View source for TSTF-07-09, TSTF-478, Revision 1, BWR Technical Specification Changes That Implement the Revised Rule for Combustible Gas Control.

{{Adams
| number = ML070530490
| issue date = 02/21/2007
| title = TSTF-478, Revision 1, BWR Technical Specification Changes That Implement the Revised Rule for Combustible Gas Control.
| author name = Crowthers M, Infanger P, Woods B, Yates B
| author affiliation = Babcock &amp; Wilcox, BWR Owners Group, Combustion Engineering, Inc, PWR Owners Group, Technical Specifications Task Force
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = PROJ0753
| license number = 
| contact person = 
| case reference number = TSTF-07-09, TSTF-478, Rev. 1
| document type = Letter type:TSTF, Technical Specifications
| page count = 43
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:TECHNICAL SPECIFICATIONS TASK FORCE TSTF                                           A JOINT OWNERS GROUP ACTIVITY February 21, 2007                                                                  TSTF-07-09 PROJ0753 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==SUBJECT:==
TSTF-478, Revision 1, "BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control"

==REFERENCE:==
Letter dated February 7, 2007 from the TSTF to the NRC, "Response to NRC Request for Additional Information Regarding TSTF-478, Revision 0, 'BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control,' dated November 9, 2006"

==Dear Sir or Madam:==

Enclosed for NRC review is Revision 1 of TSTF-478, "BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control." In the referenced letter, the TSTF committed to revise TSTF-478 to remove the proposed change to NUREG-1434, "Standard Technical Specifications for BWR/6 Plants," Specification 3.6.3.2, "Drywell Purge System," Action B. The enclosed revision to TSTF-478 incorporates this change.
Any NRC review fees associated with the review of TSTF-478 should be continue to billed to the Boiling Water Reactors Owners Group.
The TSTF requests that the Traveler be made available under the Consolidated Line Item Improvement Process.
11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Email: tstf@excelservices.com Administered by EXCEL Services Corporation

TSTF 07-09 February 21, 2007 Page 2 Should you have any questions, please do not hesitate to contact us.
Bert Yates (PWROG/W)                                  Michael Crowthers (BWROG)
Brian Woods (PWROG/CE)                               Paul Infanger (PWROG/B&W)
Enclosure cc:    Tim Kobetz, Technical Specifications Branch, NRC Ross Telson, Technical Specifications Branch, NRC

BWROG-98, Rev. 2                   TSTF-478, Rev. 1 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control NUREGs Affected:               1430           1431             1432            1433        1434 Classification: 1) Technical Change                                                 Recommended for CLIIP?: Yes Correction or Improvement:            Improvement                                          NRC Fee Status:          Not Exempt Benefit:       Retires Equipment Industry

==Contact:==
Mike Crowthers, (610) 774-7766, mhcrowthers@pplweb.com See attached.
Revision History OG Revision 0                                  Revision Status: Closed Revision Proposed by: BWROG Revision

== Description:==

Original Issue Owners Group Review Information Date Originated by OG: 10-May-04 Owners Group Comments (No Comments)
Owners Group Resolution:            Superceeded Date: 17-May-04 OG Revision 1                                  Revision Status: Closed Revision Proposed by: BWROG Revision

== Description:==

Complete replacement of Revision 0. Revised title. In addition to the original change to eliminate CAD, added changes to Primary Containment Oxygen Concentration, Primary Containment and Drywell Hydrogen Ignitors, Drywell Cooling System Fans, and Drywell Purge System.
Owners Group Review Information Date Originated by OG: 12-Aug-04 Owners Group Comments (No Comments)
Owners Group Resolution:            Approved          Date: 06-Oct-04 TSTF Review Information TSTF Received Date:          06-Oct-04                  Date Distributed for Review 06-Oct-04 OG Review Completed:               BWOG            WOG            CEOG         BWROG 21-Feb-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-98, Rev. 2                   TSTF-478, Rev. 1 OG Revision 1                                  Revision Status: Closed TSTF Comments:
TSTF approved in principle at the August 25 TSTF meeting. BWROG chairman to provide additional editorial comments. To redistribute to BWROG TSICC for confirmation.
TSTF Resolution:         Superceeded                                         Date: 06-Feb-05 OG Revision 2                                  Revision Status: Closed Revision Proposed by: BWROG Revision

== Description:==

Various editorial improvements.
Owners Group Review Information Date Originated by OG: 07-Feb-05 Owners Group Comments (No Comments)
Owners Group Resolution:            Approved          Date: 21-Mar-05 TSTF Review Information TSTF Received Date:          21-Mar-05                  Date Distributed for Review 21-Mar-05 OG Review Completed:               BWOG            WOG            CEOG          BWROG TSTF Comments:
(No Comments)
TSTF Resolution:         Approved                                            Date: 23-Apr-05 NRC Review Information NRC Received Date:            25-Apr-05 NRC Comments:
NRC provided RAI on 11/9/06. TSTF responded on 2/7/07. In response to RAI #3, the TSTF stated that they would withdraw the change to NUREG-1434 (BWR/6), Specification 3.6.3.2, to delete Required Action B.2.
Final Resolution:        Superceded by Revision TSTF Revision 1                                Revision Status: Active Revision Proposed by: TSTF Revision

== Description:==

NRC provided RAI on 11/9/06. TSTF responded on 2/7/07. In response to RAI #3, the TSTF stated that they would withdraw the change to NUREG-1434 (BWR/6), Specification 3.6.3.2, to delete Required Action B.2.
This revision makes that change.
TSTF Review Information 21-Feb-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-98, Rev. 2                   TSTF-478, Rev. 1 TSTF Revision 1                                Revision Status: Active TSTF Received Date:          07-Feb-07                  Date Distributed for Review 07-Feb-07 OG Review Completed:               BWOG            WOG            CEOG          BWROG TSTF Comments:
(No Comments)
TSTF Resolution:         Approved                                            Date: 20-Feb-07 NRC Review Information NRC Received Date:            20-Feb-07 Affected Technical Specifications Bkgnd 3.6.3.1 Bases         Drywell Cooling System Fans                                          NUREG(s)- 1433 Only S/A 3.6.3.1 Bases           Drywell Cooling System Fans                                          NUREG(s)- 1433 Only Appl. 3.6.3.1 Bases         Drywell Cooling System Fans                                          NUREG(s)- 1433 Only Ref. 3.6.3.1 Bases          Drywell Cooling System Fans                                          NUREG(s)- 1433 Only Action 3.6.3.1.A Bases      Drywell Cooling System Fans                                          NUREG(s)- 1433 Only Action 3.6.3.1.B            Drywell Cooling System Fans                                          NUREG(s)- 1433 Only Action 3.6.3.1.B Bases      Drywell Cooling System Fans                                          NUREG(s)- 1433 Only Bkgnd 3.6.3.2 Bases         Primary Containment Oxygen Concentration                             NUREG(s)- 1433 Only S/A 3.6.3.2 Bases           Primary Containment Oxygen Concentration                             NUREG(s)- 1433 Only LCO 3.6.3.2 Bases           Primary Containment Oxygen Concentration                             NUREG(s)- 1433 Only Appl. 3.6.3.2               Primary Containment Oxygen Concentration                             NUREG(s)- 1433 Only Appl. 3.6.3.2 Bases         Primary Containment Oxygen Concentration                             NUREG(s)- 1433 Only Action 3.6.3.2              Primary Containment Oxygen Concentration                             NUREG(s)- 1433 Only Action 3.6.3.2 Bases        Primary Containment Oxygen Concentration                             NUREG(s)- 1433 Only Action 3.6.3.2.A            Primary Containment Oxygen Concentration                             NUREG(s)- 1433 Only Action 3.6.3.2.A Bases      Primary Containment Oxygen Concentration                             NUREG(s)- 1433 Only 21-Feb-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-98, Rev. 2                   TSTF-478, Rev. 1 Action 3.6.3.2.B            Primary Containment Oxygen Concentration                            NUREG(s)- 1433 Only Action 3.6.3.2.B Bases      Primary Containment Oxygen Concentration                            NUREG(s)- 1433 Only 3.6.3.3                    CAD System                                                          NUREG(s)- 1433 Only Change

