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Text

Summary of Changes to ITS Section 3.6
	ML011630382
Person / Time
Site:	FitzPatrick
Issue date:	04/07/1995
From:	; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	-RFPFR, JAFP-01-0133
	Download: ML011630382 (155)
	v • d • e

SUMMARY

OF CHANGES TO ITS SECTION 3.6

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E "Source of Change Summary of Change Affected Pages RAI 3.6.1.1-1 (as Revised MU to clearly show details of CTS Definition Specification 3.6.1.1 modified) moved to ITS Bases.

CTS mark-up p 1 of 8 RAI 3.6.1.1-2 (as Revised CTS MU to show deletion of CTS 4.7.A.1 Specification 3.6.1.1 modified) requirement to inspect interior surface of drywell and suppression chamber above water line every 24 months CTS mark-up p 7 of 8 based on the inspection being required by Primary Containment Leakage Rate Testing Program three times in DOCs LA2 and L3 (DOCs p 3 of 10 years. Added DOC L3 and NSHC L3 for justification.

6 and 5 of 6)

NSHC L3 (NSHCs p 5 of 6 and 6 of 6)

RAI 3.6.1.1-3 Revised CTS MU to more clearly reflect how drywell to Specification 3.6.1.1 suppression chamber vacuum breaker leak testing is performed (DOC M4).

moved CTS 3.7.A.5.e to Bases CTS mark-up p 4 of 8 and 5 (revised DOC LA3), revised ITS SR 3.6.1.1.2. and added of 8 NUREG JFD DB1.

DOC M4 and LA3 (DOCs p 3 of 6 and 4 of 6)

ITS mark-up p 3.6-2 JFD DB1 (JFDs p 1 of 2)

ITS Bases mark-up p B 3.6-4 Retyped ITS p 3.6-2 Retyped ITS Bases p B 3.6-4 and B 3.6-5 RAI 3.6.1.1-4 (as TSTF addresses 10 CFR 50. Appendix J. Option B.

Minor Specification 3.6.1.1 modified) and TSTF-52 R3 ITS changes to make text exactly the same as the TSTF, added NUREG and Bases JFDs to note adoption of TSTF.

ITS mark-up p 3.6-2 JFDs CLB1 (deleted) and TAt (JFDs p 1 of 2)

ITS Bases mark-up p B 3.6-1, B 3.6-2. B 3.6-4. and B 3.6 5

Bases JFDs CLB1 (deleted) and TAI (Bases JFDs p I of 2 and 2 of 2)

Retyped ITS p 3.6-2 Retyped ITS Bases p B 3.6-2 RAI 3.6.1.1-5 Removed portion of TSTF-196 (unapproved) that was left Specification 3.6.1.1 in Bases MU in error.

ITS Bases mark-up p B 3.6-1 Retyped ITS Bases p B 3.6-1 Page I

, I

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages RAI 3.6.1.1-6 (as Revised NUREG MU to note that LPCI and Core Spray air Specification 3.6.1.1 modified) operated testable check valve leakage test failure does not result in ITS SR 3.6.1.1.1 failure and added NUREG JFD CLB3 (JFDs p 1 of 2)

JFD CLB3.

Added discussion in ITS SR 3.6.1.1.1 Bases to address same topic and added Bases JFD CLB4 since the ITS Bases mark-up p B 3.6-4 air operated testable check valve leakage is not counted and B 3.6-5 in La.

Bases JFD CLB4 (Bases JFDs p 1 of 2)

Retyped ITS p 3.6-2 Retyped ITS Bases p B 3.6-4 and B 3.6-5 RAI 3.6.1.2-1 (as Revisions address ITS ACTIONS Note to allows each air Specification 3.6.1.2 modified) lock penetration to be addressed as a separate Condition entry.

Replaced DOC A4 with DOC L5 and NSHC L5 for CTS mark-up p 3 of 4 justification and evaluation of less restrictive change.

DOCs A4 (deleted) and L5 (DOCs p 2 of 7 and 7 of 7)

NSHC L5 (NSHCs p 9 of 10 and 10 of 10)

ITS mark-up p 3.6-3 RAI 3.6.1.2-2 and TSTF-52 TSTF addresses 10 CFR 50, Appendix J. Option B. Minor Specification 3.6.1.2 "3

ITS changes to make text exactly the same as the TSTF.

added NUREG and Bases JFDs to note adoption of TSTF.

ITS mark-up p 3.6-7 JFD CLB1 (deleted) (JFDs p 1 of 2)

ITS Bases mark-up p B 3.6-7.

B 3.6-8. B 3.6-12 Bases JFDs CLB1 (deleted) and TA2 (Bases JFDs p 1 of 3 and 2 of 3)

Retyped ITS Bases p B 3.6-12 Page 2

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E "Source of Change Summary of Change Affected Pages RAI 3.6.1.2-3 Revised to show NUREG-1434. R1 (rather than 1433.

Ri) as Specification 3.6.1.2 the source since NUREG-1434 is based on a two drywell airlock design.

Restored air lock physical description DOCs Al. A2. A5. M3. and L4 discussion in Bases Background to the "generic" words in (DOCs p 1 of 7, 2 of 7, 3 of NUREG Bases.

7, 4 of 7. and 6 of 7)

ITS mark-up p 3.6-3 through 3.6-8 JFDs PA3, PA4,

DBI, and DB2 (JFDs p 1 of 2)

ITS Bases mark-up p B 3.6-6 through B 3.6-14 Bases JFD PA6. PA7, DB4. Xl (Bases JFDs p 1 of 3. 2 of

3. and 3 of 3)

Retyped ITS p 3.6-3 Retyped ITS Bases p B 3.6-6.

B 3.6-8 RAI 3.6..1.2-5 and TSTF-17 Revisions reflect TSTF R2 in place of R1.

TSTF allows Specification 3.6.1.2 R2 ITS SR 3.6.1.2-2 (for test of drywell air lock door interlocks) Frequency to be relaxed to 24 months and ITS mark-up p 3.6-8 thus avoid challenge to Primary Containment Operability in MODE 1. 2. and 3. Revised JFDs to reflect R2 to TSTF.

JFDs TAI and TA2 (JFDs p 1 of 2)

ITS Bases mark-up p B 3.6-13 and Insert Page B 3.6-13 Bases JFD TAl (Bases JFDs p 2 of 3)

Editorial Corrected DOC and JFD annotations which were in error.

Specification 3.6.1.2 Corrected typographical errors in the retyped ITS Bases.

ITS mark-up p 3.6-3 ITS Bases mark-up p B 3.6-14 Bases JFD DB5 (Bases JFDs p 2 of 3)

Retyped ITS Bases p B 3.6-7.

B 3.6-9, and B 3.6-10 RAI 3.6.1.3-1 and TSTF-52 TSTF-52, R3 addresses 10 CFR 50. Appendix J. Option B.

Specification 3.6.1.3 R3 Minor ITS changes to make text exactly the same as the TSTF. added NUREG and Bases JFDs to note adoption of JFD TA4 (JFDs p 3 of 5)

TSTF-52, R3.

ITS Bases mark-up p B 3.6-31 Bases JFD TA4 (Bases JFDs p 4 of 6)

Retyped ITS Bases p B 3.6-28 Page 3

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages RAI 3.6.1.3-3 Deleted phrase "an actual or" in ITS SR 3.6.1.3-8 and Specification 3.6.1.3 revised associated MUs.

DOCs and JFDs.

CTS mark-up p 5 of 9 DOC M2 (DOCs p 5 of 14)

ITS mark-up p 3.6-16 JFD X5 (JFDs p 4 of 5)

ITS Bases mark-up p B 3.6-29 Bases JFDs CLB8 and X5 (deleted) (Bases JFDs p 1 of 6 and 5 of 6)

Retyped ITS p 3.6-14 Retyped ITS Bases p B 3.6-27 RAI 3.6.1.3-4 (as TSTF-207, R5 addresses extending the time allowed to Specification 3.6.1.3 modified),

RAI 3.6.1.3-8.

restore MSIV leakage in excess of limits from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to and TSTF-207 R5 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and extends restoration time for EFCVs to 72 DOCs L3. L5.

L1O (DOCs p 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months .

Changes are made to Condition statements and of 14. 10 of 14. 12 of 14)

Completion Times.

Other changes made to bring NUREG and Bases MUs into complete agreement with TSTF text to NSHC L1O (NSHCs p 15 of 22 resolve RAI 3.6.1.3-8.

and 16 of 22)

ITS mark-up p 3.6-8. 3.6-10.

3.6-17 JFDs TA4.

X1, and X8 (JFDs p 3 of 5 through 5 of 5)

ITS Bases mark-up p B 3.6

18. B 3.6-20, and Insert Page B 3.6-22 Bases JFD TA5 and X12 (Bases JFDs p 4 of 6 and 6 of 6)

Retyped ITS p 3.6-8. 3.6-9.

3.6-10.

3.6-11 Retyped ITS Bases p B 3.6-22 Page 4

01 10

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages RAI 3.6.1.3-5 and TSTF-30 Update from TSTF R2 to R3.

Changes allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to Specification 3.6.1.3 R3 restore PCIVs to Operable status for single PCIV penetrations with closed systems.

CTS mark-up p 6 of 9 NSHC L5 (NSHCs p 7 of 22 and 8 of 22)

ITS mark-up p 3.6-10 JFD TA3 (JFDs p 3 of 5)

ITS Bases mark-up p B 3.6

20. B 3.6-21. and Insert Page B 3.6-22 Bases JFD DBlO (Bases JFDs p 4 of 6)

Retyped ITS p 3.6-10 Retyped ITS Bases p B 3.6

20. and B 3.6-22 RAI 3.6.1.3-6 and RAI See Summary for Changes to CTS 3.7.A.3. RAI 3.7.A.3-2, Specification 3.6.1.3 3.7.A-2 below.

ITS Bases mark-up p B 3.6

15. Insert Page B 3.6-15.

and B 3.6-25 Retyped ITS Bases p B 3.6-15 and B 3.6-23 RAI 3.6.1.3-7 (as Revised CTS MU to change LPCI and CS testable check Specification 3.6.1.3 modified) valve testing to per PCLRT Program (vice every 24 months).

Added justification and evaluation in DOC L13 CTS mark-up p 7 of 9 and NSHC L13.

Revised NUREG and Bases to reflect change and added NUREG JFD X9 and Bases JFD X13.

DOC L13 (DOCs p 13 of 14 and 14 of 14)

NSHC L13 (NSHCs p 21 of 22 and 22 of 22)

ITS mark-up p 3.6-18 ITS Bases mark-up p B 3.6-31 Bases JFD X13 (Bases JFDs p 6 of 6)

RAI 3.6.1.3-9 Removed changes to Bases Background MU cited by NRC Specification 3.6.1.3 reviewer.

Change was a minor editorial/language preference.

JFD X9 (JFDs p 5 of 5)

ITS Bases mark-up p B 3.6-14 Retyped ITS Bases p B 3.6-14 RAI 3.6.1.3-10 Removed minor change to ACTIONS Bases MU cited by NRC Specification 3.6.1.3 reviewer.

Change created an inconsistency with other parts of Bases.

ITS Bases mark-up p B 3.6-18 Retyped ITS Bases p B 3.6-18 Page 5

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages RAI 3.6.1.3-11 (as Removed Action C.1. Action C.2. SR 3.6.1.3.2 and SR Specification 3.6.1.3 modified) 3.6.1.3.3 Bases MU changes cited by NRC reviewer.

Changes were a minor editorial/language preferences.

ITS Bases mark-up p B 3.6-21 Retyped ITS p 3.6-14 Retyped ITS Bases p B 3.6

21. B 3.6-24. and B 3.6-25 RAI 3.6.1.3-12 Removed Action C.1 and Action C.2 Bases MU changes cited Specification 3.6.1.3 by NRC reviewer.

Change had created a duplication of other Bases text.

ITS Bases mark-up p B 3.6-21 RAI 3.6.1.3-13 (as Deleted Bases JFD X1O, revised ITS SR 3.6.1.3-10 Bases Specification 3.6.1.3 modified)

MU by changing X1O annotation to PA3 and revised Bases JFD PA3 to include reference to ITS SR 3.6.1.3-10 Bases ITS Bases mark-up p B 3.6-31 MU.

Bases JFDs PA3 and X1O (deleted) (Bases JFDs p 3 of 6 and 6 of 6)

Retyped ITS Bases p B 3.6-28 RAI 3.6.1.3-14 Revised Bases ASA text and revised Bases JFD DB8 as Specification 3.6.1.3 suggested by NRC reviewer.

Changes make the Bases ASA discussion consistent with the JAF DBA analysis and ITS Bases mark-up p B 3.6 added new References 4 and 5 accordingly.

16. Insert Page B 3.6-16.

and B 3.6-32 Bases JFD DB8 (Bases JFDs p 4 of 6)

Retyped ITS Bases p B 3.6

16. and B 3.6-28 RAI 3.6.1.3-15 Revised ITS SR 3.6.1.3.1 Bases MU as suggested by NRC Specification 3.6.1.3 reviewer.

Change makes it clearer that primary containment vent and purge valves may only be open as ITS Bases mark-up p B 3.6-25 necessary for plant operations, surveillance. etc.

Retyped ITS Bases p B 3.6-23 TSTF-45 R2 Update from TSTF R1 to R2.

Specification 3.6.1.3 JFD TAI (JFDs p 3 of 5)

ITS Bases mark-up p Insert Page B 3.6-26 Bases JFD TAI (Bases JFDs p 4 of 6)

Page 6 I

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages TSTF-269 R2 TSTF-269, R2 addresses allowing PCIVs that are locked.

Specification 3.6.1.3 sealed or otherwise secured to be verified in the correct position by administrative means. Required CTS mark-up p 6 of 9 Actions Notes are added and Bases discussions added for Notes.

