ML14183A944: Difference between revisions

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#REDIRECT [[NRC-2014-0035, License Amendment Request (LAR) 275, Application to Revise Technical Specifications Task Force (TSTF) Traveler TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process]]
| number = ML14183A944
| issue date = 07/02/2014
| title = License Amendment Request (LAR) 275, Application to Revise Technical Specifications Task Force (TSTF) Traveler TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process
| author name = McCartney E
| author affiliation = NextEra Energy Point Beach, LLC
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000266, 05000301
| license number = DPR-024, DPR-027
| contact person =
| case reference number = GL-08-001, NRC-2014-0035
| document type = Letter, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specifications
| page count = 52
| project =
| stage = Request
}}
 
=Text=
{{#Wiki_filter:July 2, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant Units 1 and 2 Docket Nos. 50-266 and 50-301 NEXT era*** POINT BEACH NRC-2014-0035 10 CFR 50.90 Renewed Facility Operating Licenses Nos. DPR-24 and DPR-27 License Amendment Request (LAR) 275 , Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-523. "Generic Letter 2008-01. Managing Gas Accumulation." Using the Consolidated Line Item Improvement Process References
: 1. Letter from NextEra Energy Point Beach, LLC , to Document Control Desk (NRC), "Response to Request for Additional Information Regarding Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal , and Containment Spray Systems," dated October 24, 2009 (ML093000085)
Pursuant to 10 CFR 50.90, NextEra E nergy Point Beach , LLC (NextEra) is submitting a request for amendment to the Technical Specifications for Point Beach Nuclear Plant (Point Beach), Units 1 and 2. The proposed amendment modifies TS requirements to address NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal , and Containment Spray Systems," as desc r ibed in TSTF-523 , Revision 2, " Generic Letter 2008-01, Managing Gas Accumulation
." NextEra committed to submit this proposed change in Reference
: 1. Attachment 1 provides a description and assessment of the proposed change. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides existing TS Bases pages marked to show the proposed change. Changes to the existing TS Bases, consistent with the technical and regulatory analyses , will be implemented under the Technical Specification Bases Control Prog r am. They are provided in Attachment 4 for information only. Approval of the proposed amendment is requested by February 28, 2015. NextEra will implement the amendment within 90 days upon receipt of the approved amendment.
NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers , WI 54241 Document Control Desk NRC 2014-0035 Page 2 of 2 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Wisconsin Official.
This application has been reviewed by the Point Beach Plant Operations Review Committee.
This letter satisfies NextEra's commitment made in Reference 1 and makes no new commitments or changes to any other existing commitments.
If you have any questions or require additional information, please contact Michael Millen at (920) 755-7845. I declare under penalty of perjury that the foregoing is true and correct. Executed on July 2, 2014. Eric McCartney Site Vice President NextEra Energy Point Beach, LLC Attachments: 1 . Description and Assessment
: 2. Proposed TS Changes (marked up pages) 3. Proposed TS Changes (clean typed pages) 4. Proposed TS Bases C h anges (marked up pages)-For Information Only cc: USNRC Regional Administrator Region Ill USNRC Project Manager, Point Beach Nuclear Plant USNRC Resident Inspector, Point Beach Nuclear Plant State of Wisconsin PSCW NextEra Energy Point Beach , LLC, 6610 Nuclear Road , Two Rivers , WI 54241 License Amendment Request for NRC 2014-0035 Attachment 1 Adoption of Technical Specifications Task Force Traveler TSTF-523, Revision 2 Generic Letter 2008-01, Managing Gas Accumulation
 
==1.0 DESCRIPTION==
 
===2.0 ASSESSMENT===
 
Attachment 1 Point Beach Description and Assessment
 
===2.1 Applicability===
 
of Published Safety Evaluation
 
===2.2 Optional===
Changes and Variations
 
===3.0 REGULATORY===
 
ANALYSIS 3.1 No Significant Hazards Consideration
 
===4.0 ENVIRONMENTAL===
 
EVALUATION
 
==5.0 REFERENCES==
 
Page 1 of 5 
 
==1.0 DESCRIPTION==
 
A TT ACHM E NT 1 D ES CRIPTION AND ASS ESS M E NT NRC 2014-0035 Attachment 1 The proposed change revises and adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.
The changes are being made to address the concerns discussed in NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," [Reference 2]. The proposed amendment is consistent with Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, " Generic Letter 2008-01 , Managing Gas Accumulation" [Reference 3]. 2.0 ASSESSMENT
 