== Description:==
Deleted 3.6.3.3 Bases              CAD System                                                          NUREG(s)- 1433 Only Change

== Description:==
Deleted S/A 3.6.3.1 Bases           Primary Containment and Drywell Hydrogen Ignitors                   NUREG(s)- 1434 Only Appl. 3.6.3.1 Bases         Primary Containment and Drywell Hydrogen Ignitors                   NUREG(s)- 1434 Only Action 3.6.3.1.B            Primary Containment and Drywell Hydrogen Ignitors                   NUREG(s)- 1434 Only Action 3.6.3.1.B Bases      Primary Containment and Drywell Hydrogen Ignitors                   NUREG(s)- 1434 Only Bkgnd 3.6.3.2 Bases         Drywell Purge System                                                NUREG(s)- 1434 Only S/A 3.6.3.2 Bases           Drywell Purge System                                                NUREG(s)- 1434 Only Appl. 3.6.3.2 Bases         Drywell Purge System                                                NUREG(s)- 1434 Only Ref. 3.6.3.2 Bases          Drywell Purge System                                                NUREG(s)- 1434 Only Action 3.6.3.2.A Bases      Drywell Purge System                                                NUREG(s)- 1434 Only Action 3.6.3.2.B Bases      Drywell Purge System                                                NUREG(s)- 1434 Only 21-Feb-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-478, Rev. 1 1.0 Description The Nuclear Regulatory Commission (NRC) has revised 10 CFR 50.44 to amend its standards for combustible gas control in light-water-cooled power reactors. The Commission eliminated the design basis loss of coolant accident (LOCA) hydrogen release from 50.44 and consolidated the requirements for hydrogen and oxygen monitoring to 50.44, while relaxing safety classifications and licensee commitments to certain design and qualification criteria. TSTF-447, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors, implemented the majority of the Technical Specification (TS) changes resulting from this rule change. Specifically, TSTF-447 provided model changes to permit the NRC to efficiently process amendments to remove requirements for hydrogen recombiners, and hydrogen and oxygen monitors from TS. TSTF-447 was approved for adoption using the Consolidated Line Item Improvement Process (CLIIP) on September 25, 2003, and many Boiling Water Reactors (BWR) have submitted TS changes to adopt the TSTF.
During the comment period for the 50.44 rule change, the Industry commented that BWRs with Mark I Containment designs either use a Containment Atmospheric Dilution (CAD) System or Hydrogen Recombiners, and that both systems would no longer be required under the revised standards for combustible gas control. However, since the proposed rule change to 50.44 and the associated model safety evaluation did not specifically address elimination of the CAD System specification, the Industry agreed to request elimination of the CAD system separate from TSTF-447.
Subsequently, an additional inconsistency between the revised 50.44 rule and the BWR Improved Standard Technical Specifications (ISTS) was discovered. Namely, BWR/4 Specification 3.6.3.1, Drywell Cooling System Fans, and BWR/6 Specification 3.6.3.1, Primary Containment and Drywell Hydrogen Igniters, contains Required Actions to Verify by administrative means that the hydrogen control function is maintained. The alternate hydrogen control functions (e.g., hydrogen recombiners or CAD systems) are intended to control a design basis LOCA hydrogen release. These functions are eliminated from the TS consistent with the 10 CFR 50.44 rule change that eliminated the design basis hydrogen release. The TS requirements for hydrogen recombiners were previously deleted by TSTF-447 and the CAD system requirements are proposed to be deleted by this Traveler. Therefore, this Traveler corrects the ISTS by eliminating the subject alternate hydrogen control function found acceptable in TSTF-447.
This proposed change also modifies BWR/4 Specification 3.6.3.2, Primary Containment Oxygen Concentration. According to the 50.44 rule change, primary containment oxygen concentration is no longer an initial condition assumed in the accident analysis, but is retained for severe accident mitigation. Therefore, a longer Completion Time, 72 hours vice 24 hours, to establish containment integrity is proposed reflecting the small likelihood of an accident occurring while in the Action.
Page 1 of 12

TSTF-478, Rev. 1 2.0 Proposed Change BWR/4 Specification 3.6.3.3, CAD system, and the associated Bases, are deleted from the BWR/4 ISTS. Note that the Specification is deleted and not relocated to licensee control. There are no subsequent specifications which must be renumbered. There are no reference changes required in other specifications due to this deletion.
BWR/4 Specification 3.6.3.1, Drywell Cooling System Fans, and BWR/6 Specification 3.6.3.1, Primary Containment and Drywell Hydrogen Igniters, are revised to eliminate Required Action B.1. Subsequent Required Actions are renumbered. The Bases are revised to reflect this change and other changes required by the 50.44 rule change.
BWR/4 Specification 3.6.3.2, Primary Containment Oxygen Concentration, is revised. The Applicability and Actions are revised. The Bases are revised to reflect the changes to the Specifications and other changes required by the 50.44 rule change.

===3.0 Background===
In the revised 10 CFR 50.44 rule, the Commission eliminated the requirements for hydrogen recombiners and hydrogen purge systems, and relaxed the requirements for hydrogen and oxygen monitoring equipment to make them commensurate with their risk significance.
Installation of hydrogen recombiners and/or vent and purge systems originally required by 50.44 (b)(3) was intended to address the limited quantity and rate of hydrogen generation that was postulated from a design basis LOCA. In the basis for the rule change, the Commission found that this hydrogen release is not risk significant because the design basis LOCA hydrogen release does not contribute to the conditional probability of a large release up to 24 hours after the onset of core damage. In addition, the Commission found that these systems were ineffective at mitigating hydrogen releases from risk significant accident sequences that could threaten containment integrity.
The Commission noted that the regulatory analysis for the rulemaking found the cost of maintaining the recombiners exceeded the benefits of retaining them to prevent containment failure sequences that progress to the very late time frame. The Commission further noted that the NRC believes that this conclusion would also be true for the backup hydrogen purge system even though the cost of the hydrogen purge system would be much lower because the system also is needed to inert the containment.
While the rule change was broad in its implications, the TS changes that were approved by the NRC (TSTF-447) in association with the rule change were relatively narrow and only addressed containment gas monitoring instrumentation requirements and the elimination of the hydrogen recombiner TS. Other justifiable TS changes were identified prior to and subsequent to the completion of the rule change. However, revision of the rule change package to address these other issues would have delayed the rule change, so the Industry and the NRC agreed to address the other ISTS changes related to the 50.44 rule change in a separate Traveler.
Page 2 of 12