DOC L11 (DOCs p 12 of 14 and 13 of 14)

NSHC L1i (NSHCs p 17 of 22)

ITS mark-up p 3.6-9 and 3.6 10 JFD TA6 (JFDs p 3 of 5)

ITS Bases mark-up p B 3.6

19. B 3.6-20. Insert Page B 3.6-20. B 3.6-21. and Insert Page B 3.6-21 Bases JFD TA6 (Bases JFDs p 4 of 6)

Retyped ITS p 3.6-9 and 3.6 10 Retyped ITS Bases p B 3.6-21 TSTF-323 RO TSTF-323.

RO addresses correct Bases Reference Specification 3.6.1.3 associated with penetrations with closed systems.

ITS Bases mark-up p B 3.6-32 Bases JFD PA3 and TA7 (Bases JFDs p 3 of 6 and 5 of 6)

Retyped ITS Bases p B 3.6-19 and B 3.6-20 Amendment 260 Revised CTS MU to reflect CTS Amendment 260 which Specification 3.6.1.3 changed MSIV closure test Frequency.

Deleted DOCs associated with CTS portions deleted.

CTS mark-up p 6 of 9 DOCs LA2 and LA4 (DOCs p 7 of 14)

Amendment 269 Revised CTS MU to reflect CTS Amendment 269.

No change Specification 3.6.1.3 to MU needed except as necessary due to movement of text.

CTS mark-up p 9 of 9 Page 7

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages Editorial Deleted NUREG JFD X4 (which duplicated NUREG JFD CLB 10) Specification 3.6.1.3 and revised NUREG MU at ITS SR 3.6.1.3.10 to reflect change.

Deleted phrase "or equivalent" two places in DOCs M4 and L9 (DOCs p 5 of DOC M4 to correct incomplete removal of TSTF 196 (not 14 and 11 of 14) approved by NRC).

Revised Reference numbers as necessary to reflect addition of new Ref. 4 and 5 in ASA NSHC L5.

LIO, and Lli (NSHCs Bases (see RAI 3.6.1.3-14 above).

p 7 of 22, 15 of 22, 17 of

22)

ITS mark-up p 3.6-17 JFDs DB2 (deleted) and X4 (deleted) (JFDs p 3 of 5 and 4 of 5)

ITS Bases mark-up Insert Page B 3.6-15, B 3.6-16. B 3.6-17, B 3.6-19. Insert Page B 3.6-22. B 3.6-25. and B 3.6-29 Bases JFDs CLB8. DB9 (deleted). and X12 (Bases JFDs p 1 of 6. 4 of 6 and 6 of 6)

Retyped ITS Bases p B 3.6

15. B 3.6-16. B 3.6-17. B 3.6-18. B 3.6-20. B 3.6-22.

B 3.6-23. B 3.6-27. and B 3.6-28 RAI 3.6.1.6-1 (as Revised JFD X1 and Bases JFD X2 to provide proper Specification 3.6.1.6 modified) justification for a 24 month Frequency.

DOC M3 (DOCs p 1 of 5)

JFD X1 (JFDs p 2 of 2)

Bases JFD X2 (Bases JFDs p 3 of 3)

RAI 3.6.1.6-2 (as Revised CTS MU and added DOC M7 to reflect more Specification 3.6.1.6 modified) restrictive ITS Conditions that require Action for any vacuum breaker (VB) inoperability for either the VB or CTS mark-up p 1 of 3 and 2 containment isolation function.

Revised DOC Li to of 3 address only separate Condition entry for each VB inoperability and deletion of discussion regarding dual DOCs M7 and Li (DOCs p 3 of functions of the VBs.

Discussion of the dual functions 5 and 4 of 5) of VBs is addressed in DOC M7.

Revised NSHC Li to reflect changes to DOC LI.

NSHC L1 (NSHCs p 1 of 5 and 2 of 5)

ITS mark-up p 3.6-23 and 3.6-24 RAI 3.6.1.6-3 Revised ITS 3.6.1.6 Bases JFD DB3 by adding details Specification 3.6.1.6 regarding scenario that results in the negative pressure transient of the greatest concern.

Bases JFD DB3 (Bases JFDs p 2 of 3)

Page 8

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages RAI 3.6.1.7-1 Changed NUREG SR 3.6.1.8.1 (ITS SR 3.6.1.7.1) MU Specification 3.6.1.7 annotation at deletion of second Frequency from CLB1 to X2.

In a similar manner change Bases MU annotation from ITS mark-up p 3.6-27 CLB1 to X5.

Deleted NUREG and Bases JFD CLB1.

Added NUREG JFD X2 and Bases JFD X5.

The changes reflect the JFDs CLB1 (deleted) and X2 fact that the second Frequency in the NUREG is not part (JFDs p 1 of 3. 2 of 3. and of the CLB.

3 of 3)

ITS Bases mark-up p B 3.6-52 Bases JFDs CLB1 (deleted) and X5 (Bases JFDs p 1 of 5.

4 of 5. and 5 of 5)

RAI 3.6.1.7-2 Restored Completion Time for Required Action B.1 to 2 Specification 3.6.1.7 hour8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months as stated in NUREG and Bases.

Deleted NUREG JFD X1 and Bases JFD X2 associated with the change.

ITS mark-up p 3.6-26 JFD X1 (deleted) (JFDs p 2 of 3)

ITS Bases mark-up p B 3.6-51 Bases JFD X2 (Bases JFDs p 3 of 5)

Retyped ITS p 3.6-20 Retyped ITS Bases p B 3.6-45

.AI 3.6.1.7-3 Replaced DOC L3 with DOC LA2 for relocation of vacuum Specification 3.6.1.7 breaker closure detail to Bases and deleted NSHC L3.

Added Bases JFD X4 and annotated Bases markup to reflect CTS mark-up p 1 of 3 relocation of the details to ITS SR 3.6.1.7.1 Bases.

DOCs LA2 and L3 (DOCs p 4 of 6 and 5 of 6)

NSHC L3 (deleted) (NSHCs p 5 of 7)

ITS Bases mark-up p B 3.6-52 and Insert Page B 3.6-52 Bases JFD X4 (Bases JFDs p 4 of 5)

RAI 3.6.1.7-4 (as Deleted changes to NUREG SR 3.6.1.8.3 (ITS SR 3.6.1.7.3) Specification 3.6.1.7 modified) and associated Bases regarding "full open" and deleted NUREG JFD PA2 and Bases JFD PA3.

The NUREG SR Bases ITS mark-up p 3.6-28 contain adequate information to convey intent of the SR without changes to the SR or the Bases.

JFD PA2 (deleted) (JFDs p 1 of 3)

ITS Bases mark-up p B 3.6-53 Bases JFD PA3 (deleted)

(Bases JFDs p 2 of 5)

Retyped ITS p 3.6-21 Retyped ITS Bases p B 3.6-47 Page 9

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages RAI 3.6.1.7-5 Revised ITS 3.6.1.7 Bases JFD DB4 by adding details Specification 3.6.1.7 regarding the scenario that results in the negative pressure transient of greatest concern.

Bases JFD D04 (Bases JFDs p 2 of 5)

RAI 3.6.1.7-6 Revised ITS 3.6.1.7 LCO Bases and Bases JFD DB2 to make Specification 3.6.1.7 it clear that the close function of all 5 vacuum breakers is required (to limit bypass leakage to within ITS Bases mark-up p B 3.6-50 that assumed in analyses).

Bases JFD DB2 (Bases JFDs p 2 of 5)

Retyped ITS Bases p B 3.6-44 New Change The Suppression Chamber-to-Drywell vacuum breaker Specification 3.6.1.7 functional test (i.e.. cycling each vacuum breaker) has been changed from monthly to in accordance with the IST CTS mark-up p I of 3 Program.

DOC L4 (DOCs p 5 of 6 and 6 of 6)

NSHC L4 (NSHCs p 6 of 7 and 7 of 7)

ITS mark-up p 3.6-38 JFD X3 (JFDs p 3 of 3)

ITS Bases mark-up p B 3.6-52 and B 3.6-53 Bases JFD X6 (Bases JFDs p 5 of 5)

Retyped ITS p 3.6-21 Retyped ITS Bases p B 3.6-47 RAI 3.6.1.9-1 Revised DOCs Al. Ml. and L2 reflect origin of ITS Specification 3.6.1.9 3.6.1.9 is NUREG-1434.

RI (rather than NUREG-1433.

RI).

DOCs Al. MI. and L2 (DOCs p I of 6. 2 of 6. and 4 of 6)

RAI 3.6.1.9-2 (as Revised Bases Background and Bases LCO discussion to Specification 3.6.1.9 modified) make clear that system design provides two pumps per subsystem while the LCO only requires one pump per ITS Bases mark-up Insert subsystem and revised Bases JFD DB6 accordingly.

Page B 3.6-57a and Insert Page B 3.6-57c Bases JFD DB6 (Bases JFDs p 2 of 2)

Retyped ITS Bases p B 3.6-52 and B 3.6-53 Page 10

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages RAI 3.6.1.9-4 Revised ITS SR 3.6.1.9.3 Bases MU to include discussion Specification 3.6.1.9 of how the surveillance is done (by introduction of air) and added Bases JFD PA5 for the change.

ITS Bases mark-up p Insert Page B 3.6-57g Bases JFD PA5 (Bases JFDs p I of 2)

Retyped ITS Bases p B 3.6-56 RAI 3.6.1.9-5 Revised CTS MU by replacing Li annotation with A4, Specification 3.6.1.9 added DOC A4 and deleted DOC Li and associated NSHC LI.

CTS mark-up p 2 of 3 DOCs A5 and LI (DOCs p I of 6, 2 of 6. 4 of 6)

NSHC LI (deleted) (NSHCs p 1 of 9)

RAI 3.6.1.9-6 Revised NUREG JFD PA2 and Bases JFD PA3 to make clear Specification 3.6.1.9 that deletion of NUREG SR 3.6.1.7.1 (ITS SR 3.6.1.9.1)

Note is because the Note is intended for designs where JFD PA2 (JFDs p 2 of 5) actuation is automatic (rather than manual as at JAFNPP).

Bases JFD PA3 (Bases JFDs p 1 of 2)

Amendment 259 Revised CTS MU page to reflect CTS Amendment.

No change Specification 3.6.1.9 to any other ITS portions required since the Amendment information is no longer applicable (and is deleted in CTS mark-up p 2 of 3 ITS Section 3.7.1).

RAI 3.6.2.1-1 and RAI Revised CTS MU (replaced A2 annotation with L5). deleted Specification 3.6.2.1 3.6.2.1-6 DOC A2. and added DOC L5 and associated NSHC L5.

Changes address ITS 3.6.2.1. Actions C.A and A.2 (in CTS mark-up p 2 of 4 combination), allow suppression pool temperature to be >

95 0F for more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months without requiring plant DOCs A2 (deleted) and L5 shutdown and cooldown as CTS does. In addition. DOC L5 (DOCs p 1 of 6. 5 of 6. 6 of addresses the relaxed ITS requirement which does not

6) require plant shutdown and cooldown when suppression pool temperature exceeds 105 degrees F as CTS does.

NSHC L5 (NSHCs p 9 of 10 and Replaced A2 with L5 on NUREG MU at Condition C.

10 of 10)

ITS mark-up p 3.6-32 RAI 3.6.2.1-2 Revised CTS MU (replaced A5 annotation with M4 at CTS Specification 3.6.2.1 3.7.A.1). deleted DOC A5. and added DOC M4.

Changes concern the Applicability of CTS and ITS and address the CTS mark-up p 1 of 4 changes for ITS 3.6.2.1 and ITS 3.6.2.3 in the same way.

Replaced A5 with M4 on NUREG MU at Applicability.

DOCs A5 (deleted) and M4 (DOCs p 1 of 6 and 3 of 6)

ITS mark-up p 3.6-31 RAI 3.6.2.1-4 Revised Bases MU by restoring upper case "C" to word Specification 3.6.2.1 "condition" in Actions D.1, D.2. and D.3 Bases.

ITS Bases mark-up p B 3.6-62 Retyped ITS Bases p B 3.6-61 Page 11

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E I,

Source of Change Summary of Change Affected Pages RAI 3.6.2.1-5 Revised Bases MU by deletion of discussion of design of Specification 3.6.2.1 suppression pool water temperature instrumentation and adding reference to description of design contained in ITS Bases mark-up p B 3.6-62 ITS 3.3.4.1 Bases.

Revised Bases JFD DB3 to reflect changes to Bases MU.

Bases JFD DB3 (Bases JFDs p 2 of 2)

Retyped ITS Bases p B 3.6-61 and B 3.6-62 TSTF-206. RO TSTF-206, RO. which allows the option of using a Specification 3.6.2.1 specific Thermal Power of 1% RTP with respect to determining the LCO (and Conditions) applicability, was ITS mark-up p 3.6-31 and incorporated.

(Actual changes were very minor since 3.6-32 almost identical changes to the NUREG and Bases had been made as part of the original ITS preparation.)

Revised JFDs CLB1 and TA1 (JFDs p 1 NUREG MU. revised Bases MU.

and added NUREG and Bases of 1)

JFDs to note incorporation of TSTF-206.

ITS Bases mark-up p B 3.6-59 and B 3.6-60 Bases JFDs CLB1 and TA1 (Bases JFDs p 1 of 2 and 2 of 2)

Retyped ITS p 3.6-26 and 3.6-27 Retyped ITS Bases p B 3.6-58 and B 3.6-59 RAI 3.6.2.3-1 (as Revised ITS SR 3.6.2.3.2 Bases markup by adding word Specification 3.6.2.3 modified)

"required" to make it clearer that the SR is applicable to only the single required RHR pump in a subsystem ITS Bases mark-up p B 3.6-70 rather than both pumps in a subsystem that are provided by design.

Added Bases JFD PA4 to reflect Bases markup Bases JFD PA4 (Bases JFDs p change.

1 of 2)

Retyped ITS Bases p B 3.6-70 RAI 3.6.2.3-3 Revised CTS markup by replacing Li markup annotation Specification 3.6.2.3 with A3 and added DOC A3.