===2.1 Applicability===
 
of Published Safety Evaluation NextEra Energy Point Beach, LLC (NextEra) has reviewed the model safety evaluation published January 15, 2014 as part of the Federal Register Notice of Availability
" TSTF-523, Generic Letter 2008-01 Managing Gas Accumulation Using the Consolidated Line Item Improvement Process" (79 FR 2700) [Reference 4]. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-523.
As described in the subsequent paragraphs, NextEra has concluded that the justifications presented in the TSTF-523 proposal and the model safety evaluation prepared by the NRC staff are applicable to Point Beach Nuclear Plant (Point Beach) and justify this amendment for incorporation of the changes to the Point Beach Technical Specifications (TS). 2.2 Optional Changes and Variations NextEra is proposing the following variations from the TS changes described in the TSTF-523, Revision 2 [Reference 3], or the applicable parts of the NRC staff's model safety evaluation.
The Point Beach TS utilize different numbering than NUREG-1431, Standard Technical Specifications Westinghouse Plants [Reference 5] on which TSTF-523 was based. Specifically, the numbering differences are provided in the table below. NUREG-1431 Point Beach Standard Technical Specifications Technical Specifications Westinghouse Plant 3.9.5 , RHR and Coolant Circulation
-3.9.4 , RHR and Coolant Circulation-Hiqh Water Level Hiqh Water Level 3.9.6 , RHR and Coolant Circulation
-3.9.5, RHR and Coolant Circulation
-Low Water Level Low Water Level These differences are editorial and do not affect the applicability of TSTF-523 to Point Beach. Page 2 of 5 NRC 2014-0035 Attachment 1 TSTF-523 and the model safety evaluation discuss the applicable regulatory requirements and guidance including the1 0 CFR 50, Appendix A, General Design Criteria (GDC). Point Beach Units 1 and 2 were not licensed to the 10 CFR 50, Appendix A, GDC. The Point Beach design criteria are discussed in the Updated Final Safety Analysis Report (UFSAR) Section 1.3, General Design Criteria.
The Point Beach design criteria that equates to GDC 1 are addressed in UFSAR Section 1.3.1, Overall Plant Requirements (GDC 1 -GDC 5) and the design criteria that equates to GDC 34 through GDC 40 are addressed in UFSAR Section 1.3.7, Engineered Safety Features (GDC 37 -GDC 65). This difference does not alter the conclusion that the proposed change is applicable to Point Beach Units 1 and 2. 3.0 REGULATORY SAFETY ANALYSIS 3.1 No Significant Hazards Consideration Determination NextEra Energy Point Beach, LLC (NextEra) requests adoption of Technical Specification Task Force Traveler (TSTF) 523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," which is an approved change to the standard technical specifications (STS), into the Point Beach Nuclear Plant Units 1 and 2 Technical Specifications (TS). The proposed change revises and adds Surveillance Requirements (SR) to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.
NextEra has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below: 1: Does the Proposed Change Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated?
Response:
No The proposed change revises and adds SRs that require verification that the Emergency Core Cooling System (ECCS), Residual Heat Removal (RHR) System, and the Containment Spray System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification.
Gas accumulation in the subject systems is not an initiator of any accident previously evaluated.
As a result, the probability of any accident previously evaluated is not significantly increased.
The proposed SRs ensure that the subject systems continue to be capable of performing their assumed safety function and are not rendered inoperable due to gas accumulation.
Thus, the consequences of any accident previously evaluated are not significantly increased.
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 Page 3 of 5 NRC 2014-0035 Attachment 1 The proposed change revises and adds SRs that require verification that the ECCS, RHR System, and Containment Spray System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification.
The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.
In addition, the proposed change does not impose any new or different requirements that could initiate an accident.
The proposed change does not alter assumptions made in the safety analysis and is consistent with the safety analysis assumptions.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Does the Proposed Change Involve a Significant Reduction in a Margin of Safety? Response: No The proposed change revises or adds SRs that require verification that the ECCS, RHR System, and Containment Spray System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification.
The proposed change adds new requirements to manage gas accumulation in order to ensure that the subject systems are capable of performing their assumed safety functions.
The proposed SRs are more comprehensive than the current SRs and will ensure that the assumptions of the safety analysis are protected.
The proposed change does not adversely affect any current plant safety margins or the reliability of the equipment assumed in the safety analysis.
Therefore , there are no changes being made to any safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. Therefore, the proposed change does not involve a significant reduction in a margin of safety. Based on the above, NextEra 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. 4.0 ENVIRONMENTAL EVALUATION 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 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. Page 4 of 5 
 
