verify an alternate                  1 hour shutdown cooling                                      method of decay heat subsystems inoperable.                                removal is available for            AND each inoperable RHR shutdown cooling                    Once per 24 hours subsystem.                          thereafter (continued)
RIVER BEND                                                  3.4-22                   Amendment No. 81, 156, 204,

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 ACTIONS (continued)
CONDITION                   REQUIRED ACTION                         COMPLETION TIME B. Required Action and     B.1          Initiate action to restore         Immediately associated Completion                 RHR shutdown cooling Time of Condition A not               subsystem(s) to met.                                  OPERABLE status.
C. Two RHR shutdown        C.1          Verify an alternate                1 hour cooling subsystems                    method of decay heat inoperable.                           removal is available for          AND each inoperable RHR shutdown cooling                  Once per 24 hours subsystem.                        thereafter D. Required Action and     --------------------NOTE-----------------
associated Completion   LCO 3.0.3 and all other LCO Time of Condition C not Required Actions requiring a met.                    MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.
D.1          Initiate action to restore         Immediately one RHR shutdown cooling subsystem to OPERABLE status.
(continued)
RIVER BEND                               3.4-23                             Amendment No. 81, 204,

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 ACTIONS (continued)
CONDITION                 REQUIRED ACTION               COMPLETION TIME EC. No RHR shutdown cooling  EC.1    Initiate action to restore Immediately subsystem in operation.          one RHR shutdown cooling subsystem or AND                              one recirculation pump to operation.
No recirculation pump in operation.               AND EC.2    Verify reactor coolant     1 hour from circulation by an          discovery of no alternate method.          reactor coolant circulation AND Once per 12 hours thereafter AND EC.3    Monitor reactor coolant    Once per hour temperature and pressure.
RIVER BEND                          3.4-23A                         Amendment No.

Enclosure, Attachment 2.a CNRO-2022-00015 Retyped Technical Specification Pages, Grand Gulf Nuclear Station, Unit 1 (3 pages to follow)

RHR Shutdown Cooling System  Hot Shutdown 3.4.9 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System  Hot Shutdown LCO 3.4.9                   Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.
                            -----------------------------------------NOTES------------------------------------------------
: 1.      Both RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours per                   8 hour period.
: 2.      One RHR shutdown cooling subsystem may be inoperable for up to 2 hours for performance of Surveillances.
APPLICABILITY:              MODE 3 with reactor steam dome pressure less than the RHR cut in permissive pressure.
ACTIONS
-------------------------------------------------------------NOTE----------------------------------------------------------
Separate Condition entry is allowed for each RHR shutdown cooling subsystem.
CONDITION                                  REQUIRED ACTION                             COMPLETION TIME A. One RHR shutdown cooling                   A.1            Verify an alternate                  1 hour subsystem inoperable.                                   method of decay heat removal is available.                AND Once per 24 hours thereafter (continued)
GRAND GULF                                                  3.4-21                    Amendment No. 142, 175, 225,

RHR Shutdown Cooling System  Hot Shutdown 3.4.9 ACTIONS (continued)
CONDITION                     REQUIRED ACTION                       COMPLETION TIME B. Required Action and     B.1            Initiate action to restore      Immediately associated Completion                  RHR shutdown cooling Time of Condition A not                subsystem to met.                                   OPERABLE status.
C. Two RHR shutdown        C.1            Verify an alternate             1 hour cooling subsystems                     method of decay heat AND inoperable.                            removal is available for each inoperable             Once per 24 hours RHR shutdown cooling            thereafter subsystem.
                             ---------------------NOTE-----------------
D. Required Action and LCO 3.0.3 and all other LCO associated Completion Required Actions requiring a MODE Time of Condition C not change to MODE 4 may be met.
suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.
D.1             Initiate action to restore     Immediately one RHR shutdown cooling subsystem to OPERABLE status.
(continued)
GRAND GULF                               3.4-22                    Amendment No. 142, 175, 225,

RHR Shutdown Cooling System  Hot Shutdown 3.4.9 ACTIONS (continued)
CONDITION                REQUIRED ACTION                 COMPLETION TIME E. No RHR shutdown cooling  E.1    Initiate action to restore Immediately subsystem in operation.         one RHR shutdown cooling subsystem or one AND                             recirculation pump to operation.
No recirculation pump in operation.               AND E.2    Verify reactor coolant     1 hour from discovery circulation by an         of no reactor coolant alternate method.         circulation AND Once per 12 hours thereafter AND E.3    Monitor reactor coolant    Once per hour temperature and pressure.
GRAND GULF                        3.4-22A                Amendment No.