Deleted DOC Li and NSHC L1.

CTS mark-up p 2 of 2 DOCs A3 and LI (deleted)

(DOCs p 1 of 5. 2 of 5. and 4 of 5)

NSHC L1 (deleted) (NSHCs p 1 of 8)

Page 12

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages RAI 3.6.2.3-4 and TSTF-TSTF-230. R1 changes ITS 3.6.2.3 Actions by allowing 8 Specification 3.6.2.3 230.

R1 hour to restore at least one RHR Suppression pool cooling subsystem to Operable when two (both) subsystems DOC L4 (DOCs p 5 of 5) are inoperable prior to entering Conditions and Actions that require a plant shutdown and cooldown.

The ITS mark-up p B 3.6-35 original ITS submittal contained this allowance without reference to the TSTF.

Changes consist of minor JFDs TA1 and X1 (deleted) revision of DOC L4. annotation of markups and addition (JFDs p 1 of 1) of NUREG JFD TAl (in place of JFD X1) and Bases JFD TA1 (in place of Bases JFD X2) to reflect approval of ITS Bases mark-up p B 3.6-69 TSTF-230.

R1.

and Insert Page B 3.6-69 Bases JFD TA1 (Bases JFDs p 1 of 2)

Retyped ITS Bases p B 3.6-69 RAI 3.6.2.3-6 Revised Bases MU by restoring upper case "C" to word Specification 3.6.2.3 "Condition" in Action A.1 Bases.

ITS Bases mark-up p B 3.6-68 Retyped ITS Bases p B 3.6-69 Amendment 259 Replaced CTS markup page 2 of 2 with Amend 259 page.

Specification 3.6.2.3 Amend 259 affects only the CTS markup without any changes to DOCs.

NUREG markup. etc.. since the changed CTS mark-up p 2 of 2 CTS text is addressed in ITS 3.7.1. RHRSW System.

Fditorial Corrected Bases MU insert page B 3.6-67 by addition of Specification 3.6.2.3 JFD DBI annotation at first insert.

ITS Bases mark-up p Insert Page B 3.6-67 RAI CTS 3.7.A.3-1 Revised CTS MU page 2 by adding annotation for CTS Specification 3.6.2.4 3.7.A.3.

No change to DOCs or ITS text necessary.

CTS mark-up p 2 of 3 Editorial Corrected NUREG markup page 3.6-69 at Condition A by Specification 3.6.2.4 deletion of reference to "M1" in left margin.

DOC M1 does not exist.

ITS mark-up p 3.6-39 RAI 3.6.4.1-1 (as Revised ITS 3.6.4.1 Conversion Package by replacing DOC Specification 3.6.4.1 modified)

A5 with DOC L5 and associated NSHC L5.

DOC L5 addresses the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months allowed by ITS 3.6.4.1. Condition A. to CTS mark-up p 2 of 4 restore Secondary Containment to an Operable status prior to requiring a plant shutdown when Secondary DOCs A5 (deleted) and L5 Containment is inoperable during movement of fuel when (DOCs p 2 of 8 and 8 of 8) the plant is operating in MODE 1. 2. or 3.

NSHC L5 (NSHCs p 9 of 10 and 10 of 10)

Page 13

.10

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages TSTF-332. R2 and BWROG-TSTF-322, R2 revises the sentence structure and phrases Specification 3.6.4.1 ED-8 used in NUREG SR 3.6.4.1.5 (ITS SR 3.6.4.1.4) to more clearly convey that the intent of the SR is to verify ITS mark-up p 3.6-49 that Secondary Containment is Operable (intact/leak tight).

Bases changes that reflect TSTF-322, R2 (as JFD TA2 (JFDs p 1 of 2) modified by "editorial" changes BWROG-ED-8) were also made.

NUREG JFD TA1 and Bases JFD TA1 were added to ITS Bases mark-up p B 3.6 reflect incorporation of the TSTF.

101 and Insert Page B 3.6 101 Bases JFD TA2 (Bases JFDs p 2 of 2)

Retyped ITS p B 3.6-38 Retyped ITS Bases p B 3.6-88 and B 3.6-89 RAI 3.6.4.2-1 Revised DOC A3 by deletion of those portions of the DOC Specification 3.6.4.2 that addressed ITS 3.6.4.2. ACTIONS Note 2 (separate Condition entry allowed for each penetration).

Added CTS mark-up p 4 of 7 DOC L8 and associated NSHC L8 to address ACTIONS Note 2.

Revised CTS markup and NUREG markup to reflect addition DOCs A3 and L8 (DOCs p 1 of of DOC L8 in place of part of DOC A3.

10 and 9 of 10)

NSHC L8 (NSHCs p 14 of 17 and 15 of 17)

ITS mark-up p 3.6-50

---,1 3.6.4.2-2 (as Replaced DOC A5 with DOC L9 and associated NSHC L9 to Specification 3.6.4.2 modified) address addition of ITS 3.6.4.2, ACTION D.1 Note.

The ACTION D.1 Note does not allow "default" to ITS 3.0.3 CTS mark-up p 5 of 7 while the Completion Times for ACTIONS A.1 and B.1 allow 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (or 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) to isolate an inoperable DOCs A5 (deleted) and L9 penetration prior to requiring plant shutdown under ITS (DOCs p 2 of 10. 9 of 10.

3.6.4.2. ACTION C.1 and C.2.

Revised CTS markup and and 10 of 10)

NUREG markup to reflect addition of DOC L9 in place of DOC A5.

NSHC L9 (NSHCs p 16 of 17 and 17 of 17)

ITS mark-up p 3.6-52 RAI 3.6.4.2-3 Replaced DOC L6 with DOC A6 and deleted NSHC L6.

Specification 3.6.4.2 Revised CTS markup to reflect changes to DOCs.

Changes reflect NRC reviewer comment that the details regarding CTS mark-up p 7 of 7 conduct of LOGIC SYSTEM FUNCTIONAL TEST is encompassed within the ITS Definition.

DOCs A6 and L6 (DOCs p 2 of 10 and 9 of 10)

NSHC L6 (deleted) (NSHCs p 11 of 17)

RAI 3.6.4.2-4 Revised Bases Applicability markup by restoring the last Specification 3.6.4.2 sentence of Applicability as cited by NRC reviewer.

Original submittal had deleted the sentence.

Deleted ITS Bases mark-up p B 3.6 associated Bases JFD PA3.

104 Retyped ITS Bases p B 3.6-92 Page 14

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages RAI 3.6.4.2-5 Revised ACTIONS A.1 and A2 Bases markup and ITS SR Specification 3.6.4.2 3.6.4.2.1 Bases markup by deletion of changes cited by NRC reviewer and deleted associated Bases JFD PA3.

ITS Bases mark-up p B 3.6 (Changes had originally inserted the phrase "isolation 105 and B 3.6-107 devices" in place of SCIVs.)

Bases JFD PA3 (deleted)

(Bases JFDs p 1 of 2)

Retyped ITS p B 3.6-38 Retyped ITS Bases p B 3.6-93 and B 3.6-95 RAI 3.6.4.2-6 Corrected error in LCO Bases markup cited by NRC Specification 3.6.4.2 reviewer.

(Changed markup annotation "X4" to "X3" since Bases JFD X4 does not exist.)

ITS Bases mark-up p B 3.6 103 TSTF-45. R2 TSTF-45, R2 exempts valves that are locked, sealed, or Specification 3.6.4.2 otherwise secured in position from the periodic (31 days) verification of proper position required by ITS SR ITS mark-up p 3.6-53 3.6.4.2.1.

Revised NUREG SR 3.6.4.2.1 markup, revised Bases markup for SR 3.6.4.2.1.

Added NUREG JFD TA2 and JFD TA2 (JFDs p 1 of 1)

Bases JFD TA2 to reflect incorporation of TSTF-45. R2.

ITS Bases mark-up p B 3.6 107 and Insert Page B 3.6 107 Bases JFD TA2 (Bases JFDs p 1 of 2)

Retyped ITS p B 3.6-42 Retyped ITS Bases p B 3.6-95 TSTF-269, R2 TSTF-269. R2 exempts valves that are locked, sealed, or Specification 3.6.4.2 otherwise secured in position from the periodic (31 days) verification of proper position required by ITS DOC M5 (DOCs p 4 of 10) 3.6.4.2. ACTION A.2.

Revised DOC M5 by adding discussion of ACTION A.2 Note 2.

Revised NUREG 3.6.4.2. ITS mark-up p 3.6-51 ACTION A.2 markup and revised Bases markup for ITS 3.6.4.2 ACTIONS A.1 and A.2 Bases.

Added NUREG JFD TA3 JFD TA3 (JFDs p 1 of 1) and Bases JFD TA3 to reflect incorporation of the TSTF.

ITS Bases mark-up p Insert Page B 3.6-105 Bases JFD TA3 (Bases JFDs p I of 2)

Retyped ITS p B 3.6-40 Retyped ITS Bases p B 3.6-93 Editorial JFDs corrected to reflect approved TSTF.

Specification 3.6.4.2 JFD TA1 (JFDs p 1 of 1)

Bases JFD TAl (Bases JFDs p 1 of 2)

Page 15

i-i

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages RAI 3.6.4.3-2 and RAI Changes reflect maintaining current licensing basis with Specification 3.6.4.3 3.6.4.3-3 regard to periodic test (cycling) of decay heat cooling valves 3A and 3B (rather than to periodically verify CTS mark-up p 3 of 10 that the valves are open as was proposed in the original submittal).

Revised CTS markup and NUREG SR 3.6.4.3.4 DOC A4 (DOCs p 1 of 8) markup by deletion of the SR Note that was added in original submittal to allow the LCO to be met during SR ITS mark-up p 3.6-56 performance.

Changes to the SR made in response to RAI 3.6.4.3-2 make the Note unnecessary and the NUREG markup ITS Bases mark-up p B 3.6 and Bases markup were revised accordingly.

DOC A4 was 114 and Insert Page B 3.6 revised to reflect deletion of the SR Note.

114 Retyped ITS p 3.6-45 Retyped ITS Bases p B 3.6 103 RAI 3.6.4.3-4 (as Revised DOC M5 to more clearly explain why addition of Specification 3.6.4.3 modified)

ITS 3.6.4.3.

ACTIONS C and E.1 Note, is "more restrictive" than CTS requirements.

DOC M5 (DOCs p 4 of 8 and 5 of 8)

RAI 3.6.4.3-5 and RAI Revised CTS 4.7.B.2 markup to show it retained rather Specification 3.6.4.3 3.6.4.3-6 than deleted (changed markup annotation from L2 to A5).

Replaced DOC L2 (and associated NSHC L2) with DOC A5.

CTS mark-up p 3 of 10 Changes discuss the fact that verification of operability of redundant systems, structures and DOCs A5 and Li (DOCs p 2 of components is implicit in the use of CTS and ITS and 8 and 7 of 8) that placing the operable SGT subsystem in service (as required by ITS 3.6.4.3, ACTION C.1) satisfies CTS NSHC L2 (deleted) (NSHCs p 3 4.7.B.2.

of 8)

RAI 3.6.4.3-7 Replaced DOC L5 with DOC A6 and deleted NSHC L5.

Specification 3.6.4.3 Revised CTS markup to reflect changs to DOCs.

Changes reflect NRC reviewer comment that the details regarding DOCs A6 and L5 (deleted) conduct of LOGIC SYSTEM FUNCTIONAL TEST is encompassed (DOCs p 2 of 8 and 8 of 8) within the ITS Definition.

NSHC L5 (deleted) (NSHCs p 8 of 8)

RAI 3.6.4.3-8 Revised Bases MU by restoring upper case "C" to word Specification 3.6.4.3 "condition" in ACTIONS A.1 Bases.

ITS Bases mark-up p B 3.6 111 Retyped ITS Bases p B 3.6-99 TSTF-362, RO TSTF-362.

RO revises the Bases to reflect Generic Letter Specification 3.6.4.3 99-02 regarding laboratory testing of charcoal filters.

The reference to Regulatory Guide 1.52 in ITS SR ITS Bases mark-up p B 3.6 3.6.4.3.2 Bases discussion is deleted and Bases 113 and B 3.6-114 References were revised accordingly.

Bases JFD TA1 was added to reflect incorporation of the TSTF.

Bases JFD TAl (Bases JFDs p 2 of 2)

Retyped ITS p 3.6-102 Retyped ITS Bases p B 3.6 102 and B 3.6-103 Page 16

i-i

SUMMARY

OF CHANGES TO ITS SECTION 3.6 - REVISION E Source of Change Summary of Change Affected Pages Amendment 269 Revised CTS markup to reflect CTS Amend 269.

No changes Specification 3.6.4.3 were made to CTS portions associated with ITS 3.6.4.3.

CTS mark-up p 2 of 10 through 4 of 10 RAI S3.6.2.4-1 Markup annotation referred to CLB1 which does not exist. NUREG Specification 3.6.2.4 Changed markup annotation to DBI as cited by NRC reviewer.

ITS Bases mark-up p B 3.6-71 RAI S3.6.3.2-1 Revised NUREG JFD DB1 and Bases JFD DB1 to more fully NUREG Specification 3.6.3.2 explain that deletion of NUREG 3.6.3.2 is based on the fact that the drywell cooling system fans at JAFNPP are JFD DB1 (JFDs p 1 of 1) not designed for operation during DBA conditions.

Bases JFD DB1 (Bases JFDs p 1 of 1)

RAI 3.7.A.3-1 Revised CTS MU to address relocation of shutdown CTS 3.7.A.3 requirements of CTS 3.7.A.8 as they apply to CTS 3.7.A.3.

Revised DOC RI to correct the erroneous CTS mark-up p 1 of 2 and 2 reference to surveillance requirements associated with of 2 CTS 3.7.A.3 and to address relocation of CTS 3.7.A.8 shutdown requirements to ODCM.

DOC R1 (DOCs p 1 of 2 and 2 of 2)

RAI 3.7.A.3-2 Revised DOC R1 by including a brief discussion noting CTS 3.7.A.3 that the only primary containment purge path that exists is. by design, via the SGT System.