===5.0 REFERE===
NC ES NRC 2014-0035 Attachment 1 1. Letter (NRC 2009-0099) from L. Meyer (NextEra Energy Point Beach, LLC) to Document Control Desk (NRC), "Response to Request for Additional Information Regarding Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal , and Containment Spray Systems," October 24, 2009 (ADAMS Accession No. ML093000085)
: 2. Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," January 11, 2008, (ADAMS Accession No. ML07291 0759) 3. Technical Specifications Task Force Traveler {TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," February 21, 2013, (ADAMS Accession No. ML 13053A075)
: 4. Federal Register Notice of Availability, "TSTF-523, Generic Letter 2008-01 Managing Gas Accumulation Using the Consolidated Line Item Improvement Process" published January 15, 2014 (79 FR 2700) 5. NUREG-1431, Revision 4, Standard Technical Specifications -Westinghouse Plants, April 2012 (ADAMS Accession No. ML 121 OOA222) Page 5 of 5 License Amendment Request for NRC 2014-0035 Attachment 2 Adoption of Technical Specifications Task Force Traveler TSTF -523, Revision 2 Generic Letter 2008-01, Managing Gas Accumulation Attachment 2 Point Beach Technical Specifications Changes Marked Up Pages This coversheet plus 8 pages 
..,j UJ 0 0 ::2: 0> c *c Q) c Q) .... Q) 1'\ij i (f) I L.. ! 5 I ..C. IN I ..... I= w-1--§ 0-ol ZQ)l E i .g, Q) i ..o: 0 I ! o-1 I .,_, I o I Zl CONDITION B. One required RHR loop B.1 inoperable. AND Two required RCS loops inoperable.
C. Required RCS or RHR C.1 loops inoperable. OR No RCS or RHR loop in AND operation.
C.2 REQUIRED ACTION Be in MODE 5. Suspend all operations involving a reduction of RCS boron concentration.
RCS Loops-MOD E 4 3.4.6 COMPLETION TIME 24 hours Immediately Initiate action to restore Immediately one loop to OPERABLE status and operation . SURVEILLANCE REQUIREMENTS SR 3.4.6.1 SR 3.4.6.2 SR 3.4.6.3 SURVEILLANCE FREQUENCY Verify one RHR or RCS loop is in operation. 12 hours Verify SG secondary side water levels are :::::: 35% 12 hours narrow range for required RCS loops. Verify correct breaker alignment and indicated 7 days power are available to the required pump that is not in operation .
SR 3.4.7.3 Point Beach RCS Loops-MOD E 5, Loops Filled 3.4.7 SURVEILLANCE Verify correct breaker alignment and indicated power are available to the required RHR pump that is not in operation.
Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water. FREQUENCY 7 days 31 days 3.4.7-3 Unit 1 -Amendment No. re4-Unit 2 -Amendment No.
ACTIONS (continued)
CONDITION B. Required RHR loops inoperable.
OR No RHR loop in operation.
B.1 RCS Loops-MODE 5, Loops Not Filled 3.4.8 REQUIRED ACTION Suspend all operations involving reduction in RCS boron concentration.
COMPLETION TIME Immediately B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.
SURVEILLANCE REQUIREMENTS SR 3.4.8.1 SR 3.4.8.2 Point Beach SURVEILLANCE Verify one RHR loop is in operation.
Verify correct breaker alignment and indicated power are available to the required RHR pump that is not in operation.
FREQUENCY 12 hours 7 days 3.4.8-2 Unit 1 -Amendment No. Unit 2-Amendment No.
en 0 ..... -c 0 (.) Q) > ro ..... -.!!? c I .E "0 ro ..... Q) I "0 c :::J "0 Q) c Q) a. 0 en ..c -ro wa.. I-3: 0 0 zt+= -c Q) > E Q) -en >. en ..... .E -Q) E I Q) .0 0 -"0 Q) ..... *s 0' Q) ..... -0 z 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS-Operating LCO 3.5.2 Two ECCS trains shall be OPERABLE.
ECCS -Operating 3.5.2 --------------------------------------
N 0 T E ------------------------------
----------In MODE 3 both safety injection (SI) pump flow paths may be ' isolated by closing the isolation valves for up to 2 hours to perform pressure isolation valve testing per SR 3.4.14.1.
------------------------------------------------
-------------------------------------
APPLICABILITY:
MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ECCS train A.1 Restore train to 72 hours inoperable.
OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
...... SR 3.5.2.1 . / Venfy each ECCS manual, power operated, and 31 days automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.
SR 3.5.2.2 Verify ECCS pi p i n g i s f u ll of watsr. 31 days "' (continued)
' ' ' l ocations susceptible to gas accumulation are sufficientlv filled with water. Point Beach 3.5.2-1 Unit 1 -Amendment No. Unit 2-Amendment Containment Spray and Cooling Systems 3.6.6 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D. One required accident D.1 Restore required 72 hours fan cooler unit service accident fan cooler unit water outlet valve outlet valve to AND inoperable.
OPERABLE status. 144 hours from discovery of failure to meet the LCO E. Required Action and E.1 Be in MODE 3. 6 hours associated Completion Time of Condition C AND or D not met. E.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
...... , SR 3.6.6.1 Verify each containment spray manual, power 31 days operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.
SR 3.6.6.2 Operate each containment cooling accident fan. 31 days \ -------------------------------NOTE
------------
--------------------------(continued)
Not required to be met for system vent flow paths opened under administrative controls.
------------------------------------------------------------------------------
>. Point Beach 3.6.6-2 Unit 1 -Amendment Unit 2-Amendment Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE SR 3.6.6.3 SR 3.6.6.4 SR 3.6.6.5 SR 3.6.6.6 SR 3.6.6.7 SR 3.6.6.8 SR 3.6.6.9 SR 3.6.6.10 Point Beach SURVEILLANCE Verify each containment fan cooler unit can achieve a cooling water flow rate within design limits with a fan cooler service water outlet valve open. Verify each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head. Verify each automatic containment spray and containment fan cooler unit service water outlet valve in the flow path that is not locked, sealed, or otherwise secured in position , actuates to the correct position on an actual or simulated actuation signal. Verify each containment spray pump starts automatically on an actual or simulated actuation signal. Verify each containment fan cooler unit accident fan starts automatically on an actual or simulated actuation signal. Verify proper operation of the accident fan cooler unit backdraft dampers. Verify each spray nozzle is unobstructed.
Verify containment spray locations susceptible to gas accumulation are sufficiently filled with water. FREQUENCY 31 days In accordance with the lnservice Testing Program 18 months 18 months 18 months 18 months 10 years 31days 3.6.6-3 Unit 1 -Amendment Unit 2-Amendment No. -2B6 RHR and Coolant Circulation-High Water Level 3.9.4 SURVEILLANCE REQUIREMENTS SR 3.9.4.1 SR 3.9.4.2 Point Beach SURVEILLANCE Verify one RHR loop is in operation.
Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water. FREQUENCY 12 hours 3.9.4-2 Unit 1 -Amendment No. Unit 2-Amendment RHR and Coolant Circulation
-Low Water Level 3.9.5 SURVEILLANCE REQUIREMENTS SR 3.9.5.1 SR 3.9.5.2 SR 3.9.5.3 Point Beach SURVEILLANCE Verify one RHR loop is in operation. Verify correct breaker alignment and indicated power available to the required RHR pump that is not in operation.
Verify RHR loop locations susceptible to gas accumulation are sufficient l y filled with water. FREQUENCY 12 hours 7 days 3.9.5-2 Unit 1 -Amendment No. Unit 2-Amendment No. 2 License Amendment Request for NRC 2014-0035 Attachment 3 Adoption of Technical Specifications Task Force Traveler TSTF-523, Revision 2 Generic Letter 2008-01, Managing Gas Accumulation Attachment 3 Point Beach Technical Specifications Changes Typed Clean Pages This coversheet plus 10 pages ACTIONS (continued)
CONDITION B. One required RHR loop B.1 inoperable.
AND Two required RCS loops inoperable. C. Required RCS or RHR C.1 loops inoperable. OR No RCS or RHR loop in AND operation. C.2 SURVEILLANCE REQUIREMENTS REQUIRED ACTION Be in MODE 5. Suspend all operations involving a reduction of RCS boron concentration. RCS Loops-MODE 4 3.4.6 COMPLETION TIME 24 hours Immediately Initiate action to restore Immediately one loop to OPERABLE status and operation.
SURVEILLANCE FREQUENCY SR 3.4.6.1 SR 3.4.6.2 SR 3.4.6.3 Point Beach Verify one RHR or RCS loop is in operation. 12 hours Verify SG secondary side water levels are ;:::: 35% 12 hours narrow range for required RCS loops. Verify correct breaker alignment and indicated 7 days power are available to the required pump that is not in operation.
3.4.6-2 (continued)
Unit 1 -Amendment No. Unit 2 -Amendment No.
RCS Loops-MODE 4 3.4.6 SURVEILLANCE REQUIREMENTS (continued)
SR 3.4.6.4 Point Beach SURVEILLANCE
-------------------------
N 0 TE -------------------------
Not required to be performed until 12 hours after entering MODE 4. Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water. FREQUENCY 31 days 3.4.6-3 Unit 1 -Amendment No. Unit 2-Amendment No.
RCS Loops-MOD E 5, Loops Fill e d 3.4.7 SURVEILLANCE REQUIREMENTS (continued)
SR 3.4.7.3 SR 3.4.7.4 Point Beach SURVEILLANCE Verify correct breaker alignment and indicated power are available to the required RHR pump that is not in operation. Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water. FREQUENCY 7 days 31 days 3.4.7-3 Unit 1 -Amendment No. Unit 2 -Amendment No.
RCS Loops-MODE 5 , Loops Not Filled 3.4.8 ACTIONS (continued)
CONDITION B. Required RHR loops inoperable.
OR No RHR loop in operation. B.1 AND REQUIRED ACTION Suspend all operations i nvolving reduction in RCS boron concentration. COMPLETION TIME Immediately B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation. SURVEILLANCE REQUIREMENTS SR 3.4.8.1 SR 3.4.8.2 SR 3.4.8.3 Point Beach SURVEILLANCE Verify one RHR loop is in operation. Verify correct breaker alignment and indicated power are available to the required RHR pump that is not in operation. Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water. FREQUENCY 12 hours 7 days 31 days 3.4.8-2 Unit 1 -Amendment No. Unit 2 -Amendment No. 
 