TSTF-478, Rev. 1 4.0 Technical Analysis Elimination of the CAD System As a result of the requirements originally imposed by 10 CFR 50.44, BWRs with Mark I containment designs either installed hydrogen recombiners or CAD systems to meet requirements for hydrogen control. To ensure that a combustible gas mixture does not occur, oxygen concentration is kept < 5.0 volume percent (v/o), or hydrogen concentration is kept
< 4.0 v/o. Hydrogen recombiners work to reduce the combustible gas concentration in the primary containment by recombining hydrogen and oxygen to form water vapor. The CAD System functions to maintain combustible gas concentrations within the primary containment at or below the flammability limits following a postulated loss of coolant accident (LOCA) by diluting hydrogen and oxygen with nitrogen.
The following is an excerpt from the BWR/4 NUREG-1433 containing the TS BASES for BWRs with Mark I Containments who use hydrogen recombiners or CAD systems. By comparing these discussions side by side, it is evident that the two systems accomplish the same function, but accomplish the task via different systems BWR-4 Hydrogen Recombiner BASES (B BWR-4 CAD BASES (B 3.6.3.3) 3.6.3.1)
BACKGROUND                                         BACKGROUND The primary containment hydrogen recombiner        The CAD System functions to maintain eliminates the potential breach of primary         combustible gas concentrations within the containment due to a hydrogen oxygen reaction      primary containment at or below the and is part of combustible gas control required    flammability limits following a postulated loss by 10 CFR 50.44, "Standards for Combustible        of coolant accident (LOCA) by diluting Gas Control Systems in Light-Water-Cooled          hydrogen and oxygen with nitrogen. To ensure Reactors" (Ref. 1), and GDC 41, "Containment       that a combustible gas mixture does not occur, Atmosphere Cleanup" (Ref. 2). The primary          oxygen concentration is kept < [5.0] volume containment hydrogen recombiner is required        percent (v/o), or hydrogen concentration is to reduce the hydrogen concentration in the        kept < 4.0 v/o.
primary containment following a loss of coolant accident (LOCA). The primary               The CAD System is manually initiated and containment hydrogen recombiner                    consists of two independent, 100% capacity accomplishes this by recombining hydrogen          subsystems. Each subsystem includes a liquid and oxygen to form water vapor. The vapor          nitrogen supply tank, ambient vaporizer, remains in the primary containment, thus           electric heater, and connected piping to supply eliminating any discharge to the environment.      the drywell and suppression chamber volumes.
The primary containment hydrogen recombiner        The nitrogen storage tanks each contain is manually initiated since flammability limits    [4350] gal, which is adequate for [7] days of would not be reached until several days after a    CAD subsystem operation.
Design Basis Accident (DBA).
The CAD System operates in conjunction with The primary containment hydrogen recombiner emergency operating procedures that are used Page 3 of 12

TSTF-478, Rev. 1 functions to maintain the hydrogen gas              to reduce primary containment pressure concentration within the containment at or          periodically during CAD System operation.
below the flammability limit of 4.0 volume          This combination results in a feed and bleed percent (v/o) following a postulated LOCA. It       approach to maintaining hydrogen and oxygen is fully redundant and consists of two 100%         concentrations below combustible levels.
capacity subsystems. Each primary containment hydrogen recombiner consists of an enclosed blower assembly, heater section, reaction chamber, direct contact water spray gas cooler, water separator, and associated piping, valves, and instruments. The primary containment hydrogen recombiner will be manually initiated from the main control room when the hydrogen gas concentration in the primary containment reaches [3.3] v/o. When the primary containment is inerted (oxygen concentration < 4.0 v/o), the primary containment hydrogen recombiner will only function until the oxygen is used up (2.0 v/o hydrogen combines with 1.0 v/o oxygen). Two recombiners are provided to meet the requirement for redundancy and independence.
Each recombiner is powered from a separate Engineered Safety Feature bus and is provided with separate power panel and control panel.
The process gas circulating through the heater, the reaction chamber, and the cooler is automatically regulated to [150] scfm by the use of an orifice plate installed in the cooler.
The process gas is heated to [1200]_F. The hydrogen and oxygen gases are recombined into water vapor, which is then condensed in the water spray gas cooler by the associated residual heat removal subsystem and discharged with some of the effluent process gas to the suppression chamber. The majority of the cooled, effluent process gas is mixed with the incoming process gas to dilute the incoming gas prior to the mixture entering the heater section.
SAFETY ANALYSIS                                     SAFETY ANALYSES The primary containment hydrogen recombiner To evaluate the potential for hydrogen and provides the capability of controlling the bulk     oxygen accumulation in primary containment Page 4 of 12

TSTF-478, Rev. 1 hydrogen concentration in primary                  following a LOCA, hydrogen and oxygen containment to less than the lower flammable       generation is calculated (as a function of time concentration of 4.0 v/o following a DBA.          following the initiation of the accident). The This control would prevent a primary               assumptions stated in Reference 1 are used to containment wide hydrogen burn, thus               maximize the amount of hydrogen and oxygen ensuring that pressure and temperature             generated. The calculation confirms that when conditions assumed in the analysis are not         the mitigating systems are actuated in exceeded. The limiting DBA relative to             accordance with emergency operating hydrogen generation is a LOCA.                     procedures, the peak oxygen concentration in primary containment is < [5.0] v/o (Ref. 2).
Hydrogen may accumulate in primary containment following a LOCA as a result of        Hydrogen and oxygen may accumulate within either:                                            primary containment following a LOCA as a result of either:
A metal steam reaction between the zirconium fuel rod cladding and the reactor coolant or       A metal water reaction between the zirconium Radiolytic decomposition of water in the           fuel rod cladding and the reactor coolant or Reactor Coolant System.                            Radiolytic decomposition of water in the Reactor Coolant System.
To evaluate the potential for hydrogen accumulation in primary containment                The CAD System satisfies Criterion 3 of 10 following a LOCA, the hydrogen generation is       CFR 50.36(c)(2)(ii).
calculated as a function of time following the initiation of the accident. Assumptions            1. Regulatory Guide 1.7, Revision [2].
recommended by Reference 3 are used to maximize the amount of hydrogen calculated.
The calculation confirms that when the mitigating systems are actuated in accordance with emergency procedures, the peak hydrogen concentration in the primary containment is <
4.0 v/o (Ref. 4).
The primary containment hydrogen recombiners satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
: 3. Regulatory Guide 1.7, Revision [1].
From the above, it is easily seen that the hydrogen recombiners and CAD system perform the exact same function for post-LOCA gas control. Considering that the 10 CFR 50.44 rule change allowed for elimination of hydrogen recombiners for post-LOCA gas control, it follows directly that the rule change basis would likewise allow for the elimination of CAD systems.
Hence, it is concluded that CAD systems no longer meet the criteria for retention in the TS and may be removed from the plant.
Page 5 of 12

TSTF-478, Rev. 1 Certain statements in the amended rule may have influenced judgments on the disposition of the CAD system. Statements refer to the backup purge system which is not a system used in BWRs with Mark I Containments who have CAD systems. Some BWRs with Mark III Containment designs have a non-safety backup purge system. The backup purge system referred to in the amended rule is believed to be the CAD system; however, the CAD system is not used for purging or for inerting activities. The CAD system is only used for post-accident addition of nitrogen. A totally separate system is used in BWRs for the initial nitrogen inerting of the containment and BWRs who have CAD systems also have separate system which may be used for purging/controlled venting as part of severe accident management strategies.
In addition, there appear to be judgments in the rule consideration that the cost to maintain the CAD system is not significant. In reality, the cost of maintaining the CAD system is significant at BWRs and exceeds the reported cost of maintaining the recombiners.
As part of the Commissions regulatory analysis for the proposed rulemaking cost and benefit calculations were performed for recombiners. The total benefits calculated are $21,300 which when compared with operating costs led to the conclusion that recombiners could be eliminated to reduce unnecessary regulatory burden. Concerning the backup hydrogen purge system (CAD), the regulatory analysis states:
The issue of eliminating the requirement for safety grade purge/vent systems is not specifically analyzed in this regulatory analysis because the staff believes that the above conclusion would also be true for the backup hydrogen purge system. The cost is expected to exceed the estimated benefit of $21,320 as calculated in Appendix A of this document.
In addition, the benefit would not be as great because the hydrogen purge system does not prevent a release.
The regulatory analysis referred to information provided by the BWR Owners Group topical report NEDO-33033 titled Regulatory Relaxation for the H2/O2 Monitors and Combustible Gas Control System, July 2001, for annual cost burden for recombiners and monitors. The BWR Owners report also includes annual cost for maintaining the CAD system. The report notes that the typical yearly cost to maintain a BWR CAD system is approximately $200k. The major costs include:
* Vendor support                                   $15k
* Maintenance, planning, and scheduling            $25k
* System and design engineering                    $80k
* Component replacements and repairs               $75k The above yearly costs when compared to the maximum present worth benefits calculated in the Commissions regulatory analysis would support elimination of the CAD system to reduce unnecessary regulatory burden.
With respect to the potential benefits of maintaining CAD for severe accidents, the BWR Emergency Procedures conclude that use of CAD is of little benefit in responding to most events, due to its limited capacity. In fact, for the likely scenario of a degraded core that generates Page 6 of 12