DOC RI (DOCs p 1 of 2)

Editorial The proper acronym was added to DOC RI.

CTS 3.7.A.3 DOC RI (DOCs p 1 of 2 and 2 of 2)

Page 17

ITS CONVERSION PACKAGE SECTION 3.6 - CONTAINMENT SYSTEMS I

'I JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.1 Primary Containment MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

DISCUSSION OF CHANGES (DOCs) TO THE CTS NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC)

FOR LESS RESTRICTIVE CHANGES MARKUP OF NUREG-1433, REVISION 1, SPECIFICATION JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION I MARKUP OF NUREG-1433, REVISION 1, BASES JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION 1, BASES RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES Ai/

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.1 Primary Containment MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS) 4

-t

JA1,141

1.

mofsel....

- ne reactor to in the refuel auds Whom the "odf Switch to Is the Reftol "ofde peoitti.

Nlb0 the me" switch is is the kfisl position. the refueling

toer eoto" OFr In "twice.

a.

Ean Node - an this mam the r"oater *"stom proesure i oat or shove 050 polsl me the Boseter Preteetlm*

System Is meolsisd with AM prawtetlmo osealulleo the 15 Iporess hith flum trip) sad the M Imterlecks Is "tweice.

3.

kutdoum Neds - no remoter it i

the shout down we" VWS the S eter e Switch toe In the shetu no" peIItlee.

0.

flat gbsoeus mowes odiltiomn as ve with reetA, coaolest temperatwre >212oP.

h.

Cold utsu sea eoudities am shew with reseter eolant temperature

&L2129U.

me the toaster vessel veste.

bCod olbsta mem qo conditions a00s showsd

4.

8stulP"AOt Ite~adf i to is sofet me low "cofme minolem sis1r lieiotleti valve casses tripf to bkpsoa*Jd, the Nooeto~r Pretet00im Sytml Is omerlis"l with Al(1

""re~ e me M

W13 N m4ll l

SnL A

system trips mad control rod withdrawal lItorlock is o rv"ice.

J.

Nibj A syates. auhoetem. train. component or device shall be GNMEAl or have OPIRABILl1M Whea it is capable of performing Its specified functlem().

Implicit In this dofiitIon shall he the e*aoiptm thet all ncesasry atteodant iulotriststil.

cstorols. semi and mergeacy electrical power "Murome, eooling or soal water, l1bricatloa or other amilety equipment that are required for the apsten. subeystem. trai.

cran pemet or dovies to perform Its fuactiamls) are aloe sapable of performioe their related support fumetlesut).

a.

ftESLj"

- operatig mesems that a system or esopaNOt is porforming its intendsd fuactions Is Its rWeuIred seoaer.

L.

w

- Inteirval between the end of one roefuling euty aed the end of the subhequent SOrNiafna tions.

'I, 1+

I' I-.

I I I.

All samol eomtagimet iolatieon volves on slid!

eseCoeted to the UDactOr Coolent System Of eotgi@lme Obic are *at required to be op.

dering plent accident conditions 0re cloed2.

T10o9 valves say be S-e 0- ZTS 34,k,/.3 4

REVISION E

'5ý C-C' ý ;.

e. we;

ci 1.0 (cont'dl set toi L~z, r,

z

-W.l d powr reeeO To oF at

M or pw. ofe213 MW3t. This is eloe termed 100 percent power an I te dneinii power levl Authorized by the operating licen60. Rated teRam,low, rated coolant flow.

rited sle system pressure, refer to the values of these parameters when the reactor is at rated power (Reference

0.

_er oatio. Reacts power operation Is any operam M w t m ode Switch In th St,.tuPMot Standby or Run posion with the reactor critical a*n 8

I percent rated temlPower.

p.

Raltnr V6210 h

masurl

- Unless otherwise Indicalted.

(enctor vessel priasres Hated in the Tedwl Specifications we those measmed by the reactor vessel eteam spaoe sensor.

0.

ghfmru a

rnouts is the period of time betwo theo a_

ow of e unit prior to refueling and the msrtup of the Plant submeeent to that refueling.

Bt afuty UediW-The safety iibemltsaelimnits.within which.

f.

w reasonable malntmoence of the fuel cladding inte*riy end the react oolran system integity are assmod.

Violation of sucha limit Is cause for u shutdown and review b the Nuclear Regl atory Commo" n before resumption ofMwit opeWraton Operation beyOnd such a rimit may not In tlfoW result in serous consequences but it i---tes an oprtonal Amendmeln No.

4. 21,. I,,-

23 2-2. 239 v

tA--innut Int tv-Secondary containment Integrity means that the reactor building is Intact and th,/

n~ol6 conditiowns swrre mat:

At host one door sn access o nIo da *

(f.

The Standv Gas Treatmwnt System Is opera

.A Automatic vemlation system Iodation days operaleor seemed In the Iolated position.

T.

F~~gavery 3

onths-aIItevl The surveillonce frequency notations I Intervals usedintee specfc~kations we defined as follows:.

NgSLMh Intervals Fflmetnc D

Daily or At least once par 24 doays w

WAnkly At least once per 7 days M

Monthly At bast once per 31 days Ousntedy or At least once per 92 Vas every3 months SA Semiannually or At bast Sone par 184 days every 6 months.

1AM Annually or Yearly At least oncepr 3se days IBM I8 Months At least owe pa S

(6mot1 days)

R Operating Cycle At least once par 24 months 1731 days)

SAO Prior to each reactor startup NA Not aplicalk~ie r,-, ZTrs,:C

,-r/

o 5

lpa'jx 2

' f

-ýAr oý; r4r;j'a 3. 6, /' I

7) sp,, k A W

C ýb

,a.C.( 1C 9 JAFNPP

ýE-, ZS 1AI4J I

(

ACmiow A Amendment No. 4e,4-34, 239

a.

Parlomr ru imed v

em xernin-tion and leaksge rate I

t estl of the Prim a ry Con tanm ent in acc ordanc e J.0:

w ith th Prim ary Containment Le akage Mae T esting..__ _

b ieosrate leakage rats, through each MOSIV is s c I.*...

I 1.5 sclh when tested at x-25 psig. The testing fraque my Is in accordance with the Prim ary

/

oul ontnkminm LeskM Rote TLoJONADQ..

C

n. a per iths, dernontr--"--

to the lekag at f

OAOV-SS. t he Lo aer oln netion system and 14AOV-1 3A,B for the Core Spray system to be less then I I scfm per valve when pneumatically tested at a 45 psig at ambient temperature, or less then 10 gopn per valve If hydrostatically tested at t:/

,0~35 p eol at ml o

t o

aspa m./ -'--

166

,,

I

.1 k

Se-e-X77-->

JAFNPP U4.7 F7 Eý is g"W mgft opm". WwMW dat nq* proce*" dM not vWM Wkwy hoop" &*psuion ChwAw - DrrNW Vocum

5.

p"mwo Suppres" Chsn*w - Mwel vacum

a.

wmn Imbew v comukwwt kdoeft Is "*W.

go

a.

ftch *ywW P*pn"m CIWI*W veown bre" p ý*mn dwift vackan bFGskws dwl dulboal-l-Wildwou0snup i

clodneevcis divw sw be op stjg wd-pogidoned in do MY Pin montmy.

poddon mept dwkq t ý tj 9 wd m spwlftd In 3.7A5.b bdow.

b.

OnS *WA MWFG8dw dm*w vmP" br"kw

b.

When It Is &WmkW dW Gm vgmm bf"ksr 'a my bg non4tft cin so bM as It IS dstm 60-i ops Mikk f0F My clu i n w"m oWsbffityls to be not moo dm 10 opin n kWkaW by do

=

, g. opmW bF.AM sW be emdeW kvno&d*, MW *MY IS days dwmftsr und the powd" I NOM&

kwWWO v" hgs bgm rohmned to rwmiW service.

C.

Each vwuum brmkw vdvo dwA be vbuWv Om dry" v*presdon dw *w vacuwn bre" kwpww to bum Prow moms mice OW my be d twilMs to b@ kwPWWM fOf OPW"-

opwation in accordum with dw kwwvks TOO proom".

d.

Ddd0d

`on-cý bak tog ft be 24 nwnft.

fat 0.25 in. wetwhnin,

. wi 90 d" Gt NjqN-,J-/ 'TM,??yeSS;0h Is CPLV%

4P_%) 4P f-a-v%

I Anwr4knwg No. 434. 40'l 282 242 176 PaAe, 4 v4 REVISION E

JAFNPP w

-5 7?

e. -

t; : 0 M

/

t.

The self ectueted vacum breakers, sholl osp1 Front end after the date thatm of t proms@

Once per 24 months, each vacuum reaker sliN be

g.

Fr omelmn athe dae thatw neots o

breakers is tested to dotwmine that th force required to open made or f oud to be inaperaoe for any moeon. the the vacuum breaker does not exceed th force vocuum broeker didl be locked domed and reactor specified in Specification 3.7.A.5.f and each vacuum operaion i permsib eony during tho uccooding breaker dhl be kwipected and verified to meet seven doys unless such vauum breaker is sooner design requiemants.

made operable. provided that the repair procedure doe not videto pdrmy containment intoegry.

ArmndmeWntN.

3r-4 4,232

'ca.

8 179 REVISION E I

.- *:.;--v.*::'*::

(.

3.C.f./ 9 3.7 (Cont'd) 47(old (1)

The drywell to torus ditferential pressure shall be established within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ot exceeding 15%

rated thermal power during startup. The differential pressure may be reduced to less than the imit up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing thermal power to less than 15% of rated before a plant shutdown.

(2)

The differental pressure may be decreased to less than 1.7 psid for a maxinuml af our (4) hours during required operability testing of the HPCI. RCIC, and Suppression Chamber Drywel Vacuum Breaker System.

(3)

It 3.7.A.7.a above cannot be met, restore the differential pressure to within omits within eight hours or reduce thermal power to less than 15%

of rated within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

t.

if the specifications of 3.7.A.1 through 3.7.A.5 cannot be

8.

Not applica met the reactor shall be In the cold condition wtn(*

.o hours.

'V Amendment No. w, J,, 221 r:

ble.

C 180a

?-11 Ai It

)

JAFNPP rA C T?4*j

A*ndi~aIN:

Asuiinukv iii:uu*

AMM t th OWMN 82" f 0 Pimty ndsecndryApplies to the prunay and secondary containmtent Inerty.

To sassue the ntegrkty of tdo piliey end secondary cntaiflmi To verify the integrity of the primary and secondary containiment A

systems.

A. -ififl CU&

M A.

Bft.. XSUtMkNIU I.

The level frain to bottom of ft tow Ond teOmPOrture The tows water level and temperature sh be moitored of the water in the toIsm be maintained within the tid Solow g limitsa wheee the reactor is Critical or whneerth racorcolat emerture is greater then The SC d'surf of the Kw 212OF and irrdiated fuel is in the reactor vesse:

the wter Of the tous e

a.

mxwium W o 1400 fWt.enemver thee is indiation of relief valve opeaionU or

b.

Mkdswfl hwve of U3.S feset.

testing which adds heat to the suppresson pool. the pool temperature shell be continuously recorded Unta the heat The torM wae levd may be outside the above addition is terminated. The operator wd verify dhet uilts for a mandaiuml of four 441 hours0.0051 days 0.123 hours 7.291667e-4 weeks 1.678005e-4 months "as result Of saveag temperature Is within applicable limts every 6 u

o lt...

CS minutes. in Nsu of continuous recording, th operat hkinxO oa sboty u nom of Pa. RC.C N M. C.

thOg e temperture every 5 Minutes.

and the Orywell TOns Vacuum Relief System.

s" t

Whenever there is indiction of relif "Wle Operation with the temperatur of the su esslion pool reching I OOF operation maximu or Maoe end the primary coolant system prssure Wgeatet II w turk ntmperowur shaMb oF then 200 psig. an e6xernl visuexamnti of thO torus afi"l be conducted before re*mio*v Power opertion Amenomant,N4o. 4S'a-).-

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JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.1 Primary Containment DISCUSSION OF CHANGES (DOCs) TO THE CTS

DISCUSSION OF CHANGES ITS: 3.6.1.1 - PRIMARY CONTAINMENT ADMINISTRATIVE CHANGES Al In the conversion of the James A. FitzPatrick Nuclear Power Plant (JAFNPP) Current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS) certain wording preferences or conventions are adopted that do not result in technical changes.

Editorial changes. reformatting, and revised numbering are adopted to make the ITS consistent with the conventions in NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4",

Revision 1 (i.e., Improved Standard Technical Specifications (ISTS)).

A2 CTS 3.7.A.2 reference to "Primary Containment Integrity" has been deleted since the CTS definition of Primary Containment Integrity in CTS 1.O.M is incorporated into ITS 3.6.1.1, 3.6.1.2 and 3.6.1.3 and is no longer maintained as a separate definition in the ITS.

Proposed ITS 3.6.1.1 requires that the primary containment shall be OPERABLE.

The definition of OPERABLE and the subsequent ITS 3.6.1.1 LCO, ACTIONs, and Surveillances are sufficient to encompass the requirements of the CTS definition.

This change removes any confusion which may exist between the definition and the specific requirements of the LCO and is a presentation preference consistent with NUREG-1433, Revision 1.

Since all aspects of the Primary Containment Integrity definition requirements, along with the remainder of the LCOs in the Containment Systems Primary Containment section (i.e., air locks, isolation valves, suppression pool, etc.) are maintained in subsequent Specifications of ITS this change is considered to be administrative only.

A3 CTS 4.7.A.2.a requirement, to perform required visual examination and leakage rate testing of the Primary Containment, has been changed.

Proposed ITS 3.6.1.1 includes an exception for primary containment air lock testing. This change is acceptable since Proposed ITS 3.6.1.2 will provide for primary containment airlock testing.