===3.5 EMERGENCY===
 
CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS-Operating L CO 3.5.2 Two ECCS trains shall be OPERABLE.
ECCS-Operating 3.5.2 ------------------
-------------------
-NOTE--------------------
--------------------In MODE 3 , both safety injection (SI) pump flow paths may be isolated by closing the isolation valves for up to 2 hours to perform pressure isolation valve testing per SR 3.4.14.1. APPLICABILITY:
MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION A. One ECCS train A.1 Restore train to inoperable. OPERABLE status. B. Required Action and B.1 Be in MODE 3. associated Completion Time not met. AND B.2 Be in MODE 4. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.5.2.1 -------------------------N 0 T E -------------------------
Not required to be met for system vent flow paths opened under administrative controls.
COMPLETION TIME 72 hours 6 hours 12 hours FREQUENCY Verify each ECCS manual, power operated, and 31 days Point Beach automatic valve in the flow path , that is not locked, sealed, or otherwise secured in position, is in the correct position.
3.5.2-1 (continued)
Un it 1 -Amendment No. Unit 2 -Amendment No.
E CCS -Oper a ting 3.5.2 SURVEILLANCE REQUIREMENTS (continued)
SR 3.5.2.2 SR 3.5.2.3 SR 3.5.2.4 SR 3.5.2.5 SR 3.5.2.6 Point Beach SURVEILLANCE Verify ECCS locations susceptible to gas accumulation are sufficiently filled with water. Verify each ECCS pump's developed head at the test flow point is greater than or equal to the required developed head. Verify each ECCS automatic valve in the flow path that is not locked, sealed , or otherwise secured in position , actuates to the correct position on an actual or simulated actuation signal. Verify each ECCS pump starts automatically on an actual or simulated actuation s i gnal. Verify , by visual inspection , each ECCS train containment sump suction inlet is not restricted by debris and the suction inlet debris screens show no evidence of structural distress or abnormal corrosion. FREQUENCY 31 days In accordance with the lnservice Testing Program 18 months 18 months 18 months 3.5.2-2 Unit 1 -Amendment No. Unit 2 -Amendment No.
Containment Spray and Cooling Systems 3.6.6 ACTIONS (continued)
CONDITION REQUIRED ACTION D. One required accident D.1 Restore required fan cooler unit service accident fan cooler unit water outlet valve outlet valve to inoperable. OPERABLE status. E. Required Action and E.1 Be in MODE 3. associated Completion Time of Condition C AND or D not met. E.2 Be in MODE 5. SURVEILLANCE REQUIREMENTS SR 3.6.6.1 SURVEILLANCE
-------------------------N 0 T E -------------------------Not required to be met for system vent flow paths opened under administrative controls. Verify each containment spray manual , power operated , and automatic valve in the flow path that is not locked , sealed, or othe r wise secured in position is in the correct position. COMPLETION TIME 72 hours AND 144 hours from discovery of failure to meet the LCO 6 hours 36 hours FREQUENCY 31 days SR 3.6.6.2 Operate each containment cooling accident fan. 31 days Point Beach 3.6.6-2 (continued)
Unit 1 -Amendment No. Unit 2 -Amendment No.
Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued)
SR 3.6.6.3 SR 3.6.6.4 SR 3.6.6.5 SR 3.6.6.6 SR 3.6.6.7 SR 3.6.6.8 SR 3.6.6.9 SR 3.6.6.1 0 Point Beach SURVEILLANCE FREQUENCY Verify each containment fan cooler unit can 31 days achieve a cooling water flow rate within design limits with a fan cooler service water outlet valve open. Verify each containment spray pump's In accordance developed head at the flow test point is greater with the than or equal to the required developed head. lnservice Testing Program Verify each automatic containment spray and 18 months containment fan cooler unit service water outlet valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal. Verify each containment spray pump starts 18 months automatically on an actual or simulated actuation signal. Verify each containment fan cooler unit accident 18 months fan starts automatically on an actual or simulated actuation signal. Verify proper operation of the accident fan 18 months cooler unit backdraft dampers. Verify each spray nozzle is unobstructed.
10 years Verify containment spray locations susceptible 31 days to gas accumulation are sufficiently filled with water. 3.6.6-3 Unit 1 -Amendment No. Unit 2 -Amendment No.
RHR and Coolant Circulation
-High Water Level 3.9.4 SURVEILLANCE REQUIREMENTS SR 3.9.4.1 SR 3.9.4.2 Point Beach SURVEILLANCE Verify one RHR loop is in operation. Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water. FREQUENCY 12 hours 31 days 3.9.4-2 Unit 1 -Amendment No. Unit 2 -Amendment No.
RHR and Coolant Circulation
-Low Water Level 3.9.5 SURVEILLANCE REQUIREMENTS SR 3.9.5.1 SR 3.9.5.2 SR 3.9.5.3 Point Beach SURVEILLANCE Verify one RHR loop is in operation.
Verify correct breaker alignment and indicated power available to the required RHR pump that is not in operation. Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water. FREQUENCY 12 hours 7 days 31 days 3.9.5-2 Unit 1 -Amendment No. Unit 2 -Amendment No.
License Amendment Request for NRC 2014-0035 Attachment 4 Adoption of Technical Specifications Task Force Traveler TSTF-523, Revision 2 Generic Letter 2008-01, Managing Gas Accumulation Attachment 4 Point Beach Technical Specifications Bases Changes Marked Up Pages For Information Only This coversheet plus 24 pages BASES LCO (continued)
Management of gas voids is important to RHR System OPERABILITY. Point Beach RCS Loops -MODE 4 B 3.4.6 that are designed to validate various accident analyses values. An example of one of the tests is validation of the pump coastdown curve used as input to a number of accident analyses including a loss of flow accident.
This test is generally performed during the initial startup testing program , and as such should only be performed once. If changes are made to the RCS that would cause a change to the flow characteristics of the RCS , the input values must be revalidated by conducting the test aga i n. The 1 hour time period is adequate to perform the test , and operating experience has shown that boron stratification is not a problem during this short period with no forced flow. Utilization of Note 1 is perm i tted provided the following conditions are met along with any other conditions imposed by initial startup test procedures:
: a. No operations are permitted that would dilute the RCS boron concentration , therefore maintaining the margin to criticality.
Boron reduction is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation
; and b. Core outlet temperature is maintained at least 1 0°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction. Note 2 requires that the secondary side water temperature of each SG be 50°F above each of the RCS cold leg temperatures before the start of an RCP with any RCS cold leg temperature the Low Temperature Overpressure Protection (L TOP) enabling temperature specified in the PTLR. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started. SG secondary side water temperature can be approximated by using the SG metal temperature indicator.
An OPERABL E RCS loop comprises an OPERABLE RCP and an OPERABLE SG, which has the minimum water level specified in SR 3.4.6.2. The OPERABL E RCP and SG must be i n the same loop for the RCS loop to be considered OPERABLE.
Similarly for the RHR System , an OPERABLE RHR loop comprises an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RCPs and RHR pumps are OPERABLE if they are capable of being powered and are able to provide forced flow if required.
B 3.4.6-2 Unit 1 -Amendment Unit 2-Amendment No. tt-9=-
BASES RCS Loops -MOD E 4 B 3.4.6 ACTIONS (continued)
C.1 and C.2 SURVEILLANCE REQUIREMENTS REFERENCES Point Beach If no loop is OPERABLE or in operation, except during cond i tions permitted by Note 1 in the LCO section, all operations involving a reduction of RCS boron concentration must be suspended and action to restore one RCS or RHR loop to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing, and the margin to criticality must not be reduced in this type of operation.
The immediate Completion Times reflect the importance of maintaining operation for decay heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.