TSTF-478, Rev. 1 significant hydrogen, use of CAD can be detrimental to event mitigation as it overpressurizes the containment during containment flooding scenarios, forcing containment venting that would otherwise not be warranted.
From these discussions, it is clear that the change to 10 CFR 50.44 eliminated the basis for considering the CAD system to meet 10 CFR 50.36(c)(2)(ii). The Safety Evaluation reached the same conclusion for the hydrogen recombiner system and allowed that system to be deleted from the TS and allows the equipment to be eliminated from the plant. This Traveler deletes the CAD system from the TS and allows the equipment to be eliminated from the plant.
Elimination of the Required Actions to Verify the Hydrogen Control Function Mark III containment plants were originally designed with only hydrogen recombiners to control the hydrogen from a DBA (5% cladding reaction). The igniters were added later as a backfit to control hydrogen from a severe accident (75 % cladding reaction). Although the igniters are primarily designed to control hydrogen generated from a severe accident, they can also control the smaller hydrogen buildup from a DBA.
BWR/6 TS 3.6.3.1, Required Action B.1, requires verification that the hydrogen control function is maintained if both igniter divisions are inoperable. The Bases only requires this verification for the DBA design function (i.e., one recombiner and one purge system). It does not require verification of alternate severe accident mitigation design features. Note that a recombiner is not sufficient to control hydrogen from a severe accident.
The 50.44 rule change eliminated the DBA hydrogen control requirements and the recombiner TS requirements. TSTF-447 eliminated the Required Action B.1 Bases statement describing which systems provide the alternate DBA hydrogen control capabilities, but the Action itself was unchanged. BWR/6 TS 3.6.3.1, Required Action B.1, needs to be deleted since the action was related to maintaining an alternate DBA function (i.e., the hydrogen recombiners) which has been eliminated. Alternate methods of managing a severe accident hydrogen release are addressed through the Severe Accident Management Guidelines.
Required Action B.1 of BWR/4 TS 3.6.3.1 requires verification that the hydrogen control function is maintained if both drywell cooling system fans were inoperable. This Action may be deleted because, consistent with the basis for the changes to 10 CFR 50.44, the probability of the occurrence of an accident that would generate hydrogen in the amounts capable of exceeding the flammability limit is low during the 7 day period of mixing system unavailability.
The Drywell Cooling System fans (BWR/4 TS 3.6.3.1) and Drywell Purge Systems (BWR/6 TS 3.6.3.2) ensure a mixed atmosphere for combustible gas control as required by 10 CFR 50.44 (b)(1). A mixed atmosphere helps prevent localized accumulation of hydrogen following a Design Basis Accident (DBA) LOCA. Localized concentration in amounts exceeding the flammability limits could impact safety related structures or components relied upon to mitigate a DBA. More recent studies have shown, however, that the hydrogen release postulated from a DBA LOCA is not risk significant because it is not large enough to lead to early containment failure. The revised rule effective October 16, 2003, eliminated the design basis LOCA hydrogen Page 7 of 12

TSTF-478, Rev. 1 release from 10 CFR 50.44, but retained the requirement for all containment types to have the capability for ensuring a mixed atmosphere. Since the DBA LOCA hydrogen release was eliminated from 10 CFR 50.44, the system is not needed to mitigate a design basis accident and therefore no longer satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). However, the system requirements are retained in accordance with Criterion 4. The Applicable Safety Analysis section of the TS Bases for BWR/4 TS 3.6.3.1 and BWR/6 TS 3.6.3.2 are revised to state that the LCOs meet Criterion 4 instead of Criterion 3.
Changes to the Primary Containment Oxygen Concentration Specification BWR/4 TS 3.6.3.2, Primary Containment Oxygen Concentration, Bases, Applicable Safety Analysis section, state that the LCO satisfies 10 CFR 50.36(c)(2)(ii) Criterion 2. Criterion 2 is A process variable, design feature or operational restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. As noted in the Final Rulemaking for 10 CFR 50.44 (68 FR 54123), a combustible gas mixture is no longer postulated to occur as a result of any design basis accident. Thus, the existing UFSAR accident analyses for evaluating combustible gas mixtures from a design basis LOCA, performed pursuant to Regulatory Guide 1.7, Rev. 2, (or earlier revision, per the individual plants licensing basis) is no longer required and may be removed from the UFSAR, pursuant to 10 CFR 50.71(e). Therefore, LCO 3.6.3.2 no longer meets the definition of Criterion 2.
The regulatory analysis for the revised 50.44 rule change also concluded that combustible gases produced by severe (i.e., beyond design basis) accidents, involving both fuel-cladding oxidation and core-concrete interaction, would be risk significant for plants with Mark I and II containments if not for the inerted containment atmosphere. Thus, the final rule retains the existing requirement in 50.44(c)(3)(i) to inert Mark I and II type containments. However, given the change in status of being needed for severe accidents and not for DBAs, the Bases are revised to state that the LCO meets Criterion 4. Criterion 4 is a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
The regulatory analysis performed for the Final Rule change to 10 CFR 50.44 (68 FR 54123),
determined that the threat of a hydrogen explosion that threatened containment integrity was sufficiently improbable that it could be removed from the plants design basis and re-categorized as a severe accident. Given the low probability of a severe accident occurring while the primary containment oxygen is not within limit, the Traveler proposes to expand the current Completion Time of 24 hours to 72 hours, which is more in keeping with the severe accident determination.
The existing provision of the Applicability to allow the LCO to not be met within 24 hours of startup and shutdown, while originally intended to be a relaxation, often represents an operational hardship, and is not commensurate with the associated plant risk for a condition only associated with severe accidents. Changing the Applicability to remove the 24 hour allowance and instead invoking LCO 3.0.4.c, which allows entering the Mode of Applicability with the LCO not met while relying on the actions, allows the use of the proposed 72 hour Completion Page 8 of 12

TSTF-478, Rev. 1 Time instead of the Applicability exclusion. The generic risk evaluation performed for the rulemaking package justifies the LCO 3.0.4.c allowance, which need not be re-performed on a plant specific basis.
Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is permitted to be de-inerted for a short period of time following plant startup to facilitate containment access to perform required inspections during startup. The use of the LCO 3.0.4.c provision will allow the containment to remain de-inerted for up to 72 hours after entry into MODE 1 to permit containment entries to perform inspections or any needed repairs just after startup. It also allows the process of inerting the containment to be performed after the plant has reached steady state conditions, rather than during the plant startup process, when many other activities and Surveillances are being performed. The current provision only allows a delay of up to 24 hours. This short allowance is sometimes not sufficient to prevent the plant from beginning the inerting process, only to have an equipment problem requiring containment entry, necessitating exiting the Mode of Applicability and de-inerting the containment. Such starting and stopping is an Operator distraction that is not warranted.
In addition, the Completion Time of 72 hours for Required Action A.1 will allow the containment to be de-inerted earlier in the routine plant shutdown process. This eliminates a complex task from the shutdown process, when many other activities are underway requiring Operator vigilance. The current provision of 24 hours prior to shutdown is a confusing allowance, requiring estimating when the shutdown will be completed, so that the Applicability time limit can be started appropriately. Any interruption in the shutdown process can cause the plant to stop the de-inerting process and re-inert the containment in order to comply with the LCO. Such starting and stopping is an Operator distraction that is not warranted.
5.0 Regulatory Analysis 5.1 No Significant Hazards Consideration The TSTF has evaluated whether or not a significant hazards consideration is involved with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:
: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The Containment Atmosphere Dilution (CAD) system and primary containment oxygen concentration are not initiators to any accident previously evaluated. The Required Actions taken when a drywell cooling system fan, or when two primary containment and drywell hydrogen igniter divisions are inoperable are not initiators to any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The CAD system, drywell cooling system fans, and primary Page 9 of 12