Enclosure, Attachment 2.b CNRO-2022-00015 Retyped Technical Specification Pages, River Bend Station, Unit 1 (3 pages to follow)

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 3.4    REACTOR COOLANT SYSTEM (RCS) 3.4.9     Residual Heat Removal (RHR) Shutdown Cooling SystemHot Shutdown LCO 3.4.9                   Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.
                            -------------------------------------------NOTES--------------------------------------------
: 1.      Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours per 8 hour period.
: 2.      One RHR shutdown cooling subsystem may be inoperable for up to 2 hours for performance of Surveillances.
APPLICABILITY:                      MODE 3 with reactor steam dome pressure less than the RHR cut in permissive pressure.
ACTIONS
------------------------------------------------------NOTE---------------------------------------------------------------
Separate Condition entry is allowed for each RHR shutdown cooling subsystem.
CONDITION                                 REQUIRED ACTION                          COMPLETION TIME A. One RHR shutdown                        A.1          Verify an alternate                  1 hour cooling subsystem                                     method of decay heat inoperable.                                           removal is available.               AND Once per 24 hours thereafter (continued)
RIVER BEND                                                  3.4-22                   Amendment No. 81, 156, 204,

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 ACTIONS (continued)
CONDITION                   REQUIRED ACTION                         COMPLETION TIME B. Required Action and     B.1          Initiate action to restore         Immediately associated Completion                 RHR shutdown cooling Time of Condition A not               subsystem to met.                                  OPERABLE status.
C. Two RHR shutdown        C.1          Verify an alternate                1 hour cooling subsystems                    method of decay heat inoperable.                           removal is available for          AND each inoperable RHR shutdown cooling                  Once per 24 hours subsystem.                        thereafter D. Required Action and     --------------------NOTE-----------------
associated Completion   LCO 3.0.3 and all other LCO Time of Condition C not Required Actions requiring a met.                    MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.
D.1          Initiate action to restore         Immediately one RHR shutdown cooling subsystem to OPERABLE status.
(continued)
RIVER BEND                               3.4-23                             Amendment No. 81, 204,

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 ACTIONS (continued)
CONDITION                REQUIRED ACTION               COMPLETION TIME E. No RHR shutdown cooling  E.1    Initiate action to restore Immediately subsystem in operation.         one RHR shutdown cooling subsystem or AND                             one recirculation pump to operation.
No recirculation pump in operation.               AND E.2    Verify reactor coolant     1 hour from circulation by an          discovery of no alternate method.          reactor coolant circulation AND Once per 12 hours thereafter AND E.3    Monitor reactor coolant    Once per hour temperature and pressure.
RIVER BEND                         3.4-23A                         Amendment No.

Enclosure, Attachment 3.a CNRO-2022-00015 Markup of Technical Specification Bases Pages (For Information Only),
Grand Gulf Nuclear Station, Unit 1 (4 pages to follow)

RHR Shutdown Cooling System - Hot Shutdown B 3.4.9 BASES APPLICABILITY    shutdown cooling mode to remove decay heat to reduce or (continued)     maintain coolant temperature. Otherwise, a recirculation pump is required to be in operation.
The requirements for decay heat removal in MODES 4 and 5 are discussed in LCO 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown"; LCO 3.9.8, "Residual Heat Removal (RHR) - High Water Level"; and LCO 3.9.9, "Residual Heat Removal (RHR) - Low Water Level."
ACTIONS          A Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.
A.1 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, the overall reliability is reduced, however, because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability.
Therefore an alternate method of decay heat removal must be provided.
(continued)
NO CHANGES ON THIS PAGE, FOR INFORMATION ONLY GRAND GULF                                B 3.4-44                               LBDCR 20085

RHR Shutdown Cooling System - Hot Shutdown B 3.4.9 BASES ACTIONS    A.1 (continued)
With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability.
This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour 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 methods(s) must be reconfirmed every 24 hours thereafter. This will provide assurance of continued heat removal capability.
The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as contributing to the alternate method capability. Alternate methods that can be used include (but are not limited to) the Spent Fuel Pool Cooling System the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystem.
B.1 If the required alternate method(s) of decay heat removal cannot be verified within one hour, immediate action must be taken to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The Required Action will restore redundant decay heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.
C.1 With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability.
This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour 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 hours thereafter. This will provide assurance of continued heat removal capability.
The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability. Alternate methods that can be used include (but are not GRAND GULF                         B 3.4-45                              LBDCR 20085