SR 3.4.6.1 This SR requires verification every 12 hours that one RCS or RHR loop is in operation. Verification includes flow rate , temperature , or pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS and RHR loop performance.
SR 3.4.6.2 SR 3.4.6.2 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level 35%. If the SG secondary side narrow "-1/ range water level is < 35%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink necessary for removal of decay heat. The min i mum steam generator narrow range level limit (35%) includes instrument uncertainty.
The 'j( 12 hour Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of SG level. SR 3.4.6.3 Verification that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation , if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pump. The Frequency of 7 days is considered reasonable in view of other administrative controls available d has been shown to be acceptable by operating experience.
None. B 3.4.6-4 Unit 1 -Amendment No. :Me---J/ Unit 2 -Amendment No. 256-{'-
i'NSERT 1 I SR 3.4.6.4 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RHR loops and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel. Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations.
The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.
The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.
Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.
Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.
Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.
The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.
This SR is modified by a Note that states the SR is not required to be performed until 12 hours after entering MODE 4. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering MODE 4. The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR System piping and the procedural controls governing system operation.
BAS E S LCO (continued)
Management of gas voids is important to RHR System OPERABILITY.
APPLICABILITY Point Beach RCS Loops -MOD E 5, Loops Filled B 3.4.7 Note 2 allows one RHR loop to be inoperable for a period of up to 2 hours , provided that the other RHR loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when such testing is safe and possible.
Note 3 requires that the secondary side water temperature of each SG be s; 50&deg;F above each of the RCS cold leg temperatures before the start of a reactor coolant pump (RCP) with an RCS cold leg temperature s; Low Temperature Overpressure Protection (L TOP) arming temperature specified in the PTLR. This restriction is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started. Note 4 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting removal of RHR loops from operation when at least one RCS loop is in operation.
This Note provides for the transition to MODE 4 where an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops. Note 4 also allows both RHR loops to be removed from operation when at least one RCS loop is in operation to allow for the performance of leakage or flow testing, as required by Technical Specifications or by regulation.
This allowance is necessary based on the design of the Point Beach RHR System configuration , which requires the system to be removed from service to perform the required PIV testing. RHR pumps are OP E RABLE if they are capable of being powered and are able to provide flow if required.
An SG can perform as a heat sink via natural circulation (Ref. 1) when it has an adequate water level and *s OP E RABLE. In MODE 5 with RCS loops filled, this LCO requires forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. One loop of RHR provides sufficient circulation for these purposes.
However, one additional RHR loop is required to be OPERABL E, or the secondary side water level of at least one SGs is required to be ;::: 35% '-11 narrow range. I" B 3.4.7-3 Unit 1 -Amendment V Unit 2 -Amendment No.-zse. ;f\
BASES SURVEILLANCE REQUIREMENTS (continued)
INSERT 2 next page REFERENCES Point Beach SR 3.4.7.2 RCS Loops -MOD E 5, Loops Filled B 3.4.7 Verifying that at least one SG is OPERABLE by ensuring its secondary
\1/ side narrow range water level is :2: 35% narrow range ensures an }' alternate decay heat removal method via natural circulation (Ref. 1) in the event that the second RHR loop is not OPERABLE. The minimum K steam generator narrow range level limit (35%) includes instrument uncertainty.
If both RHR loops are OPERABLE, this Surveillance is not needed. The 12 hour Frequency is cons i dered adequate in view of other indications available in the control room to alert the operator to the loss of SG level. SR 3.4.7.3 Verification that a second RHR pump is OPERABLE ensures that an additional pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation.
Verification is performed by verifying proper breaker alignment and power available to \l/ the RHR pump. If secondary side water level is :2: 35% narrow range in If\ at least one SG, this Surveillance is not needed. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating
: 1. NRC Information Notice 95-35, "Degraded Ability of Steam Generators to Remove Decay Heat by Natural Circulation." B 3.4.7-5 Unit 1 -Amendment No. 246 , I/ Unit 2 -Amendment No. -r5e {' 
!INSERT 21 SR 3.4.7.4 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RHR loops and may also prevent water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel. Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations.
The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.
The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to* the acceptance criteria for the location.
Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.
Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.
Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.
The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.
The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR System piping and the procedural controls governing system operation.
BASES LCO (continued)
Management of gas voids is important to RHR System OPERABILITY.
APPLICABILITY ACTIONS Point Beach RCS Loops -MOD E 5, Loops Not F illed B 3.4.8 Note 2 allows one RHR loop to be inoperable for a period of::;; 2 hours, provided that the other loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when these tests are safe and possible.
An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger.
RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required.
In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the RHR System. Operation in other MODES is covered by: LCO 3.4.4, "RCS Loops-MODES 1 and 2"; LCO 3.4.5 , "RCS Loops-MODE 3"; LCO 3.4.6, "RCS Loops-MODE 4"; LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled"; LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant High Water Level" (MODE 6); and LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Low Water Level" (MODE 6). If only one RHR loop is OPERABLE and in operation, redundancy for RHR is lost. Action must be initiated to restore a second loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal. B.1 and B.2 If no required RHR loops are OPERABLE or in operation, except during conditions permitted by Note 1, all operations involving a reduction of RCS boron concentration must be suspended and action must be initiated immediately to restore an RHR loop to OPERABLE status and operation.
Boron dilution requires forced circulation for uniform dilution, and the margin to criticality must not be reduced in this type of operation.
The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must continue until one loop is restored to OPERABLE status and operation. B 3.4.8-2 Unit 1 -Amendment No. 284 Unit 2 -Amendment No. 200-BASES SURVEILLANCE REQUIREMENTS INSERT 3 next page REFERENCES Point Beach SR 3.4.8.1 RCS Loops -MOD E 5, Loops Not Filled B 3.4.8 This SR requires verification every 12 hours that one loop is in operation.
Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours is sufficient considering other indications and alarms available to the operator in the control room to monitor RHR loop performance.
SR 3.4.8.2 Verification that the required number of pumps are OPERABLE ensures that additional pumps can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation.