TSTF-478, Rev. 1 containment and drywell hydrogen igniters are used to mitigate the consequences of an accident. However, the revised 10 CFR 50.44 no longer defines a design basis accident (DBA) hydrogen release and the Commission has subsequently found that the DBA loss of coolant accident (LOCA) hydrogen release is not risk significant. In addition, CAD has been determined to be ineffective at mitigating hydrogen releases from the more risk significant beyond design basis accidents that could threaten containment integrity. This is similar to the Staffs conclusion relative to hydrogen recombiners. Therefore, elimination of the CAD system will not significantly increase the consequences of any accident previously evaluated.
The consequences of an accident while relying of the revised Required Actions for primary containment oxygen concentration, drywell cooling system fans, and primary containment and drywell hydrogen igniters are no different than the consequences of the same accidents under the current Required Actions. As a result, the consequences of any accident previously evaluated is not significantly increased.
Therefore, the proposed changes do 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.
No new or different accidents result from utilizing the proposed change. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation, except for the elimination of the CAD system. The CAD system is not considered an accident precursor, nor does its existence or elimination have any adverse impact on the pre-accident state of the reactor core or post accident confinement of radionuclides within the containment building from any design basis event. In addition, the changes do not impose any new or different requirements. The changes to the Technical Specifications do not alter assumptions made in the safety analysis, but reflect changes to the safety analysis requirements allowed under the revised 10 CFR 50.44. The proposed changes are consistent with the revised safety analysis assumptions.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
: 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
The Commission has determined that the DBA LOCA hydrogen release is not risk significant and is not required to be assumed in the plants accident analyses. The proposed changes reflect this new position and, in light of the remaining plant equipment, instrumentation, procedures, and programs that provide effective mitigation of and recovery from reactor Page 10 of 12

TSTF-478, Rev. 1 accidents, including postulated beyond design basis events, does not result in a significant reduction in a margin of safety.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Based on the above, the TSTF concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.
5.2 Applicable Regulatory Requirements/Criteria The proposed changes revise the ISTS to reflect changes in the applicable regulatory requirements and criteria in 10 CFR 50.44.
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.
6.0 Environmental Consideration A review has determined that the proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.
7.0 References
: 1. Notice of Proposed Rulemaking, Federal Register: August 2, 2002 (Volume 67, Number 149), Proposed Rules, Page 50374-50383, Combustible Gas Control in Containment.
: 2. Final Rule, Federal Register: 68 FR 54141 (Volume 67, Number 149), September 16, 2003, Combustible Gas Control in Containment.
: 3. Letter from Thomas H. Boyce (NRC) to Technical Specification Task Force dated October 1, 2003, approving TSTF-447, Revision 1, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors.
Page 11 of 12

TSTF-478, Rev. 1 INSERT 1 The [Drywell Cooling System fans] ensure a mixed atmosphere for combustible gas control as required by 10 CFR 50.44 (b)(1). The [Drywell Cooling System fans] were originally designed to help mitigate the potential consequences of hydrogen generation following a Design Basis Accident (DBA) loss of coolant accident (LOCA). However, more recent studies have shown that the hydrogen release postulated from a DBA LOCA is not risk significant because it is not large enough to lead to early containment failure. The revised rule effective October 16, 2003, eliminated the design basis LOCA hydrogen release from 10 CFR 50.44 but retained the requirement for all containment types to have the capability for ensuring a mixed atmosphere in order to prevent local accumulation of detonable gases that could threaten containment integrity or equipment operating in a local compartment.
INSERT 2 With two primary containment and drywell igniter divisions inoperable, one igniter division must be restored to OPERABLE status within 7 days. In this condition, the ability to prevent an uncontrolled hydrogen ignition is reduced. However, severe accident management strategies employ other methods to control hydrogen concentrations and lower containment pressure to prevent overpressurization of the drywell and containment. In addition, the random ignition sources which could ignite the hydrogen after a buildup could also cause ignitions that help prevent the buildup of detonable hydrogen concentrations. The 7 day Completion Time is based on the low probability of the occurrence of a degraded core event that would generate hydrogen in amounts equivalent to a metal water reaction of 75% of the core cladding and the amount of time available after the event for operator action to prevent hydrogen accumulation or reduce containment pressure.
INSERT 3 The [Drywell Purge System] ensures a mixed atmosphere for combustible gas control as required by 10 CFR 50.44 (b)(1). The [Drywell Purge System] was originally designed to help mitigate the potential consequences of hydrogen generation following a Design Basis Accident (DBA)
LOCA. However, more recent studies have shown that the hydrogen release postulated from a DBA LOCA is not risk significant because it is not large enough to lead to early containment failure. The revised rule effective October 16, 2003, eliminated the design basis LOCA hydrogen release from 10 CFR 50.44, but retained the requirement for all containment types to have the capability for ensuring a mixed atmosphere in order to prevent local accumulation of detonable gases that could threaten containment integrity or equipment operating in a local compartment.
Page 12 of 12

TSTF-478, Rev. 1
[Drywell Cooling System Fans]
3.6.3.1 3.6 CONTAINMENT SYSTEMS LC0 3.6.3.1           Two [drywell cooling system fans] shall be OPERABLE.
APPLICABILITY:        MODES 1 and 2.
. ACTIONS CONDITION                        EQUIRED ACTION                 COMPLETION TIME A. One [required] [drywell   A.l       Restore,[required][drywell     30 days cooling system fan]                 cooling system fan] to inoperable.                         OPERABLE status.
B. Two [required] [drywell cooling system fans]
inoperable.
Restore one [required]         7 days
[drywell 'cooling system fan]
to OPERABLE status.
C. Required Action and        C.l      Be in MODE 3.                   12 hours associated Completion Time not met.
BWR/4 STS                                                                    Rev. 3.0, 03/31/04

TSTF-478, Rev. 1
[Drywell Cooling System Fans]
B 3.6.3.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.3.1 [Drywell Cooling System Fans]
BASES BACKGROUND            The [Drywell Cooling System fans] ensure a uniformly mixed post accident primary containment atmosphere, thereby minimizing the potential for local hydrogen burns due to a pocket of hydrogen above the flammable concentration.
The [Drywell Cooling System fans] are an Engineered Safetv Feature and are designed to withstand @ ~ o ~ o l a n b c d & (In0t ~ ipost       d accident environments without loss of function. The system has two independent subsystems consisting of fans, fan coil units, motors, controls, and ducting. Each subsystem is sized to circulate [500] scfm.
The [Drywell Cooling System fans] employ both forced circulation and natural circulation to ensure the proper mixing of hydrogen in primary containment. The recirculation fans provide the forced circulation to mix hydrogen while the fan coils provide the natural circulation by increasing the density through the cooling of the hot gases at the top of the drywell causing the cooled gases to gravitate to the bottom of the drywell. The two subsystems are initiated manually since flammability limits would not be reached until several days afte           ~3    Each subsystem is powered from a separate emergency p o w e z l y . Since each subsystem can provide 100% of the mixing requirements, the system will provide its design function with a worst case single active failure.
be restored to service manually by the operator. In the event of a loss of offsite power, all fan coil units, recirculating fans, and primary containment water chillers are transferred to the emergency diesels. The fan coil units and recirculating fans are started automatically from diesel power upon loss of offsite power.
APPLICABLE      p    ~    h [Drywell e      Cooling System fans] provide the capability for reducing the Hydrogen may accumulate in primary contai result of:
: a. A metal steam reaction between the zirconium fuel rod cladding and the reactor coolant or BWR14 STS                                B 3.6.3.1-1                               Rev. 3.0, 03/31/04