Therefore. this change is considered to be a presentation preference consistent with NUREG 1433, Revision 1, and an administrative change only.

TECHNICAL CHANGES - MORE RESTRICTIVE M1 CTS 3.7.A.8 requires the reactor to be in the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the requirements of CTS 3.7.A.2 (primary containment integrity) cannot be met.

ITS 3.6.1.1 Required Action B.1 requires the plant to be in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the Required Action and associated Completion Time of ITS 3.6.1.1 ACTION A (Li) is not met.

In addition. ITS 3.6.1.1 Required Action B.2 requires the plant to be in MODE 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (M2).

This change is more restrictive because it provides an additional Page 1 of 6 Revi sion E JAFN1PP

DISCUSSION OF CHANGES ITS: 3.6.1.1 - PRIMARY CONTAINMENT TECHNICAL CHANGES - MORE RESTRICTIVE M1 (continued)

-requirement to place the plant in MODE 3 in 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months (1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from Required Action A.1 (L1) and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from Required Action B.1).

The allowed Completion Times in Required Action B.1 and B.2 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.

However, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time ensures timely action is taken to place the plant in a shutdown condition (MODE 3).

The consequences of any design bases event is significantly reduced when plant is shutdown.

This change is consistent with NUREG-1433, Revision 1.

M2 CTS 4.7.A.5.d requires the drywell to suppression chamber leak rate to be verified.

ITS SR 3.6.1.1.2 adds the Frequency requirement that if two consecutive leak tests fail, the leak test must be repeated every 12 months until two consecutive leak tests pass.

Two consecutive test failures would indicate unexpected primary containment degradation, and increasing the Frequency to once every 12 months establishes the acceptability of the drywell to suppression chamber leakage sooner.

The increased Frequency of 12 months for the drywell to suppression chamber leak test following two consecutive test failures imposes additional operational requirements and time restraints.

Therefore, this change is considered to be more restrictive but necessary to ensure suppression pool bypass leakage is maintained within limits.

M3 The CTS Applicability of the Primary Containment in CTS 3.7.A.2 is whenever the reactor is critical or when the reactor water temperature is above 212°F and fuel is in the reactor vessel.

In addition, there is an exception in CTS 3.7.A.2. to not require primary containment integrity to be met during low power physics tests at atmospheric pressure and power levels not to exceed 5 *Wt.

however any change to this requirement is discussed in the Discussion of Changes for ITS 3.10.8.

The scope of the current Applicability covers MODE 1. 3 and portions of MODE 2 operations.

The Applicability in ITS 3.6.1.1 is MODES 1, 2 and 3.

This change is considered more restrictive since the containment will be required to be Operable at all times in MODE 2 even prior to any plant startup when reactor coolant temperature may be below 212°F.

This change is consistent with NUREG-1433. Revision 1.

Page 2 of 6 Revi sion E

,JAFNPP

DISCUSSION OF CHANGES ITS: 3.6.1.1 - PRIMARY CONTAINMENT TECHNICAL CHANGES - MORE RESTRICTIVE M4 The CTS 4.7.A.5.d requirement that the drywell to suppression chamber leak rate test be conducted at 1 psid is being changed to a differential pressure of k 1 psi.

Performing the test at precisely 1 psid is not

-possible and actual test performance is conducted at slightly higher differential pressure to ensure test differential pressure does not decrease to less than 1 psi.

The higher test differential pressure increases leakage resulting in conservative (more restrictive) test results.

Therefore, this change is considered to be more restrictive but necessary to allow test performance in strict compliance with the SR and in a conservative manner.

TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC)

LA1 The details of the CTS 1.0.M definition of Primary Containment integrity that the drywell and pressure suppression chamber are intact and the requirement that manways (CTS 1.0.M.4) are closed are proposed to be relocated to the Bases.

The requirement in ITS LCO 3.6.1.1 that the Primary Containment shall be OPERABLE (see A2) and the definition of Operability is sufficient to ensure the requirements are met.

The ITS 3.6.1.1 LCO Bases states that compliance with this LCO will ensure a primary containment configuration, including hatches (manways), that is structurally sound and that will limit leakage to those leakage rates assumed in the analysis.

This requirement ensures the existing requirements are retained.

As such, these details are not required to be in the ITS to provide adequate protection of public health and safety.

Changes to the Bases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the ITS.

LA2 Not used.

LA3 The details in CTS 3.7.A.5.e that the drywell to suppression chamber leakage rate limit of & 71 scfm shall be monitored via the suppression chamber 10 minute pressure transient is proposed to be relocated to the Bases.

The requirement in ITS SR 3.6.1.1.2 to verify the suppression chamber pressure increase is s 0.25 in. water gauge/minute for a 10 minute period is sufficient to ensure the requirement is met.

The details in the Bases of SR 3.6.1.1.2 will ensure the test is performed consistent with the current requirements.

As such, these details are not required to be in the ITS to provide adequate protection of public health and safety.

Changes to the Bases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the ITS.

LA4 The requirement of CTS 4.7.A.3 (Continuous Leak Rate Monitoring) that when the primary containment is inerted, it shall be continuously Page 3 of 6 Revision E JAFNPP

DISCUSSION OF CHANGES ITS: 3.6.1.1 - PRIMARY CONTAINMENT TECHNICAL CHANGES - MORE RESTRICTIVE (GENERIC)

LA4 (continued) monitored for gross leakage by review of the inerting system makeup requirements is proposed to be relocated to the UFSAR.

The requirements in ITS LCO 3.6.1.1, that the Primary Containment shall be Operable, the requirement in ITS LCO 3.6.1.2, that two primary containment air locks shall be Operable, the definition of Operability, and the requirements in SR 3.6.1.1.1 and SR 3.6.1.2.1 to perform required visual examinations and leakage rate testing in accordance with the Primary Containment Leakage Rate Testing Program are sufficient to ensure all Primary Containment Leakage limits are met. As such, this Surveillance is not required to be in the ITS to provide adequate protection of public health and safety. Changes to the UFSAR will be controlled by the provisions of 10 CFR 50.59.

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li CTS 3.7.A.2 does not provide any time to restore the primary containment to Operable status if it is found to be inoperable.

Entry into CTS 3.7.A.8 is required and the plant is required to be in cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ITS 3.6.1.1 ACTION A has been added to allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore primary containment to OPERABLE status.

ITS 3.6.1.1 ACTION A provides 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore the primary containment to OPERABLE before proceeding to ACTION B and the subsequent MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Ml) and MODE 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (12). The additional one hour allowed to restore primary containment provides a period of time to correct the problem commensurate with the importance of maintaining primary containment OPERABILITY during MODES 1, 2, and 3.

Additionally, the one hour period ensures the probability of an accident (requiring containment OPERABILITY) occurring during periods where primary containment is inoperable is maintained at a minimum.

L2 CTS 3.7.A.8 requires the reactor to be in the cold condition (MODE 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the requirements of CTS 3.7.A.2 (primary containment integrity) cannot be met.

ITS 3.6.1.1 Required Action B.2 requires the plant to be in MODE 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months if the Required Action and associated Completion Time (primary containment restored to OPERABLE status in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) of ITS 3.6.1.1 ACTION A (L1) is not met.

However, ITS 3.6.1.1 Required Action B.1 requires the plant to be in MODE 3min 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (MU).

This change is less restrictive because it extends the time for the plant to be in MODE 4 from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months (1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from Required Action A.1 (Li) and 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months from Required Action B.1).

The allowed Completion Times in Required Actions B.1 and B.2 are reasonable, based on operating experience, to reach the required plant conditions from Revision E JAFNPP Page 4 of 6

DISCUSSION OF CHANGES ITS: 3.6.1.1 - PRIMARY CONTAINMENT TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 (continued) full power conditions in an orderly manner and without challenging plant

-systems.

The consequences of an accident are not significantly increased because ITS 3.6.1.1, Required Action B.1 will require the plant be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months once the determination is made that the Required Action or Completion Time associated with the primary containment being inoperable cannot be satisfied.

This change reduces the time the reactor would be allowed to continue to operate once the condition is identified.

The consequences of a LOCA are significantly mitigated when the reactor is shutdown and a controlled cooldown is already in progress.

This change is consistent with NUREG-1433, Revision 1.

L3 The requirement in CTS 4.7.A.1 to perform a visual inspection of the accessible interior surfaces of the drywell and above the water line of the torus (suppression chamber) once per 24 months for evidence of deterioration is proposed to be deleted.

The visual examination required by CTS 4.7.A.2.a (ITS SR 3.6.1.1.1) duplicates the visual inspection (examination) required by CTS 4.7.A.1 except for the Frequency of the required examinations.

CTS 4.7.A.2.a (ITS SR 3.6.1.1.1) is required by the Primary Containment Leakage Rate Testing Program, which is based on 10 CFR 50, Appendix J, Option B, to be performed prior to each Type A test and two additional times during each 10 year interval.

Thus the CTS 4.7.A.2.a (ITS SR 3.6.1.1.1) required visual examination is performed at least 3 times in each 10 year period while the CTS 4.7.A.1 required visual inspection is performed once per 24 months (or five times in a 10 year period).

Additional examinations are performed as required by the Inservice Inspection (ISI) Program and every five years as required by the Maintenance Rule.

The results of examinations conducted over more than 20 years of plant operation and through 14 refuel outages has shown that no significant deterioration has taken place.

This operating experience base demonstrates that performing the visual examinations at the Frequency required by the Primary Containment Leakage Rate Testing Program (at least three examinations in a 10 year period) is adequate to detect significant deterioration of the accessible interior surfaces of the drywell and above the water line of the suppression chamber.

As such, performing the CTS 4.7.A.1 required visual inspections once per 24 months is not required to provide adequate protection of public health and safety.

Changes to the Primary Containment Leakage Rate Testing Program are controlled by the provisions of 10 CFR 50.59.

Page 5 of 6 Revision E JAFNPP

DISCUSSION OF CHANGES ITS: 3.6.1..1 - PRIMARY CONTAINMENT TECHNICAL CHANGES - RELOCATIONS None Page 6 of 6 Revi si on E JAFNPP

I /

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.1 Primary Containment NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC) FOR LESS RESTRICTIVE CHANGES I\\

i

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.1 - PRIMARY CONTAINMENT TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

The proposed change adds an ACTION to allow one hour to restore the primary containment to OPERABLE status.

The addition of one hour allows restoration of primary containment within a period of time commensurate with the importance of maintaining primary containment OPERABILITY during MODES 1. 2, and 3.

Also, the one hour period to restore primary containment ensures that the probability of an accident (requiring primary containment OPERABILITY) occurring during periods where primary containment is inoperable is minimal.

This change allows the plant a more lenient shutdown path than currently exists, permitting the shutdown (if primary containment OPERABILITY cannot be restored) to proceed in a more orderly and controlled manner.

This change will not allow continuous operation when components are inoperable or parameter limits are not met.

This change to the Completion Times to attempt to restore primary containment OPERABILITY is not assumed in the initiation of any analyzed event.

Therefore, the probability of an accident previously evaluated is not significantly increased.

In addition, the consequences of an event occurring during the proposed primary containment restoration Completion Time are the same as the consequences of an event occurring during the existing Completion Times.

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

2.

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

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

This change to the Completion Times to attempt to restore primary containment OPERABILITY is not assumed in the initiation of any analyzed event.

In addition, the consequences of an event occurring during the proposed primary Revision E Page 1 of 6 JAFNPP

.,1 NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.1 - PRIMARY CONTAINMENT TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li CHANGE

2.

(continued) containment of an event this change of accident restoration Completion Time are the same occurring during the existing Completion will not create the possibility of a new from any accident previously evaluated.

as the consequences Times.

Therefore, or different kind

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change does not involve any physical alteration of plant systems, structures or components. changes in parameters governing normal plant operation, or methods of operation.

The relaxation in the time allowed to initiate a plant shutdown (allowing one hour to attempt to restore primary containment OPERABILITY prior to initiating a plant shutdown) represents a relaxation over the provisions of the current definition of Limiting Condition for Operation.

However, this relaxation is acceptable based on the small probability of an event requiring primary containment OPERABILITY and the desire to minimize transients.

This change will not affect a margin of safety because it has no impact on the safety analysis assumptions.

The Completion Time to restore primary containment OPERABILITY is not assumed in any analyzed accidents.

The proposed change will enhance plant safety by providing an opportunity to avoid a shutdown transient by the restoration of primary containment OPERABILITY within a reasonable amount of time.

Therefore, this change will not involve a significant reduction in a margin of safety.

Page 2 of 6 Revision E JAFNPP

/

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.1 - PRIMARY CONTAINMENT TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change does not involve any physical alteration of plant systems, structures or components. changes in parameters governing normal plant operation, or methods of operation.

The proposed change modifies the Completion Times for Shutdown Actions when a Required Action and associated Completion Time specified in the Technical Specifications cannot be met.

The proposed change does not increase the probability of an accident because the change extends the time allowed for the pl ant to get to Cold Shutdown from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Shutdown Completion Times are not assumed in the initiation of any analyzed event.

The change will not allow continuous operation with the primary containment inoperable.

The consequences of an accident are not significantly increased because ITS 3.6.1.1, Required Action B.1 will require that the plant be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months once the determination is made that the Required Action or Completion Time associated with the primary containment being inoperable cannot be satisfied.

This change reduces the time the reactor would be allowed to continue to operate once the condition is identified.

The consequences of a LOCA are significantly mitigated when the reactor is shutdown and a controlled cooldown is already in progress.. In addition, the consequences of an event occurring during the proposed shutdown Completion Time are the same as the consequences of an event occurring during the existing shutdown Completion Time.

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

JAFNPP Page 3 of 6 Revision E

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.1 - PRIMARY CONTAINMENT TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 CHANGE

2.

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

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

The shutdown Completion Times are not assumed to be the initiator of any analyzed accident.

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

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation. or methods of operation.

The change extends the time allowed for the plant to get to Cold Shutdown from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the Required Action or Completion Time associated with an, inoperable containment cannot be satisfied.