Verification is performed by verifying proper breaker alignment and power available to the required pumps. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.
None. B 3.4.8-3 Unit 1 -Amendment No. Unit 2 -Amendment No. -266-jiNSERT 3 SR 3.4.8.3 RHR 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 loops and may also prevent water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel. Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations.
The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.
Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.
The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations.
If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.
Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.
Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.
Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.
The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.
The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR System piping and the procedural controls governing system operation.
BASES APPLICABLE SAFETY ANALYSES (continued)
LCO Management of gas voids is important to ECCS System OPERABILITY.
Point Beach E CCS -Operating B 3.5.2 vessel upper plenum and RCS cold legs, flows into the downcomer, fills the lower plenum, and refloods the core. The effects on containment mass and energy releases are accounted for in appropriate analyses (Ref. 4). The LCO ensures that an ECCS train will deliver sufficient water to match boiloff rates soon enough to minimize the consequences of the core being uncovered following a large LOCA. It also ensures that the Sl pumps will deliver sufficient water and boron during a small LOCA to maintain core subcriticality. For smaller LOCAs, the steam generators continue to serve as the heat sink, providing part of the required core cooling. The ECCS trains satisfy Criterion 3 of the NRC Policy Statement.
In MODES 1, 2, and 3, two independent (and redundant)
ECCS trains are required to ensure that sufficient ECCS flow is available, assuming a single failure affecting either train. Additionally , individual components within the ECCS trains may be called upon to mitigate the consequences of other transients and accidents.
In MODES 1, 2, and 3, an ECCS train consists of, an Sl subsystem , and an RHR subsystem.
Each train includes the piping, instruments, and controls to ensure an OPERABLE flow path taking suction from the RWST upon an Sl signal and capable of manually transferring suction to the containment sump. During an event requiring ECCS actuation, a flow path is required to provide an abundant supply of water from the RWST to the RCS via the ECCS pumps and their respective supply headers to the RCS. In the long term , this flow path may be switched to take its supply from the containment sum? The flow path for each train must maintain its designed independence to ensure that no single failure can disable both ECCS trains. As indicated in the Note, the Sl pump flow paths may be isolated for 2 hours in MODE 3, under controlled conditions, to perform pressure isolation valve testing per SR 3.4.14.1. The flow path is readily restorable from the control room. B 3.5.2-4 10/20/01 BASES ECCS -Operating B 3.5.2 ACTIONS (continued)
An event accompanied by a loss of offsite power and the failure of an EDG can disable one ECCS train until power is restored. A reliability analysis (Ref. 5) has shown that the impact of having one full ECCS train inoperable is sufficiently small to justify continued operation for 72 hours. SURVEILLANCE REQUIREMENTS Point Beach With more than one component inoperable such that both ECCS trains are not available, the facility is in a condition outside design and licensing basis. Therefore, LCO 3.0.3 must be immediately entered. B.1 and B.2 If the inoperable trains cannot be returned to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 6 hours and MODE 4 within 12 hours. The allowed Completion Times are reasonable , based on operating experience , to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SR 3.5.2.1 Verifying the correct alignment for manual , power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked , sealed , or otherwise secured in position, since these were verified to be in the correct position prior to locking , sealing , or securing. A valve that receives an actuation signal is allowed to be in a non-accident position provided the valve will automatically reposition within the proper stroke time. This Surveillance does not require any testing or valve manipulation. Rather , it involves verification that those valves capable of being mispositioned are in the correct position. The 31 day Frequency is appropriate because the valves a r e operated under administrative control, and an improper valve position would only affect a single train. This Frequency has been shown to be acceptable through operating experience. B 3.5.2-6 Unit 1 -Amendment No. Unit 2-Amendment No. -244--
INSERT 4 ECCS piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel. Selection of ECCS locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations.
The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.
Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.
The ECCS is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations.
If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. ECCS locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.
Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.
Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.
Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.
The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.
The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the ECCS piping and the procedural controls governing system operation.
BASES SURVEILLANCE REQUIREMENTS (continued)
Point Beach SR 3.5.2.3 E CCS -Operating B 3.5.2 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by the ASME Code. This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the plant safety analysis.
SRs are specified in the lnservice Testing Program , which implements the requirements of the ASME OM Code, providing the activities and Frequencies necessary to satisfy the requirements.
SR 3.5.2.4 and SR 3.5.2.5 These Surveillances demonstrate that each automatic ECCS valve actuates to the required position on an actual or simulated Sl signal and that each ECCS pump starts on receipt of an actual or simulated Sl signal. This Surveillance is not required for valves that are locked, sealed , or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the poten t ial for unplanned plant transients if the Surveillances were performed with the reactor at power. The 18 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.
The actuation logic is tested as part of ESF Actuation System testing, and equipment performance is monitored as part of the lnservice Testing Program. B 3.5.2-7 Unit 1 -Amendment No. Unit 2 -Amendment No. 21-4--
BASES LCO (continued)
Management of gas voids is important to ECCS OPERABILITY APPLICABILITY ACTIONS Point Beach ECCS -Shutdown B 3.5.3 During an event requiring ECCS actuation, a flow path is required to provide an abundant supply of water from the RWST to the RCS via the ECCS pumps and their respective supply headers. In the long term, this flow path may be switched to tal<e its supply from the containment sump. This LCO is modified by a Note that allows an RHR train to be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned (remote or local) to the ECCS mode of operation and not otherwise inoperable.
This allows operation in the RHR mode during MODE 4. In Mode 4, the "B" ECCS train shall be OPERABLE and aligned for injection when the "A" train Is aligned for decay heat removal. This Is due to concerns raised in NRC Information Notice 2010-011.
The operating RHR train may be susceptible to steam voiding if the suction source is switched from the RCS hot leg to the RWST or to the containment sump in response to a LOCA during Mode 4 decay*heat removal operation.
In MODES 1, 2, and 3, the OPERABILITY requirements for ECCS are covered by LCO 3.5.2. In MODE 4 with RCS temperature below 350&deg;F, one OPERABLE ECCS train is acceptable without single failure consideration, on the basis of the stable reactivity of the reactor and the limited core cooling requirements.