TSTF-478, Rev. 1
[Drywell Cooling System Fans]
B 3.6.3.1 BASES APPLICABLE SAFETY ANALYSIS (continued)
: b. Radiolytic decomposition of water in the Reactor Coolant System.
To evaluate the potential for drogen accumulation in primary containment followi                 the hydrogen generation as a function of (an  ac~;de-+Y     time following the ini              e accident is calculated. Conservative assumptions recommended by Reference 1 are used to maximize the amount of hydrogen calculated.
The Reference 2 calculations show that (hydrogen a s s d Y
                   - mechanical mixing was assumed in the analysis, two [Drywell Cooling System fans] are [required] to be OPERABLE (typically four to six fans
\
are required to keep the drywell cool during operation in MODE 1 or 2) by thie; LCO.
The [Drywell Cooling System fans] satisfy Criterion-10 CFR 5OV36(c)(2)(ii).
Two [Drywell Cooling System fans] must be OPERABLE to ensure operation of at least one fan in the event of a worst case single active failure. Each of these fans must be powered from an independent safety related bus.
Operation with at least one fan provides the capability of controlling the bulk hydrogen concentration in primary containment without exceeding the flammability limit.
APPLICABILITY     In MODES 1 and 2, the two [Drywell Cooling System fans] ensure the capability to prevent localized hydrogen concentrations above the flammability limit of 4.0 v/o in drywell, assuming a worst case single active failure.
                             . Also, because of the limited time in this MODE, the probability of an accident requiring the [Drywell Cooling System fans] is low.
Therefore, the [Drywell Cooling System fans] are not required in MODE 3.
BWR14 STS                           B 3.6.3.1-2                               Rev. 3.0, 03/31/04

TSTF-478, Rev. 1
[Drywell Cooling System Fans]
B 3.6.3.1 BASES APPLICABILITY (continued)
In MODES 4 and 5, the probability and consequences o f 6 X A ) a r e reduced due to the pressure and temperature limitations in these MODES. Therefore, the [Drywell Cooling System fans] are not required in these MODES.
ACTIONS           A.1 With one [required] [Drywell Cooling System fan] inoperable, the inoperable fan must be restored to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE fan is adequate to perform the hydrogen mixing function. However, the overall reliability is reduced because a single failure in the OPERABLE fan could result in reduced hydrogen mixing capability. The 30 day Completion Time is based on the ate hydrogen control operable, the ability to perform bilities must be verified by administrative means wit                        te hydrogen control capabilities are provided                        ment lnerting System or phere Dilution System]. The 1 hour Completion           ows a reasonable period of time to verify BWRl4 STS                           B 3.6.3.1-3                             Rev. 3.0, 03/31/04

TSTF-478, Rev. 1
[Drywell Cooling System Fans]
B 3.6.3.1 BASES ACTIONS (continued) fintinued operation is permitted with two [Drywell Cooling System fans]
inoperable for up to 7 days. Seven days is a reasonable time to allow G o C. 1 If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the L C 0 does not apply.
To achieve this status, the plant must be brought to at least MODE 3 within 12 hours. The allowed Completion Time of 12 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE       SR 3.6.3.1.I REQUIREMENTS Operating each [required] [Drywell Cooling System fan] for 2 15 minutes ensures that each subsystem is OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action.
The 92 day Frequency is consistent with the lnservice Testing Program Frequencies, operating experience, the known reliability of the fan motors and controls, and the two redundant fans available.
BWRI4 STS                             B 3.6.3.1-4                            Rev. 3.0, 03/31/04

TSTF-478, Rev. 1
[Drywell Cooling System Fans]
B 3.6.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)
Verifying that each [required] [Drywell Cooling System fan] flow rate is 2 [500] scfm ensures that each fan is capable of maintaining localized hydrogen concentrations below the flammability limit. The [ I 81 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the [ I 81 month Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. ]
REFERENCES      1. Regulatory Guide 1.7, Revision   [a. @
L
: 2. FSAR, Section [6.2.5].
BWRI4 STS                                                               Rev. 3.0, 03/31I04

TSTF-478, Rev. 1 Primary Containment Oxygen Concentration
                          -WaTg-          -- - - -                                                3.6.3.2 I     3.6.3.2     Primary Containment Oxygen Concentration L C 0 3.6.3.2            The primary containment oxygen concentration shall be < 4.0 volume percent.
APPLICABILITY:
ours after THER
[24] hours prior to
\ACTIONS CONDITION                          REQUIRED 'ACTION               COMPLETION TIME A. Primary containment              A.l    Restore oxygen                 @ hours oxygen concentration not within limit.
concentration to within limit.
to B. Required Action and                                                    8 hours associated Completion Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                    FREQUENCY SR 3.6.3.2.1          Verify primary containment oxygen concentration is     7 days within limits.
BWR/4 STS                                                                        Rev. 3.0, 03/31/04

TSTF-478, Rev. 1 Primary Containment Oxygen Concentration B 3.6.3.2 B 3.6 CONTAINMENT SYSTEMS B 3.6.3.2 Primary Containment Oxygen Concentration BASES BACKGROUND O                  T               h               e Reference 1 Final Rule removed the definition of a design-basis LOCA hvdrogen release and eliminated requirements for hvdrogen control svstems to mitigate such a release at currentlv-licensed nuclear power plants. However, the supporting analvsis for this rulemaking concluded that combustible gases produced bv bevond desian-basis accidents, involving both fuel-claddinq oxidation and core-concrete interaction, would be risk significant for plants with Mark I and I1 containments if not for the inerted containment atmosphere. Given the relativelv small volume and large zirconium inventorv, these containments, without inertinn, would have a high likelihood of failure from hvdrogen combustion due to the potentiallv large concentration of hvdrogen that a severe accident could cause. With the primary containment inert, that is, oxvgen concentration < 4.0 volume
\
percent Wol, a combustible mixture cannot be present in the primarv containment for anv hvdrogen concentration. Thus, the Final Rule required plants with Mark I and II containments to maintain the containment atmosphere with a low concentration of oxvaen (i.e., < 4.0 VIOLrendering it inert to combustion.
APPLICABLE             The Reference 1 czh&&m+evaluation         assumes that the primary SAFETY                 containment is inerted when an event with significant core damage ANALYSES               occurs. Thus, the hvdrogen assumed to be released to the ~ r i m a r y containment as a result of degraded core conditions is not likelv to produce combustible gas mixtures in the primary containment.
Primary containment oxygen concentration satisfies Criterion 2-44of 10 CFR 50.36(c)(2)(ii), as it provides defense in depth for beyond design BWR14 STS                               B 3.6.3.2-1                            Rev. 3.0, 08/01/03

TSTF-478, Rev. 1 Primary Containment Oxygen Concentration B 3.6.3.2 basis events that could result in combustible gas mixtures that could         I threaten containment integritv and lead to offsite radioloaical releases. I LC0           The primary containment oxygen concentration is maintained < 4.0 v/o to ensure that an-a bevond-design basis event that _canproduces significant amounts of hydrogen does not result in a combustible mixture inside primary containment.
APPLICABILITY The primary containment oxygen concentration must be within the specified limit when primary containment is i n e r t e d                 w The primary containment must be inert in MODE 1, since this is the condition with the highest probability of an event that could produce hydrogen.
BWRl4 STS                      B 3.6.3.2-2                             Rev. 3.0, 08/01/03

TSTF-478, Rev. 1 Primary Containment Oxygen Concentration B 3.6.3.2 BASES ACTIONS      A Note to the Actions permits the use of the rsrovisions of LC0 3.0.4.c.
This allowance permits entrv into the Mode of Applicabilitv while relving on the ACTIONS.
If oxygen concentration is 2 4.0 vlo at any time while operating in MODE I , 0 shtMcw+oxygen concentration must be restored to < 4.0 vlo within 24Z2_hours. Intentional entrv into the Condition and Required Actions is permitted durinca the reactor startup and shutdown process. The 2 4 z h o u r Completion Time is allowed when oxygen concentration is 2 4.0 vlo because of the low probability and long duration of an event that would generate significant amounts of hydrogen occurring during this period.
If oxygen concentration cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, power must be reduced MODE 2 #e+M$?h RTP within 8 hours. The 8 hour Completion Time is             I reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE SR 3.6.3.2.1 REQUIREMENTS The primary containment must be determined to be inert by verifying that oxygen concentration is < 4.0 vlo. The 7 day Frequency is based on the slow rate at which oxygen concentration can change and on other indications of abnormal conditions (which would lead to more frequent checking by operators in accordance with plant procedures). Also, this Frequency has been shown to be acceptable through operating experience.
REFERENCES    1.                    . . . Federal Reaister Notice 68 FR 54123, m       t    r    o      l in Containment, Final Rule. dated September 16, 2003.
BWR/4 STS                                                              Rev. 3.0, 08/01/03