There is no significant reduction in the margin of safety because ITS 3.6.1.1, Required Action B.1 will require that the plant be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months once the determination is made that the Required Action or Completion Time of ITS 3.6.1.1 ACTION A cannot be satisfied.

This concurrent change reduces the time the reactor would be allowed to continue to operate once the condition is identified.

The consequences of a LOCA are significantly mitigated when the reactor is shutdown and a controlled cooldown is already in progress.

In addition, this change provides the benefit of a reduced potential for a plant event that could challenge safety systems by providing additional time to reduce pressure in a controlled and orderly manner.

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

Page 4 of 6 Revision E JAFNPP

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.1 - PRIMARY CONTAINMENT TECHNICAL CHANGES -LESS RESTRICTIVE (SPECIFIC)

L3 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change deletes a requirement to perform a visual inspection of the accessible interior surfaces of the drywell and above the water line of the suppression chamber once per 24 months.

The same visual inspection is required by other requirements at other (less frequent) intervals.

The probability of an accident is not increased by elimination of a surveillance requirement that is not assumed to be the initiator of any analyzed event.

The consequences of an accident are not significantly increased because the same visual inspection (examination) is required by CTS 4.7.A.2.a (proposed ITS SR 3.6.1.1.1),

the Inservice Inspection (ISI) Program, and the Maintenance Rule.

Past performance of CTS 4.7.A.1 and these other requirements has shown that evidence of deterioration of the accessible interior surfaces of the drywell and above the water line of the suppression chamber would be detected under the reduced examination Frequency requirements of CTS 4.7.A.2.a (proposed ITS SR 3.6.1.1.1) prior to the deterioration being significant.

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

2.

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

The proposed change does not involve any physical alteration of plant systems, structures or components. changes in parameters governing normal plant operation, or methods of operation.

The proposed change will still ensure visual examinations are performed as required by CTS 4.7.A.2.a (proposed ITS SR 3.6.1.1.1). the Maintenance Rule and the ISI program at a Frequency that is adequate to detect evidence of deterioration prior to the deterioration being significant.

Therefore.

this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

Page 5 of 6 Revision E 3AFN1PP

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.1 - PRIMARY CONTAINMENT TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L3 CHANGE

3.

-Does this change involve a significant redluction in a margin of safety?

The proposed change increases the interval between visual examinations of the accessible interior surface of the drywell and above the water line of the suppression chamber for evidence of deterioration by deletion of the CTS 4.7.A.1 requirement to perform the examination once per 24 months.

Industry and plant operating experience demonstrates that examinations performed as required by CTS 4.7.A.2.a (proposed ITS SR 3.6.1.1.1). the Maintenance Rule, and the Inservice Inspection (ISI)

Program are adequate for detection of the evidence of deterioration.

In addition, since the Primary Containment Leakage Rate Test Program contains provision for decreasing the interval between tests as a result of unsatisfactory test results, the proposed change does not involve a significant reduction in a margin of safety.

Page 6 of 6 Revision E JAFNPP

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.1 Pfimary Containment MARKUP OF NUREG-1433, REVISION I SPECIFICATION

Primary Containment 3.6.1.1 3.6 CONTAINMENT SYSTEMS 3.6.1.1 Primary Containment

-LCO 3.6.1.1 Primary containment shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TINE A.

Primary containment A.1 Restore primary 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable, containment to OPERABLE status.

B.

Required Action and B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

am B.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Rev 1, 04/07/95

[3.7,0 BWR/4 STS 3.6-1 C1., 0

~

a 1.'jvrgr.. 6o/C. t fa..C.--_

n.n m

Dair, V e ewusrnri i MJIr DrniHiTArFMFNTS SR 3.6.1.1.1 Perform required visualeatatosa

/-------Lleakage rate testtnglexcept for prtmarl 44t*

Y *'"

containment air lock, testing, in I~ ~~~P "--......

accordance with Teu U, Pippe"11'x.?

Primary Containment 3.6.1.1 SURVEILLANCE FREQUENCY ist accorda e'with 10

DCFR50, endix J, a modified by approved exempt ns, the leakage ate acceptance cr1 ria are (0.6 2 for the Type B an ype C tests ndý 7test.

SSR 3.6.1.1.2 V erif y]suppression chamber Lq

.,7, A., 43 rsur osnn

'hero minute test4 0.25 inch water gauge per uminute teste te period "i%

4ZUXII1f differential pressure of

?-,je psU drwefsO FNV7 arriIv ch.Ae j

EEmonthst

NOTE----

Only required after two consecutive tests fail and,

P, continues until two consecutive /

tests pass monthsj' Rev 1, 04/07/95 BWR/4 STS I

3.6-2

"4 "

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.1 Primary Containment JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1

-4

-d JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS: 3.6.1.1 - PRIMARY CONTAINMENT RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 Not used.

CLB2 The brackets have been removed on the ITS SR 3.6.1.1.2 Frequency and

-changed from 18 months to 24 months as currently required by CTS 4.7.A.5.d.

CLB3 ITS SR 3.6.1.1 has been revised to reflect CTS Amendment 234 (which

,)

implemented 10 CFR 50, Appendix J, Option B).

The hydrostatic and pneumatic test leakage limits for the LPCI and Core Spray (CS) System air operated testable check valves were not addressed by Amendment 234.

Amendment 40 established the current leakage limits for the LPCI and CS testable check valves and thus ITS SR 3.6.1.1 is revised to specifically exclude the testable check valve testing from the Primary Containment Leakage Rate Test Program leakage limits and testing schedule.

ITS SR 3.6.1.3.11 specifies the leakage limits and testing Frequency for the LPCI and CS testable check valves.

PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl Editorial changes have been made for enhanced clarity or to correct a grammatical/typographical error.

-I PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB1 ITS SR 3.6.1.1.2 has been revised to reflect UFSAR Section 5.2.4.4.

DIFFERENCE BASED ON AN APPROVED TRAVELER (TA)

TA1 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 52, Revision 3, have been 2 incorporated into the revised Improved Technical Specifications.

DIFFERENCE BASED ON A SUBMITTED, BUT PENDING TRAVELER (TP)

None Page 1 of 2 Revision E JAFNPP

JUSTIFICATIONFOR DIFFERENCES FROM NUREG-1433. REVISION 1 ITS: 3.6.1.1 - PRIMARY CONTAINMENT DIFFERENCE FOR ANY REASON OTHER THAN THE ABOVE (X)

X1 ITS SR 3.6.1.1.2, second Frequency to verify drywell to suppression chamber differential pressure leakage rate, in accordance with the Note condition, when two consecutive tests fail and continues until two

-consecutive tests pass, has been included.

The Frequency of 12 months is half of the normal Frequency of ITS SR 3.6.1.1.2 (CTS 4.7.A.5.d) which is consistent with the philosophy utilized in NUREG-1433.

Page 2 of 2 Revision A JAFNPP

.0 JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.1 Primary Containment MARKUP OF NUREG-1433, REVISION 1, BASES

primary Containment B 3.6.1.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.1.1 Primary Containment confine the -ostulaled release of radioactive material.

Th primary contaiment consists o,*a steel esse surrounds the Reactor yr.System ro ides a

tially leak tight tbarrier against an The isolation devices for the penetrations in the primary containment boundary are a part of the containment leak tight barrier.

To mintain this leak tight barrier:

AN4'.

C9

)IC. a iov..L.t UJ a.

All penetrations required to be closed during accident conditions are either:

1.

capable of being closed by an OPERABLE automatic containmnt isolation systm, or

2.

closed by manual valves, blind flangeý, or de-activated automatic valves secured in their closed positions, except as provided in LCO 3.6.1.3, "Primary Containment Isolation Valves (PCIVs)6;

b.

The primary containment air lock is OPERABLE, except

(-)-

. 4 rovided in LCO 3.1.1.2, Primary Containment Air

c. All equipamet hatches are CROs-fsPecA(,4J This Specification ensures that the primary containment, in the event.1 assmptions used in the safety anal1 and 2.

SR 3.6.1.1.1 leakage rate ri L 4 f

-n.

tj

dh-i BWR/4 STS 8 3.6-1 Rev 1, 04/07/gS I

04 4

I eV;$ib.

BASES BACKGROUND (continued)

APPLICABLE conformance with 10 CFR 50, Appendix JL(Ref. 3), as modified by approved exemptions.

The safety design basis for the primary containment is that it must. withstand the pressures and temperatures of the limiting DBA without exceeding the design leakage rate.

The OSA that postulates the maximu release of radioactive material within primary cont~ainmt as Is 0

In the analysis of this accident, it is assumed that primary containment is OPERABLE such that release of fission products to the environment is controlled by the rate of primary containment leakage.

Analytical methods and assumptions involving the primary containment are presented in References I and 2.

The safety analyses assume a nonmechanistic fission-product release following a DBA. which forms the basis for determination of offsite doses.

The fission product release is, in turn, based on an assumed leakage rate from the primary containment.

OPERABILITY of the primary containment ensures that the leakage rate ass, the an alyses is not exceeded.

ia.

ILI

qa4 (continued)

Rev! 1, 0407/9 Rev 1, 04/07/9I REVISION E BWR/4 STS B 3.6-2

-j Primary Containment B 3.6.1.1 BASES LCD structurally sound and that will limit leakage to those (continued) leakage rates assumed in the safety analyses. 181

_nSec)

Individual leakage rates i

for the primary

?nv containment air loc are-addressed in LCO 3.6.1.

Lea APPLICABILITY In HODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment.

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

Therefore, primary containment is not required to be OPERABLE in NODES 4 and 5 to prevent leakage of radioactive material from primary containment.

ACTIONS A.

.In the event primary containment is inoperable, primary containment must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The I hour Completion Tim provides a period of time to correct the problem commensurate with the importance of maintaining primary containmnt OPERABILITY during NOES 1, 2, and 3.

This tim period also ensures that the probability of an accident (requiring primary containment OPERABILITY) occurring during periods where primary containment is inoperable is minimal.

If primary containment cannot be restored to OPERABLE status within the required Completion Tim, the plant must be brought to a VIODE in which the LCO does not apply.

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

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

(continued)

Rev 1, 04/07/g5 BWR/4 STS B 3.6-3

maintaining the pressure suppression function of primary containment requires limiting the leakage from the drywell

-to the suppression chamber.

Thus, if an event were to occur that pressurized the drywall, the stem would be directed throuh the downcomers into the suppressiop -pool. This SR B 3.6-4 Rev 1, 04/07, ind)

/95

- I BWR/4 STS

Primary Containment B 3.6.1.1

. ie SURVEIL REQUIRE LANCE sZL..

1.2 (continued) iconsiderin t i prudent thatth Surve ance eri lunrt outa-e also i

the fact t at copnent lures that might have affected this test ar identified by other primary containment Sb.. Two consecutive test failures, however, would indicate unexpected primary containment degradation; in this event, aS Note indiates, inceasing the Frequency to once every onths3 is required until the situation is remedied aced by passing two consecutive tests.

REFERENCES '

FSAR, Section "2.

oSAR, Section

3.

10 CFR SO, AppendixV77~EiIvZ L---

.01 1-A&6A bJ3,,"r /If' B 3.6-S

+/-)

Rev 1, 04/07/95

&Y~ L ~

BWR/4 STS MMMý i

7(i 4ý1

) --ý) <-"

D V.-'Ao Lta-)

.- A:

/ `4 JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.1 Primary Containment JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1, BASES

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS BASES: 3.6.1.1 - PRIMARY CONTAINMENT RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 Not used.

CLB2 The brackets have been removed on the ITS SR 3.6.1.1.2 Frequency and

-changed from 18 months to 24 months as currently required by CTS 4.7.A.5.d.

The proper justification for performing this test is included.

The test can be performed safely during plant operation.

CLB3 The bracketed values have been corrected consistent with the Primary Containment Leakage Rate Testing Program.

CLB4 ITS SR 3.6.1.1.1 Bases have been revised to reflect Primary Containment Leakage Rate Test Program test Frequency and leakage test and test Frequency are not applicable to the Low Pressure Coolant Injection (LPCI) and Core Spray (CS) System injection line air operated testable check valves.

CTS Amendment 40 established the hydrostatic and pneumatic test leakage limits for the LPCI and CS testable check valves and the limits and test Frequency were not addressed or changed by CTS Amendment 234 which implemented 10 CFR 50, Appendix J, Option B.

In ITS the leakage limits and test Frequency for the LPCI and CS System testable check valves are specified in ITS SR 3.6.1.3.11.

PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl Changes have been made/additions, deletions, and/or changes to the NUREG to reflect the plant specific nomencl ature, number, reference, system description, or analysis description.

PA2 Editorial changes have been made for enhanced clarity, be consistent with other places in the Specifications, or to correct a grammatical/typographi cal error.

PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB1 ISTS 3.6.1.1 has been revised to reflect that, JAFNPP penetration designs do not include pressurized sealing mechanisms.

DB2 ITS 3.6.1.1 has been revised to reflect the specific JAFNPP reference requirements of, UFSAR, Section 5.2, Primary Containment System.

DB3 ITS 3.6.1.1 has been revised to reflect the specific JAFNPP reference requirements of, UFSAR, Section 14.6.1.3, Loss-Of-Coolant Accident.

DB4 ITS SR 3.6.1.1.2 has been revised to reflect UFSAR, Section 5.2.4.4.

JAFNPP Page 1 of 2 Revi si on E

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS BASES: 3.6.1.1 - PRIMARY CONTAINMENT DB5 ITS 3.6.1.1 has been revised to reflect that the JAFNPP design which J,

includes two primary containment air locks.

DIFFERENCE BASED ON AN APPROVED TRAVELER (TA)

TA1 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 52, Revision 3. have been incorporated into the revised Improved Technical Specifications.

DIFFERENCE BASED ON A SUBMITTED, BUT PENDING TRAVELER (TP)

None DIFFERENCE FOR ANY REASON OTHER THAN THE ABOVE (X)

X1 NUREG-1433, Revision 1. Bases reference to "the NRC Policy Statement" has been replaced with 10 CFR 50.36(c)(2)(ii), in accordance with 60 FR 36953 effective August 18, 1995.