RHR Shutdown Cooling System - Hot Shutdown B 3.4.9 limited to) the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystem.
D.1 If the required alternate methods of decay heat removal cannot be verified within one hour, immediate action must be taken to restore at least one RHR shutdown cooling subsystem to OPERABLE status. The immediate Completion Time reflects the importance of restoring a method of heat removal.
Required Action D.1 is modified by a Note indicating that all required MODE changes to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status. In this case, LCO 3.0.3 and other Required Actions directing entry into MODE 4 could force the unit into a less safe condition in which there may be no adequate means to remove decay heat. It is more appropriate to allow the restoration of one of the RHR shutdown cooling subsystems before requiring entry into a condition in which that subsystem would be needed and exiting a condition where other sources of cooling are available.
When at least one RHR subsystem is restored to OPERABLE status, the Completion Times of LCO 3.0.3 or other Required Actions resume at the point at which they were suspended.
CE.1, CE.2, and CE.3 With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as is permitted by LCO Note 1, reactor coolant circulation by the RHR shutdown cooling subsystem or one recirculation pump must be restored without delay.
Until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature.
The 1 hour Completion Time is based on the coolant circulation function and is modified such that the 1 hour is applicable (continued)
GRAND GULF                         B 3.4-465a                            LBDCR 20085

RHR Shutdown Cooling System - Hot Shutdown B 3.4.9 BASES ACTIONS      CE.1, CE.2, and CE.3 (continued) separately for each occurrence involving a loss of coolant circulation.
Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours thereafter. This will provide assurance of continued temperature monitoring capability.
During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR shutdown cooling system 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 Surveillance 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 hour 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 RHR shutdown cooling system 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 (continued)
GRAND GULF                            B 3.4-46                               LBDCR 20085

Enclosure, Attachment 3.b CNRO-2022-00015 Markup of Technical Specification Bases Pages (For Information Only),
River Bend Station, Unit 1 (4 pages to follow)

RHR Shutdown Cooling System  Hot Shutdown B 3.4.9 BASES APPLICABILITY  The requirements for decay heat removal in MODES 4 and 5 are (continued)   discussed in LCO 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown"; LCO 3.9.8, "Residual Heat Removal (RHR) - High Water Level"; and LCO 3.9.9, "Residual Heat Removal (RHR) - Low Water Level."
ACTIONS        A Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.
A.1 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability.
Therefore, an alternate method of decay heat removal must be provided.
(continued)
No Changes on this page, For Information Only RIVER BEND                              B 3.4-45                        Amendment No. 204

RHR Shutdown Cooling System  Hot Shutdown B 3.4.9 BASES ACTIONS    A.1 (continued)
With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability.
This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour 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 hours thereafter. This will provide assurance of continued heat removal capability.
The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to the alternate method capability. Alternate methods that can be used include (but are not limited to) the Control Rod Drive System, the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling system.
B.1 If the required alternate method(s) of decay heat removal cannot be verified within one hour, immediate action must be taken to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The Required Action will restore redundant decay heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.
C.1 With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability.
This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour 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 hours thereafter. This will provide assurance of continued heat removal capability.
The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient (continued)
RIVER BEND                         B 3.4-46                       Amendment No. 204

RHR Shutdown Cooling System  Hot Shutdown B 3.4.9 BASES ACTIONS    C.1 (continued) losses can be considered as, or contributing to, the alternate method capability. Alternate methods that can be used include (but are not limited to) the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystem.
D.1 If the required alternate methods of decay heat removal cannot be verified within one hour, immediate action must be taken to restore at least one RHR shutdown cooling subsystem to OPERABLE status. The immediate Completion Time reflects the importance of restoring a method of heat removal.
Required Action D.1 is modified by a Note indicating that all required MODE changes to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status. In this case, LCO 3.0.3 and other Required Actions directing entry into MODE 4 could force the unit into a less safe condition in which there may be no adequate means to remove decay heat. It is more appropriate to allow the restoration of one of the RHR shutdown cooling subsystems before requiring entry into a condition in which that subsystem would be needed and exiting a condition where other sources of cooling are available.
When at least one RHR subsystem is restored to OPERABLE status, the Completion Times of LCO 3.0.3 or other Required Actions resume at the point at which they were suspended.
EC.1, EC.2, and EC.3 With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as is permitted by LCO Note 1, reactor coolant circulation by the RHR shutdown cooling subsystem or one recirculation pump must be restored without delay.
Until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature.
The 1 hour Completion Time is based on the coolant circulation function and is modified such that the 1 hour is applicable separately for each occurrence involving a loss of coolant circulation. Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours thereafter. This will provide assurance of continued temperature monitoring capability.
(continued)
RIVER BEND                        B 3.4-46A                           Amendment No.

RHR Shutdown Cooling System  Hot Shutdown B 3.4.9 BASES ACTIONS      EC.1, EC.2, and EC.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 Surveillance 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 hour 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 RHR 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.
(continued)
RIVER BEND                            B 3.4-47                         Amendment No. 204}}