TSTF-478, Rev. 1 CAD System SYSTEMS Atmosphere Dilution (CAD) System
            \
LC0 3.6.3.3        Two CAD subsystems shall be OPERABLE.
APPLICABILITY:       ODES 1 and 2.
CONDITION                  REQUIRED ACTlO            COMPLETION TIME A. One CAD subsystem                                        30 days inoperable.             A.1        PERABLE C Aatus.e m to B. [ Two CAD subsystems    B.                              1 hour inoperable.
Once per 12 hours thereafter Restore one CAD   \
                                     'subsystemto OPERABLE status.
7 days ]
I C.l      Be in MODE 3.
BWR14 STS                                                        Rev. 3.0, 0~131104

TSTF-478, Rev. 1 BWR/4 STS   Rev. 3.0,03/31/04

TSTF-478, Rev. 1 CAD System B 3.6.3.3 SYSTEMS Atmosphere Dilution (CAD) System BACKGROUND of two independent, a liquid nitrogen piping to The CAD System o               onjunction with emergency operating procedures that ar             uce primary containment pressure periodically dur                 operation. This combination results in a feed and bleed ap               ntaining hydrogen and oxygen concentrations
                              /
APPLICABLE                                                    accumulation in SAFETY                                                             oxygen generation ANALYSES                                                              of the accident).
a.
and oxygen may accumulate within p LOCA as a result of:
t A metal water reaction between the zirconium the reactor coolant or ary containment
: b. Radiolytic decomposition of water in the Reactor BWW4 STS                    B 3.6.3.3-1                             Rev. 3.0,03/31/04

TSTF-478, Rev. 1 CAD System B 3.6.3.3 BASES \
           \
LC0           Two CAD subsystems must be OPERABLE. This ensures least one CAD subsystem in the event of a worst case failure. Operation of at least one CAD subsystem is primary containment post-LOCA oxygen days.
APPLICABILITY d
DES 1 and 2, the CAD System is required to main In the oxygen within primary containment below the fla mability limit of a LOCA. This ensures that the rela ' e leak tightness of is adequate and prevents da ge to safety related located within prima containment.
ction rates and the total an those calculated for analysis were to be e time to reach a flammable concent conservatively calc                                2. The extended time would other means and also al CAD were not available.
OPERABLE in MODE 3, In MODES 4 and                                                 of a LOCA are reduced due to MODES.
MODES 4 and 5.
ACTIONS bsystem is inoperable, it must 30 days. In this Condition, the             g OPERABLE CAD adequate to perform the oxygen II reliability is reduced because a s LE subsystem could result in reduced ay Completion Time is based on the I rence of a LOCA that would generate nts capable of exceeding the flamma available after the event for operator action limit, and the availability of the OPERABLE BWR/4 STS                                                                      Rev. 3.0, 03/31/04

TSTF-478, Rev. 1 CAD System B 3.6.3.3  /
   \
BASES perform the hydrogen RIS NOTE------   ------.--- ----- -------
Technical Specification alternate justify this Condition: In addition, the apability must be verified once per ts continued availability.
k by examining logs or other subsystems inoperable for to allow two CAD he occurrence of a the flammability limit.
   /
With two CAD subsystems inoperable, one CAD restored to OPERABLE status within 7 days.
is based on the low probability of the generate hydrogen in the amounts limit, the amount of time available prevent exceeding this limit, and mitigating systems.      '
BWR14 STS                    B 3.6.3.3-3                               Rev. 3.0, 03/31/04

TSTF-478, Rev. 1 CAD System B 3.6.3.3 uired Action cannot be met within the e plant must be brought to a MODE in o achieve this status, the plant must b within 12 hours. The allowed Compl le, based on operating experience, t ditions in an orderly manner and w SURVEILLANCE REQUIREMENTS en supply in the CAD CAD operation. This s sufficient time after an accident g term inerting. This is verified m is capable of performing its uency is based on shown 31 days to be an acceptable e availability of other J
Verifying the c rect alignment automatic v es in each of the          subsystem flow paths provides assurance at the proper flow                       stem operation. This SR does no pply to valves that a positi , since these valves w to lo ing, sealing, or securing.
Ive is also allowed to be in the nonacci       osition provided it can ligned to the accident position within th       assumed in the cc~dentanalysis, This is acceptable beca manually initiated. This SR does not apply to v inadvertently misaligned, such as check valves.
any testing or valve manipulation; rather, it involves valves capable of being mispositioned are in the co BWR14 STS                       B 3.6.3.3-4                             Rev. 3.0, 03131104

TSTF-478, Rev. 1 CAD System B 3.6.3.3 BWRM STS  Rev. 3.0, 03131104

TSTF-478, Rev. 1 Primary Containment and Drywell Hydrogen lgnitors 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1      Primary Containment and Drywell Hydrogen lgnitors LC0 3.6.3.1            Two divisions of primary containment and drywell hydrogen ignitors shall be OPERABLE, each with > 90% of the associated ignitor assemblies OPERABLE.
APPLICABILITY:         MODES 1 and 2.
ACTIONS CONDITION                      REQUIRED ACTION               1   COMPLETION TIME A. One primary                  A.1      Restore primary                  30 days containment and drywell              containment and drywell.
hydrogen ignitor division            hydrogen ignitor dlvision.to inoperable.                          OPERABLE status.
: 8. Two primary containment and drywell hydrogen ignitor divisions inoperable.
B.@      Restore one primary              7 days b     containment and drywell hydrogen ignitor division to OPERABLE status.
C. Required Action and associated Completion C.l      Be in MODE 3.                 1  12 hours Time not met.
BWR16 STS                                                                       Rev. 3.0, 03131104

TSTF-478, Rev. 1 Primary Containment and Drywell Hydrogen Ignitors B 3.6.3.1 BASES APPLICABLE    The hydrogen ignitors cause hydrogen in containment to burn in a SAFETY        controlled manner as it accumulates following a degraded core accident ANALYSES      (Ref. 3). Burning occurs at the lower flammability concentration, where the resulting temperatures and pressures are relatively benign. Without the system, hydrogen could build up to higher concentrations that could result in a violent reaction if ignited by a random ignition source after such a buildup.
The hydrogen ignitors are not included for mitigation of a Design Basis Accident (DBA) because an amount of hydrogen equivalent to that generated from the reaction of 75% of the f u d cladding with water is far in probabilistkrisk analysis to be a significant contributor to limiting the severity of accident sequences that are commonly found to dominate risk for units with Mark Ill containment.
The hydrogen ignitors satisfy Criterion 4 of 10 CFR 50.36(c)(2)(ii).
Two divisions of primary containment and drywell hydrogen ignitors must be OPERABLE, each with more than 90% of the ignitors OPERABLE.
This ensures operation of at least one ignitor division, with adequate coverage of the primary containment and drywell, in the event of a worst case single active failure. This will ensure that the hydrogen concentration remains near 4.0 v/o.
APPLICABILITY In MODES 1 and 2, the hydrogen ignitor is required to control hydrogen concentration to near the flammability limit of 4.0 v/o following a degraded core event that would generate hydrogen in amounts equivalent to a metal water reaction of 75% of the core cladding. The control of hydrogen concentration prevents overpressurization of the primary containment. The event that could generate hydrogen in quantities sufficiently high enough to exceed the flammability limit is limited to MODES 1 and 2.
In MODE 3, both the hydrogen production rate and the total hydrogen a degraded core accident would be less than that Also, because of the limited time in this MODE, the probability of an accident requiring the hydrogen ignitor is low.
Therefore, the hydrogen ignitor is not required in MODE 3.
In MODES 4 and 5, the probability and consequences of a degraded core accident are reduced due to the pressure and temperature limitations.
Therefore, the hydrogen ignitors are not required to be OPERABLE in MODES 4 and 5 to control hydrogen.
BWR/6 STS                        B 3.6.3.1-2                               Rev. 3.0, 03/31/04