X2 ITS LCO 3.6.1.1 Bases has been revised to reflect the existence of a requirement to limit leakage from the drywell to the suppression chamber to ensure the pressure suppression function is maintained and the primary containment pressure does not exceed design limits.

X3 ITS SR 3.6.1.1.1 has been revised to reflect changes to ISTS 3.6.1.3 requirements at JAFNPP, that ISTS SR 3.6.1.3.12 and SR 3.6.1.3.7 were deleted in accordance with ITS 3.6.1.3, CLB9 and CLB1 respectively, and that subsequent Surveillances have been renumbered accordingly.

X4 ITS SR 3.6.1.1.2, second Frequency to verify drywell to suppression chamber differential pressure leakage rate, in accordance with the Note condition, when two consecutive tests fail and continues until two consecutive tests pass, has been included.

The Frequency of 12 months is half of the normal Frequency in ITS 3.6.1.1.2 (CTS 4.7.A.5.d) which is consistent with the philosophy utilized in NUREG-1433, Revision 1.

Page 2 of 2 Revision E 3AFNPP

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.1 Primary Containment RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES 4

Primary Containment 3.6.1.1 3.6 CONTAINMENT SYSTEMS 3.6.1.1 Primary Containment LCO 3.6.1.1 APPLICABILITY:

Primary containment shall be OPERABLE.

MODES 1. 2, and 3.

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

containment to OPERABLE status.

B. Required Action and B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

AND B.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Amendment 3AFNPP 3.6-1

Primary Containment 3.6.1.1 SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.6.1.1.1 Perform required visual examinations and In accordance leakage rate testing except for primary with the containment air lock and Low Pressure Primary Coolant Injection and Core Spray System Containment injection line air operated testable Leakage Rate check valve testing, in accordance with Testing Program the Primary Containment Leakage Rate Testing Program.

SR 3.6.1.1.2 Verify suppression chamber pressure 24 months increase is : 0.25 in. water guage/minute over a 10 minute period with a drywell to AND suppression chamber differential pressure of k 1 psi.

NOTE -----

Only required after two consecutive tests fail and continues until two consecutive tests pass 12 months Amendment (Rev. E)

JAFNPP 3.6-2

Primary Containment B 3.6.1.1 B 3.6 CONTAINMENT SYSTEM4S B 3.6.1.1 Primary Containment BASES BACKGROUND The function of the primary containment is to isolate and contain fission products released from the Reactor Primary System following a Design Basis Loss of Coolant Accident (LOCA) and to confine the postulated release of radioactive material.

The primary containment consists of the drywell (a steel pressure vessel in the shape of an inverted light bulb) and the suppression chamber (a steel pressure vessel in the shape of a torus) located below and encircling the drywell.

The primary containment surrounds the Reactor Coolant System and provides an essentially leak tight barrier against an uncontrolled release of radioactive material to the environment.

The isolation devices for the penetrations in the primary containment boundary are a part of the containment leak tight barrier.

To maintain this leak tight barrier:

a.

All penetrations required to be closed during accident conditions are either:

1.

capable of being closed by an OPERABLE automatic containment isolation system, or

2.

closed by manual valves, blind flanges, or de-activated automatic valves secured in their closed positions, except as provided in LCO 3.6.1.3, "Primary Containment Isolation Valves (PCIVs);

b.

The primary containment air lock is OPERABLE, except as provided in LCO 3.6.1.2. "Primary Containment Air Locks'; and

c.

All equipment hatches are closed.

This Specification ensures that the performance of the primary containment, in the event of a Design Basis Accident (DBA),

meets the assumptions used in the safety analyses of References 1 and 2.

SR 3.6.1.1.1 leakage rate requirements are specified in the Primary Containment Leakage Rate Testing Program which is in conformance with 10 CFR 50, (continued)

Revision 0 (Rev. E)

B 3.6-1 3AFNPP

Primary Containment B 3.6.1.1 BASES BACKGROUND Appendix J. Option B (Ref. 3), as modified by approved (continued) exemptions.

APPLICABLE The safety design basis for the primary containment is that SAFETY ANALYSES it must withstand the pressures and temperatures of the limiting DBA without exceeding the design leakage rate.

The DBA that postulates the maximum release of radioactive material within primary containment is a Loss of Coolant Accident (LOCA).

In the analysis of this accident, it is assumed that primary containment is OPERABLE such that release of fission products to the environment is controlled by the rate of primary containment leakage.

Analytical methods and assumptions involving the primary containment are presented in References 1 and 2.

The safety analyses assume a nonmechanistic fission product release following a DBA, which forms the basis for determination of offsite doses.

The fission product release is, in turn, based on an assumed leakage rate from the primary containment.

OPERABILITY of the primary containment ensures that the leakage rate assumed in the safety analyses is not exceeded.

The maximum allowable leakage rate for the primary containment (L ) is 1.5% by weight of the containment air per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at the design basis LOCA maximum peak containment pressure (P,) of 45 psig (Primary Containment Leakage Rate Testing Program).

Primary containment satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 4).

LCO Primary containment OPERABILITY is maintained by limiting leakage to s 1.0 L., except prior to the first startup after performing a required Primary Containment Leakage Rate Testing Program leakage test.

At this time the applicable leakage limits must be met.

Compliance with this LCO will ensure a primary containment configuration, including equipment hatches, that is structurally sound and that will limit 4

(continued)

JAFNPP B 3.6-2 Revision 0 (Rev. E)

-4.

-I Primary Containment B 3.6.1.1 BASES LCO (continued)

APPLICABILITY ACTIONS leakage to those leakage rates assumed in the safety analyses.

Individual leakage rates for the primary containment air locks are addressed in LCO 3.6.1.2 and specified in the Primary Containment Leakage Testing Program.

In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment.

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

Therefore, primary containment is not required to be OPERABLE in MODES 4 and 5 to prevent leakage of radioactive material from primary containment.

A. 1 In the event primary containment is inoperable, primary containment must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining primary containment OPERABILITY during MODES 1. 2, and 3.

This time period also ensures that the probability of an accident (requiring primary containment OPERABILITY) occurring during periods where primary containment is inoperable is minimal.

B.1 and B.2 If primary containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a NODE in which the LCO does not apply.

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

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

(continued)

Revision 0 B 3.6-3 JAFNPP

Primary Containment B 3.6.1.1 BASES (continued)

SURVEILLANCE REQUIREMENTS SR 3.6.1.1.1 Maintaining the primary containment OPERABLE requires compliance with the visual examinations and leakage rate test requirements of the Primary Containment Leakage Rate Testing Program.

Failure to meet the air lock leakage limit (SR 3.6.1.2.1), or the main steam isolation valve leakage limit (SR 3.6.1.3.10) does not necessarily result in a failure of this SR.

The impact of the failure to meet these SRs must be evaluated against the Type A. B, and C acceptance criteria of the Primary Containment Leakage Rate Testing Program. Failure to meet the Low Pressure Coolant Injection (LPCI) or Core Spray (CS)System injection line air operated testable check valve leakage limit (SR 3.6.1.3.11) does not result in failure to meet this SR since the LPCI and CS testable check valve leakage is not included in the Primary Containment Leakage Rate Testing Program limits (Ref. 5 and 6).

0 As left leakage. prior to startup after performing a required Primary Containment Leakage Rate Testing Program leakage test, is required to be s 0. 6 L for combined Type B and C leakage, and s 0.75 La for overalT Type A leakage.

At all other times between required leakage rate tests, the acceptance criteria is based on an overall Type A leakage limit of s 1.0 La.

At s 1.0 L. the offsite dose consequences are bounded by the assumptions of the safety analysis.

The Frequency is required by the Primary Containment Leakage Rate Testing Program.

SR 3.6.1.1.2 Maintaining the pressure suppression function of primary containment requires limiting the leakage from the drywell to the suppression chamber.

Thus, if an event were to occur that pressurized the drywell. the steam would be directed through the downcomers into the suppression pool.

This SR is a leak test that confirms that the bypass area between the drywell and suppression chamber is less than the equivalent of a one inch diameter plate orifice (Ref. 1).

This ensures that the leakage paths that would bypass the suppression pool are within allowable limits.

(continued)

JAFNPP B 3.6-4 Revision 0 (Rev. E)

.4.

II Primary Containment B 3.6.1.1 BASES (continued)

SURVEILLANCE REQUIREMENTS REFERENCES SR 3.6.1.1.2 (continued)

Satisfactory performance of this SR can be achieved by establishing a known differential pressure between the drywell and the suppression chamber (a 1 psi)and verifying that the pressure in the suppression chamber does not increase by more than 0.25 inches of water per minute over a 10 minute period.

The leakage test is performed every 24 months.

The 24 month Frequency was developed considering the fact that component failures that might have affected this test are identified by other primary containment SRs.

Two consecutive test failures, however, would indicate unexpected primary containment degradation; in this event, as the Note indicates, increasing the Frequency to once every 12 months is required until the situation is remedied as evidenced by passing two consecutive tests.

1.

UFSAR, Section 5.2.

2.

UFSAR, Section 14.6.1.3.

3.

10 CFR 50, Appendix.J, Option B.

4.

10 CFR 50.36(c)(2)(ii).

5.

License Amendment 40, dated November 9. 1978.

6.

License Amendment 234, dated October 4, 1996.

Revision 0 (Rev. E) t\\)

-5 I-'

JAFNPP B 3.6-5 J

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.2 Primary Containment Air Locks MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

DISCUSSION OF CHANGES (DOCs) TO THE CTS NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC)

FOR LESS RESTRICTIVE CHANGES MARKUP OF NUREG-1433, REVISION 1, SPECIFICATION JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION 1 MARKUP OF NUREG-1433, REVISION 1, BASES JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION 1, BASES RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.2 Primary Containment Air Locks MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

JAII&P 16 (coatd)

S-_eo) Mid

- the roactot As Ac the to mode VMnS the Nol switch it IN the an "odf positlo.

"me the Ned.* Switoh 1 the holvel posltion, the r*ueling lot too" ore Ao service.

3.

ha med" - so this Mcde the roateor sr Iesenro Is at or cw as *W poll ti le aster Pr t s i N w Spetem Ao e cerg l ced Arm preteetloe (onselelg the is pore bigh fla trip) el" the MN haterloshe Dervils.

3.

Sbthdow Nnde - nho reeator is in the dea ce"l Whom the Reactor oeft switch the Setdoms Nledo oealtieo.

a.

Met e1tdt maer eonditions Ni Swith toasor oenltet tenmperatre )

ton he with met Is meut to An dews

b.

Cold tII.. ceame ceoditionNoe shew with toaster Nselect temperaturo LSIVII°.

eel the toaster vessel vwated.

4, Strt"Ie.t, Steafn

- Ir thi. seode the Io SI~~~Mr0 W

a @n 110141lo I"Ifl"~o IV""o a lolmo trip to bltposed thio Ioector I

a,.O. e.

ystem.

134

,seri.oo.with (I

Amendment me

4.

134 SoEe J.4.~ (. 2i(ý2

'I, system trips and control rod withdrawa lmterloeho-la service.

i QMM W - A System. subsystem. grain.

a ofipoent er device Shell be OpISAD or have 0PtIASlLITy om It In eapeble of porforming its pocillied leactlea(s). lplicit IA this dolinitioa shell he the aessumtio that all noeessary attoedasto Instrumeteation. conttrols nermal and emorgency electrical pooer seurces*

cooling or goal wateri luerication or other auiliary equipment that are required lot the system. subaystom. train. com peacet or device tO perform Its fusction(s) are also cepablo of performing their related support fnoctios(s).

a.

211SA

- Operating angs that a system or smpecent in perormirnag Its Intended functions in Its requoiredWanaer.

is reird

- Iter.al bet the nd of one roluliq uteo ai tboendof e 46A~ -

L.

r %-WumaW inusritCAlCi--ao -that tjil\\

driwall a0 preOmerO mUplpromieS Cheeber are Istctae ad all of"Mfallownna a

1.

All 0nneal icosti t

Isolation valves on lines commectod to the Reactor Coolast Systm or costaslmniat which are not required to be opre daArle plant accident conditions to closed.

These Ivos y bes AlL /oJ t,

.=--_.

q

JAFNPP Nk.

Bal1W ojttd power sof refr to operation at a reactor MWt. This Is else tnmned 100 percent pwe an Is the mawdm power leve aulthorlied by toe op t

cnm. Raed sem Now.,

rated coolant flow, lated nucoee system proemue, rotor to the values of these pa met when the reoator is at tted power (Reference

.I.

0.

-UM Reactor power operation Is any operato wihtemd Switch In the Steutulwott Standby or Run pooion with the reactor critical and above I Percent rated powe.

P.

Rmfltf VAlW BFMUuE-Uniess otherwise indicaled, reactor vessel liese-s ited in the Technica Specifications, we those measured by the reactor vessel stem space aeneor.

a.

I IniM--Roeuftf alloup Is the period of time be en the elu*own of te unit prior to ref001011 enad the Mtat of the PNa subsequnt, to tha refueling.

a.

8fatyWIM. The soeety Emits are limits within which red t maintenance of the fuel claddin Interty and the reactor coolant system Integrity are assured.

Violation of such a Mit is cause for unit sudcwn and review by the Nuclear Reagulatory Commission before roeumptiOn of unit oprration. Operation beyond such a limit may not In Itsif result in rovue consequences but it Indicates an operational

~

J The surveillance frequency notations I Intervals used-In these specifications ave defined as folows:

Uolm ItaenwelIs FEmmufn D

Daily At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months W

Weakly At least once per 7 days M

Monthly At least once 31 dys 0

Ouertedy or At least oncpeW 92 dloys every3 months SA Semiannually or At least once p 184 days every 6 months A

Annually or Yearly At least o0e pe 366 days laM 16 Montha At least once Per IS moths 11 days)

R Operating Cycle At least oncwe p 24 months I days)

SAI Prior to each reactor Meatuj.