In MODES 5 and 6, plant conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled." MODE 6 core cooling requirements are addressed by LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level," and LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level." A Note prohibits the application of LCO 3.0.4.b to an inoperable ECCS high head subsystem when entering MODE 4. There is an increased risl< associated with entering MODE 4 from MODE 5 with an inoperable ECCS high head subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.
With no ECCS RHR subsystem OPERABLE, the plant Is not prepared to respond to a loss of coolant accident or to continue a cooldown using the RHR pumps and heat exchangers.
The Completion Time of 8 3.5.3-2 5/21/2014 BASES LCO Management of gas voids is important to Containment Spray System OPERABILITY.
Point Beach Containment Spray and Cooling Systems B 3.6.6 Each Containment Spray System consists of a spray pump, spray header , nozzles, valves, piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the RWST upon an ESF actuation signal during the injection phase and to allow manual alignment from the control room for taking suction from the RHR system during the recirculation phase. Each Containment Accident Fan Cooler Unit consists of cooling coils, accident backdraft damper , accident fan , service water outlet valves, and controls necessary to ensure an OPERABLE service water flow path. During a LOCA, a minimum of two containment accident fan cooler units with their accident fans running and one containment spray train are required to maintain the containment peak pressure and temperature below the design limits (Ref. 3). Additionally, one containment spray train is also required to remove iodine from the -J; containment atmosphere, and to provide the motive force and flowpath If" to the containment sump for NaOH from the Spray Additive System. SLB During a SLB event , the most limiting single failure is a Main Feedwater Isolation Valve (MFIV) failing to close on demand , and continuing to feed the faulted steam generator. Therefore, both trains of containment spray and all four containment accident fan coolers and their associated accident fans are assumed to operate as designed (Ref. 3). The resulting transient bounds the failure of a single train of safeguards.
The single failure assumptions for a SLB involve containment sprays, containment coolers, and main feedwater isolation.
Therefore, a safety function evaluation per TS 3.0.6 and TS 5.5.14 must be performed for the supported function of containment Operability if a loss of containment spray or containment fan cooler function occurs. The review must consider Main Feedwater Isolation OPERABILITY per the requirements of TS 3.7.3. B 3.6.6-7 Ju11e 20 , 2012 t BASES Containment Spray and Cooling Systems B 3.6.6 ACTIONS (continued)
The 144 hour portion of the Completion Time for Required Action C.1 is based upon engineering judgment.
It takes into account the low probability of coincident entry into two Conditions in this Specification coupled with the low probability of an accident occurring during this time. Refer to Section 1.3 for a more detailed discussion of the purpose of the "from discovery of failure to meet the LCO" portion of the Completion Time. SURVEILLANCE REQUIREMENTS With one containment cooler service water outlet valve inoperable, the containment cooling water outlet valve must be restored to OPERABLE status within 72 hours. During this period, the remaining containment cooler service water outlet valve is capable of providing 1 00% of assumed cooling water flow to all four containment accident fan coolers. The 72 hour Completion Time was developed taking into account the auto open and flow capability afforded by the redundant cooling water outlet valve , and the low probability of DBA occurring during this period. E.1 and E.2 If the Required Action and associated Completion Time of Condition C or D of this LCO are not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SR 3.6.6.1 Verifying the correct alignment for manual, power operated, and automatic valves in the containment spray flow path provides assurance that the proper flow paths will exist for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these were verified to be in the correct position prior to locking, sealing , or securing. This SR does not require any testing or valve manipulation. Rather , it involves verification that those valves outside containment (only check valves are inside containment) and capable of potentially being mispositioned are in the correct position.
The Surveillance Frequency is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include a stationing of a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.
Point Beach B 3.6.6-10 Unit 1 11/1a/02 Unit 2 11/13/02 BASES SURVEILLANCE REQUIREMENTS (continued)
Point Beach Containment Spray and Cooling Systems B 3.6.6 pressure signal. This Surveillance is not required for valves that are locked , sealed, or otherwise secured in the required position under administrative controls.
The 18 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillances when performed at the 18 month Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR 3.6.6.7 This SR requires verification that each containment accident fan cooler unit accident fan actuates upon receipt of an actual or simulated safety injection signal. The 18 month Frequency is based on engineering judgment and has been shown to be acceptable through operating experience.
See SR 3.6.6.5 and SR 3.6.6.6 , above , for further discussion of the basis for the 18 month Frequency.
SR 3.6.6.8 This SR verifies proper operation of the containment accident fan cooler unit backdraft dampers. The backdraft damper of concern is the one installed in the discharge flowpath of the normal fan. This damper prevents back flow which would bypass the cooler coils when the accident fan is in operation and the normal fan is not in operation. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and engineering judgment.
SR 3.6.6.9 With the containment spray inlet valves closed and the spray header drained of any solution , low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degraded.
Due to the passive design of the nozzle , a test at 10 year intervals is considered adequate to detect obstruction of the nozzles. ISR 3.6.6.1 0 I INSERT 5 next page B 3.6.6-12 Unit 1 -Amendment No. -2&1-Unit 2 -Amendment No. W6-INSERT 5 Containment Spray System flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the containment spray trains and may also prevent a water hammer and pump cavitation.
Selection of Containment Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations.
The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.
Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.
The Containment Spray System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations.
If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Containment Spray System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. Containment Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.
Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.
Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.
The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.
The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the Containment Spray System piping and the procedural controls governing system operation.
BASES LCO Management of gas voids is important to RHR System OPERABILITY. APPLICABILITY Point Beach RHR and Coolant Circulation
-High Water Level B 3.9.4 Only one RHR loop is required for decay heat removal in MODE 6, with the water level 2': 23 ft above the top of the reactor vessel flange. Only one RHR loop is required to be OPERABLE , because the volume of water above the reactor vessel flange provides backup decay heat removal capability.
At least one RHR loop must be OPERABLE and in operation to provide: a. Removal of decay heat; b. Mixing of borated coolant to minimize the possibility of criticality; and c. Indication of reactor coolant temperature. An OPERABLE RHR loop includes an RHR pump , a heat exchanger, valves, piping , instruments, and controls to ensure an OPERABLE flow path and to determine the low end temperature.