TSTF-478, Rev. 1 Primary Containment and Drywell Hydrogen Ignitors B 3.6.3.1 BASES ACTIONS    Ad With one hydrogen ignitor division inoperable, the inoperable division must be restored to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE hydrogen ignitor division is adequate to perform the hydrogen burn function. However, the overall reliability is reduced because a slngle fbilure in the OPERABLE subsystem could result in reduced hydrogen control capability. The 30 day Completion Time is based on the low probability of the occurrence of a degraded core event that would generate hydrogen in amounts equivalent to a metal water reaction of 75% of the core cladding, the amount of time available after the event for operator action to prevent hydrogen accumulation from exceeding the flammability limit, and the low probability of failure of the OPERABLE hydrogen ignitor division.
continued operatio LOCA that would generate h xceeding the flammability limit.
If any Required Action and required Completion Time cannot be met, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant mdst be brought to at least MODE 3 within 12 hours. The allowed Completion Time of 12 hours is reasonable, based on operating experience, to reach MODE 3 from ful\ power conditions in an orderly manner and without challenging plant systems.
BWRI6 STS                    B 3.6.3.1-3                             Rev. 3.0, 03/31/04

TSTF-478, Rev. 1
[Drywell Purge System]
B 3.6.3.2 B 3.6 CONTAINMENT SYSTEMS B 3.6.3.2 [Drywell Purge System]
BASES BACKGROUND           The [Drywell Purge System] ensures a uniformly mixed post accident containment atmosphere, thereby minimizing the potential for local hydrogen burns due to a pocket of hydrogen above the flammable concentration.
The [Drywell Purge System] is an Engineered Safety Feature and is designed to operate 'following a loss of coolant accident (LOCA) in post accident environments without loss of function. The system has two independent subsystems, each consisting of a compressor and associated valves, controls, and piping. Each subsystem is sized to pump [500] scfm. Each subsystem is powered from a separate emergency power supply. Since each subsystem can provide 100% of the mixing requirements, the system will provide its design function with a worst case single active failure.
Following a LOCA, the drywell is immediately pressurized due to the release of steam into the drywell environment. This pressure is relieved by the lowering of the water level within the weir wall, clearing the drywell vents and allowing the mixture of steam and noncondensibles to flow into the primary containment through the suppression pool, removing much of the heat from the steam. The remaining steam in the drywell begins to condense as steam flow from the reactor pressure vessel ceases, the drywell pressure falls rapidly. Both drywell purge compressors start automatically 30 seconds after a LOCA signal is received from the Emergency Core Cooling System instrumentation, but only when drywell pressure has decreased to within approximately [0.087] psi above primary containment pressure. This ensures the blowdown from the drywell to the primary containment is complete. The drywell purge compressors force air from the primary containment into the drywell. Drywell pressure increases until the water level between the weir wall and the drywell is forced down to the first row of suppression pool vents forcing drywell atmosphere back into containment and mixing with containment atmosphere to dilute the hydrogen.
BWR/6 STS                               B 3.6.3.2-1                              Rev. 3.0, 03/31/04

TSTF-478, Rev. 1
[Drywell Purge System]
B 3.6.3.2 ANALYSES Hydrogen may accumulate in primary containment following result of:
: a. A metal steam reaction between the zirconium fuel rod cladding and the reactor coolant and
: b. Radiolytic decomposition of water in the Reactor Coolant System and drywell sump.
he accident is calculated.
Reference 1 are used to The [Drywell Purge System] satisfies Criterion @of I 0 CFR 50.36(c)(2)(ii).
Two [drywell purge] subsystems must be OPERABLE to ensure operation of at least one primary containment [drywell purge] subsystem in the event of a worst case single active failure. Operation with at least one OPERABLE [drywell purge] subsystem provides the capability of controlling the hydrogen concentration in the drywell without exceeding the flammability limit.
APPLICABILITY In MODES 1 and 2, the two [drywell purge] subsystems ensure the capability to prevent localized hydrogen concentrations above the flammability limit of 4.0 v/o in the drywell, assuming a worst case single production rate and the total hydro en would be less than that calculated fork*)
                      . Also, because of the limited time in this MODE, the probability of an accident requiring the [Drywell Purge System] is low. Therefore, the
[Drywell Purge System] is not required in MODE 3.
BWRI6 STS                        B 3.6.3.2-2                               Rev. 3.0, 03/31/04

TSTF-478, Rev. 1
[Drywell Purge System]
B 3.6.3.2 BASES APPLICABILITY (continued) tJ In MODES 4 and 5, the probability and consequences o f m a r e reduced due to the pressure and temperature limitations in these MODES. Therefore, the [Drywell Purge System] is not required in these MODES.
ACTIONS With one [drywell purge] subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE subsystem is adequate to perform the drywell purge function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced drywell purge capability. The 30 day Completion Time is based on h availability of the second subsystem, the low probability of e i ! ! t h a t would generate hydrogen in amounts capable of exceeding the flammability limit, and the amount of time available after the event for a    ac~denf operator action to prevent hydrogen accumulation from exceeding this limit.
B.l and B.2 REV1EWER'S NOTE--------------------------- -----
This Condition is only allowed for units with an alternate hydrogen control system acceptable to the technical staff.
With two [drywell purge] subsystems inoperable, the ability to perform the hydrogen control function via alternate capabilities must be verified by administrative means within 1 hour. The alternate hydrogen control capabilities are provided by [one division of the hydrogen ignitors]. The 1 hour Completion Time allows a reasonable period of time to verify that a loss of hydrogen control function does not exist.
                  ................................... REV1EWER'S NOTE...................................
The following is to be used if a non-Technical Specification alternate hydrogen control function is used to justify this Condition: In addition, the alternate hydrogen control system capability must be verified once per 12 hours thereafter to ensure its continued availability.
BWR/6 STS                                    B 3.6.3.2-3                           Rev. 3.0, 03/31/04

TSTF-478, Rev. 1
[Drywell Purge System]
B 3.6.3.2 BASES ACTIONS (continued)
[Both] the [initial] verification may [and all subsequent verifications] may be performed as an administrative check by examining logs or other information to determine the availability of the alternate hydrogen control system. It does not mean to perform the surveillances needed to demonstrate OPERABILITY of the alternate hydrogen control system. If the ability to perform the hydrogen control function is maintained, continued operation is permitted with two [drywell purge] subsystems inoperable for up to 7 days. Seven days is a reasonable time to allow two
[drywell purge] subsystems to be inoperable because the hydrogen control function is maintained and because of the low probability of the occurrence ow h a t would generate hydrogen in amounts capable of exceeding the flammability limit.
If any Required Action and the required Completion Time cannot be met, the plant must be brought to a MODE in which the LC0 does not apply.
To achieve this status, the plant must be brought to at least MODE 3 within 12 hours. The allowed Completion Time of 12 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE      SR 3.6.3.2.1 REQUIREMENTS Operating each [drywell purge] subsystem for 1 15 minutes ensures that each subsystem is OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, compressor failure, or excessive vibration can be detected for corrective action. The 92 day Frequency is consistent with lnservice Testing Program Frequencies, operating experience, the known reliability of the compressor and controls, and the two redundant subsystems available.
Verifying that each [drywell purge] subsystem flow rate is 2 [500] scfm ensures that each subsystem is capable of maintaining drywell hydrogen concentrations below the flammability limit. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the [I81 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. ]
B W / 6 STS                           B 3.6.3.2-4                            Rev. 3.0, 03/31/04

TSTF-478, Rev. 1
[Drywell Purge System]
B 3.6.3.2 BASES REFERENCES 1. Regulatory Guide 1.7, Revision R, s  d P[    6 ~ >
BWR/6 STS                                         Rev. 3.0, 03/31/04}}