The flow path starts in one of the RCS hot legs and is returned to the RCS cold leg. The LCO is modified by a Note that allows the required operating RHR loop to not be in operation for up to 1 hour per 8 hour period, provided no operations are permitted that would cause a reduction of the RCS boron concentration. Boron concentration reduction is prohibited because uniform concentration distribut i on cannot be ensured without forced circulation.
This permits operations such as core mapping or alterations in the vicinity of the reactor vessel hot leg nozzles and RCS to RHR isolation valve testing. During this 1 hour period, decay heat is removed by natural convection to the large mass of water in the refueling cavity. One RHR loop must be OPERABLE and in operation in MODE 6 , with the water level 2': 23 ft above the top of the reactor vessel flange, to provide decay heat removal. The 23 ft water level was selected because it corresponds to the 23 ft requirement established for fuel movement in LCO 3.9.6, "Refueling Cavity Water Level." Requirements for the RHR System in other MODES are covered by LCOs in Sect i on 3.4 , Reactor Coolant System (RCS), and Section 3.5, Emergency Core Cooling Systems (ECCS). RHR loop requirements in MODE 6 with the water level < 23 ft are located in LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant CirculationLow Water Level." B 3.9.4-2 Unit 1 -Amendment No. 2-9-4-Unit 2 -Amendment No. -2e&-
BASES ACTIONS SURVEILLANCE REQUIREMENTS RHR and Coolant Circulation
-High Water Level B 3.9.4 RHR loop requirements are met by having one RHR loop OPERABLE and in operation, except as permitted in the Note to the LCO. If RHR loop requirements are not met, there will be no forced circulation to provide mixing to establish uniform boron concentrations.
If RHR loop requirements are not met, actions shall be taken immediately to suspend loading of irradiated fuel assemblies in the core. With no forced circulation cooling, decay heat removal from the core occurs by natural convection to the heat sink provided by the water above the core. A minimum refueling water level of 23ft above the reactor vessel flange provides an adequate available heat sink. Suspending any operation that would increase decay heat load, such as loading a fuel assembly, is a prudent action under this condition.
If RHR loop requirements are not met, actions shall be initiated and continued in order to satisfy RHR loop requirements.
With the unit in MODE 6 and the refueling water level:::::
23ft above the top of the reactor vessel flange, corrective actions shall be initiated immediately.
SR 3.9.4.1 This Surveillance demonstrates that the RHR loop is in operation and circulating reactor coolant. Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing decay heat removal capability and mixing of the borated coolant to prevent thermal and boron stratification in the core. The Frequency of 12 hours is sufficient, considering the flow, temperature, INSERT 6 pump control, and alarm indications available to the operator in the next page room for monitoring the RHR System. REFERENCES
: 1. FSAR. Section 9.2 and 14.1.4. Point Beach B 3.9.4-3 Unit 1 -Amendment No. Unit 2 -Amendment No . .;we....
jiNSERT 6 SR 3.9.4.2 RHR 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 loops and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel. Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations.
The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.
Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.
The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.
Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.
Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.
The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.
The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR System piping and the procedural controls governing system operation.
BASES LCO (continued)
Management of gas voids is important to RHR System OPERABILITY.
APPLICABILITY ACTIONS Point Beach RHR and Coolant Circulation-Low Water Level B 3.9.5 An OPERABLE RHR loop consists of an RHR pump, a heat exchanger, valves, piping, instruments and controls to ensure an OPERABLE flow path and to determine the low end temperature.
The flow path starts in one of the RCS hot legs and is returned to one of the RCS cold legs. Both RHR pumps may be aligned to the Refueling Water Storage Tank to support filling or draining the refueling cavity or for performance of required testing. Two RHR loops are required to be OPERABLE, and one RHR loop must be in operation in MODE 6, with the water level <23ft above the top of the reactor vessel flange, to provide decay heat removal. Requirements for the RHR System in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS), and Section 3.5, Emergency Core Cooling Systems (ECCS). RHR loop requirements in MODE 6 with the water level 23 ft are located in LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level." A.1 and A.2 If less than the required number of RHR loops are OPERABLE, action shall be immediately initiated and continued until the RHR loop is restored to OPERABLE status and to operation or until 23 ft of water level is established above the reactor vessel flange. When the water level is above the reactor vessel flange, the Applicability changes to that of LCO 3.9.4, and only one RHR loop is required to be OPERABLE and in operation.
An immediate Completion Time is necessary for an operator to initiate corrective actions. If no RHR loop is in operation, there will be no forced circulation to provide mixing to establish uniform boron concentrations.
If no RHR loop is in operation, actions shall be initiated immediately, and continued, to restore one RHR loop to operation. Since the unit is in Conditions A and B concurrently, the restoration of two OPERABLE RHR loops and one operating RHR loop should be accomplished expeditiously.
B 3.9.5-2 Unit 1 -Amendment No. ze+ Unit 2 -Amendment No. -266-BASES SURVEILLANCE REQUIREMENTS INSERT 7 next page REFERENCES Point Beach SR 3.9.5.1 RHR and Coolant Circulation
-Low Water Level B 3.9.5 This Surveillance demonstrates that one RHR loop is in operation and circulating reactor coolant. Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing decay heat removal capability and mixing of the borated coolant to prevent thermal and boron stratification in the core. In addition, during operation of the RHR loop with the water level in the vicinity of the reactor vessel nozzles, the RHR pump suction requirements must be met. The Frequency of 12 hours is sufficient, considering the flow, temperature, pump control, and alarm indications available to the operator for monitoring the RHR System in the control room. SR 3.9.5.2 Verification that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation , if needed, to maintain decay heat removal and reactor coolant circulation.
Verification is performed by verifying proper breaker alignment and power available to the required pump. The Frequency of 7 days is considered reasonable in view of other administrative controls available nd has been shown to be acceptable by operating experience.
: 1. FSAR. Section 9.2 and 14.1.4 B 3.9.5-3 Unit 1 -Amendment No. ze.+ Unit 2 -Amendment 
!IN SERT 7 1 SR 3.9.5.3 RHR 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 loops and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel. Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations.
The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of i mportant components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.
The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.
Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.
Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.
Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.
The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.
The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR System piping and the procedural controls governing system operation.}}

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