NA Not applicable

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JAFNPP

1) The drye to tons dllwentio Pressure shal estbisled wit h 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of exceeding 15%

rated thma, pawsdur ing statup. The diferentia preessu may be reduced to lWss wthe limil to 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing thermru poaws to less tOm 15% of rrted belare a plo (2) The Mier@ -

pressue may be decreased to les Owu 1.7 psld for a maximuin of four (4) hours during required operabity testing of the HPCI. RCIC. mad Suippreslsn Chamiber Miywe Vaciuum Oera" System.

(3) N &3.A..a anove cannot be mat restore td di-re.

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of raedwif Ot next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.2 Primary Containment Air Locks DISCUSSION OF CHANGES (DOCs) TO THE CTS a¸

DISCUSSION OF CHANGES ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS R

ZIIT ADMINISTRATIVE CHANGES Al In the conversion of the James A. FitzPatrick Nuclear Power Plant (JAFNPP) Current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS) certain wording

-preferences or conventions are adopted that do not result in technical changes.

Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the conventions in NUREG-1434 "Standard Technical Specifications, General Electric Plants, BWR/6",

Revision 1 (i.e., Improved Standard Technical Specifications (ISTS)).

A2 CTS 3.7.A.2 reference to "Primary Containment Integrity" has been deleted since the CTS 1.0.M definition of Primary Containment Integrity is incorporated into ITS 3.6.1.1. 3.6.1.2, and 3.6.1.3 and is no longer maintained as a separate definition in the ITS.

Proposed ITS 3.6.1.2 requires that the primary containment air locks shall be OPERABLE.

The definition of OPERABLE and the subsequent ITS 3.6.1.2 LCO, ACTIONs, and Surveillances are sufficient to encompass the requirements of the CTS definition for airlock requirements.

This change removes any confusion which may exist between the definition and the specific requirements of the LCO and is a presentation preference consistent with NUREG 1434, Revision 1.

Since, all aspects of the Primary Containment Integrity definition requirements, along with the remainder of the LCOs in the Containment Systems Primary Containment section (i.e., primary containment, isolation valves, suppression pool, etc.) are maintained in subsequent Specifications of ITS this change is considered to be administrative only.

A3 CTS 4.7.A.2.a is modified by Note 1.

Proposed ITS SR 3.6.1.2.1 NOTE states, "An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test."

Since the inoperability affects only one door, the barrel and the other OPERABLE door are providing a sufficient containment barrier.

Even though the overall test acceptance criteria may not be satisfied (SR 3.0.1 would normally require this to result in declaring the LCO not met " possibly requiring proposed Condition C to be entered), the Note clarifies the intent that the previous test not be considered "not met."

Adding this Note, is consistent with the CTS 1.0.M Primary Containment Integrity condition requirement that at least one door in each air lock is closed and sealed, and the Required Actions of ITS 3.6.1.2 Condition A allowing for one door in an air lock being INOPERABLE.

Therefore, this change is considered to be an administrative change.

Page 1 of 7 JAFNPP Revision E

DISCUSSION OF CHANGES ITS: 3.6.1.2 PRIMARY CONTAINMENT AIR LOCKS ADMINISTRATIVE CHANGES A4 Not Used.

A5 CTS 3.7.A.2 has been modified by addition of a Note.

Proposed ITS 3.6.1.2 ACTIONS Note 3 requirement, to enter the applicable Conditions and Required Actions of ITS 3.6.1.1, Primary Containment, when air lock leakage exceeds the overall Primary Containment leakage rate acceptance criteria, establishes the need to consider the Primary Containment OPERABILITY if the air lock leakage acceptance criteria is not being met.

This change is consistent with the relationship of containment integrity and air lock OPERABILITY established in the CTS 1.O.M definition of Containment Integrity.

In addition, CTS 4.7.A.2.a (the primary containment airlock leakage surveillance test) is modified by Note 2.

Note 2 of ITS SR 3.6.1.2.1 states that the "Results shall be evaluated against criteria applicable to SR 3.6.1.1.1".

SR 3.6.1.1.1 is the primary containment leakage rate test.

This will ensure that air lock leakage is properly accounted for in determining the combined Type B and C primary containment leakage.

These Notes are considered administrative since CTS 4.7.A.2.a currently applies to both Type B and C testing and consistent with the design basis analysis.

TECHNICAL CHANGES - MORE RESTRICTIVE R

M1 CTS 3.7.A.2 requirement, for primary containment integrity (as defined in CTS 1.O.M. which requires only, that at least one door in each air lock is closed and sealed), is being revised.

NUREG-1434. Revision 1, ITS 3.6.1.2 Bases for air lock OPERABILITY, requires that both air lock doors be OPERABLE.

As a result of this requirement, ITS 3.6.1.2 Condition A, for one or more primary containment air locks with one primary containment air lock door INOPERABLE, associated Required Actions. and Completion Times, has been added.

This change is acceptable since it establishes the Required Actions and associated Completion Times which ensure that an acceptable primary containment leakage boundary is maintained.

Since, this change imposes additional operational requirements, it constitutes a more restrictive change.

This change is not considered to result in any reduction to safety.

Page 2 of 7 JAFNPP Revision E

-j DISCUSSION OF CHANGES ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - MORE RESTRICTIVE M2 ITS SR 3.6.1.2.2, to verify that only one door in the primary containment air lock can be opened at a time, has been added.

CTS 4.7.A.2 does not have a requirement to ensure the interlock mechanism is OPERABLE.

The air lock interlock mechanism is designed to prevent simultaneous opening of both doors in the air lock.

This prevents the primary containment from being INOPERABLE due to both air lock doors being open at the same time.

In addition ITS 3.6.1.2 ACTION B. for one or more primary containment air locks with primary containment air lock interlock mechanism INOPERABLE. associated Required Actions, and Completion Times, has also been added.

This change is acceptable since it establishes the Required Actions and associated Completion Times and Surveillance Requirements which ensure that an acceptable primary containment leakage boundary is maintained.

The addition of new Surveillance Requirements and ACTIONS imposes additional operational requirements, and constitutes a more restrictive change.

This change is not considered to result in any reduction to safety.

M3 CTS 3.7.A.8 requirement, that the reactor to be in the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the requirements of Specification 3.7.A.2 cannot be met, is being changed.

ITS 3.6.1.2 Required Action D.1 requires the plant to be in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the Required Action and associated Completion Times for restoring an INOPERABLE air lock are not met.

In addition, ITS 3.6.1.2 Required Action D.2 places the plant in MODE 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (L4).

This change is more restrictive because it provides an additional requirement to place the plant in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months The allowed Completion Times in Required Action D.1 and D.2 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.

However, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time ensures timely action is taken to place the plant in a shutdown condition (MODE 3).

The consequences of any design bases event is significantly reduced when plant is shutdown.

This change is consistent with NUREG-1434, Revision 1.

-2 M4 The CTS Applicability of the Primary Containment in CTS 3.7.A.2 is whenever the reactor is critical or when the reactor water temperature is above 212°F and fuel is in the reactor vessel.

In addition, there is an exception in CTS 3.7.A.2, to not require primary containment integrity to be met during low power physics tests at atmospheric pressure and power levels not to exceed 5 MWt, however any change to this requirement is discussed in the Discussion of Changes for ITS 3.10.8.

The scope of the current Applicability covers MODE 1, 3 and portions of MODE 2 operations.

The Applicability in ITS 3.6.1.2 is MODES 1, 2 and 3.

This change is considered more restrictive since the primary containment air locks will be required to be Operable at all JAFNPP Page 3 of 7 Revision E

DISCUSSION OF CHANGES ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - MORE RESTRICTIVE M4 (continued) times in MODE 2 even prior to any plant startup when reactor coolant

- temperature may be below 2120F.

This change is consistent with NUREG 1434, Revision 1.

TECHNICAL CHANGES - LESS RESTRICIVE (GENERIC)

(1IIT_ *-iI.-*

LA1 The detail of the CTS definition of Primary Containment Integrity in CTS 1.0.M.2 that at least one door in each airlock is closed and sealed is proposed to be relocated to the Bases.

The requirement in ITS LCO 3.6.1.2 that two primary containment air locks shall be Operable, the definition of Operability and the associated Surveillances of ITS 3.6.1.2 are sufficient to ensure the requirements are met.

The ITS 3.6.1.2 Bases describes the design of the airlock doors (each of the personnel access hatch doors contains double gasketed seals) and requires them to be closed.

As such, these details are not required to be in the ITS to provide adequate protection of public health and safety.

Changes to the Bases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the ITS.

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li A Note is being added to the actions of CTS 3.7.A.2 (ITS 3.6.1.2 ACTION Table Note 1) to permit entry through a closed or locked air lock door for the purpose of making-0epairs.

If the outer door is inoperable, then it may be easily accessed for repair.

If the inner door is inoperable, however, then it is proposed to allow entry through the OPERABLE outer door, which means there is a short time during which the primary containment boundary is not intact (during access through the outer door).

The proposed allowance will have strict administrative controls, which are detailed in the proposed Bases.

A dedicated (i.e., not involved with any repair or other maintenance effort) individual will be assigned to ensure:

1) the door is opened only for the period of time required to gain entry into or exit from the air lock, and 2) any operable door is re-locked prior to the departure of the dedicated individual.

Repairs are directed towards reestablishing two OPERABLE doors in the air lock.

Two OPERABLE doors closed is clearly the most desirable plant condition for air locks.

The existing actions, in some circumstances, allow indefinite operation with only one OPERABLE door locked closed.

Two OPERABLE doors closed is clearly an improvement on safety over one

°Page 4 of 7 Revision E JAFNPP

DISCUSSION OF CHANGES ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li (continued)

OPERABLE door locked closed.

By not allowing access to make repairs, the existing actions could result in an inability of the plant to establish and maintain this highest level of safety possible (two OPERABLE doors closed), without a forced plant shutdown.

Furthermore, the overall air lock test must be performed every 6 months.

This could eventually result in a pl ant shutdown from the inability to properly perform this test due to the inability to affect repairs to the inoperable door.

Therefore, allowing entry and exit, while temporarily allowing loss of containment operability, is proposed based on the expected result of restoring two OPERABLE doors to the air lock.

Restricting this access to make repairs of an inoperable door or air lock ensures this allowance applies only towards meeting this goal.

This change is acceptable due to the low probability of an event that could pressurize the primary containment during the short time in which the containment integrity is compromised, and the increased safety attained by completing repairs such that two OPERABLE doors can be closed.

L2 CTS 3.7.A.2 primary containment integrity (air lock) requirement, for at least one door in each air lock to be closed and sealed (CTS 1.0.M.2).

is being revised.

ITS 3.6.1.2 Condition A (Ml). Required Actions Note 2 is being added.

This note allows entry through a closed and/or locked OPERABLE air lock door (for reasons other than repairs) for a limited period of time (i.e., 7 days) if one or both air locks are inoperable (due to the inoperability of one air lock door).

Although one OPERABLE air lock door locked closed is sufficient to maintain primary containment integrity and allow continued operation, entry and exit during operation may be necessary to perform.Technical Specification (TS) Surveillances and Required Actions, as well as other activities inside primary containment that are required by TS or activities that support TS required equipment.

Should access not be allowed, a plant shutdown could be required to attend to these activities.

The proposed allowance requires administrative controls, which are detailed in the Bases.

A dedicated (i.e.. not involved with any repair or other maintenance effort) individual will be assigned to ensure:

1) the door is opened only for the period of time required for entry or exit from the air lock, and 2).the OPERABLE door is closed and locked prior to the departure of the dedicated individual.

This allowance is considered acceptable due to the low probability of an event that could pressurize the primary containment during the short time the OPERABLE door is expected to be open.

Page 5 of 7 Revision E JAFNPP

DISCUSSION OF CHANGES ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L3 A new Condition and Required Action is being added to CTS 3.7.A.2.

ITS 3.6.2.1 ACTION C, for a primary containment air lock inoperable for reasons other than Condition A (one or more primary containment air locks with one primary air lock door inoperable) or B (one or more primary containment air locks with primary containment air lock interlock mechanism inoperable).

Since, an inoperable air lock does not necessarily mean the primary containment is inoperable, Required Action C.3 allows up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore an inoperable air lock to OPERABLE status.

Required Action C.1 immediately initiates action to evaluate primary containment overall leakage (OPERABILITY) using current air lock test results.

If this evaluation shows the primary containment is inoperable, then proposed Note 3 to the ACTIONS would require the primary containment LCO ACTIONS to be entered (thus, the full 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of this LCO could not be used).

If however, the evaluation is satisfactory, the full 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months could be utilized since the accident analysis assumptions are still met.

In addition, Required Action C.2 verifies, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , that a door is closed, consistent with the ACTIONS of LCO 3.6.1.1 that require primary containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

L4 CTS 3.7.A.8 requirement, that the reactor be in the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the requirements of CTS 3.7.A.2 (3.7.A.1 through 3.7.A.5) cannot be met, is being relaxed.

ITS 3.6.1.2 Required Action D.2 allows the plant 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to reach COLD SHUTDOWN (MODE 4). However, ITS 3.6.1.2 Required Action D.1 requires the plant to be in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (M3).

This change is less restrictive because it extends the time for the plant to be in MODE 4 from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times in Required Actions D.1 and D.2 are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

The consequences of an accident are not significantly increased because ITS 3.6.1.2, Required Action D.1 will require the plant be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months once the determination is made that the Required Action or Completion Time associated with the primary containment being inoperable cannot be satisfied.

This change reduces the time the reactor would be allowed to continue to operate once the condition is identified.

The consequences of a LOCA are significantly mitigated when the reactor is shutdown and a controlled cooldown is already in progress.

This change is consistent with NUREG-1434, Revision 1.

Page 6 of 7 JAFNPP Revision E

DISCUSSION OF CHANGES ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L5 CTS 3.7.A.2 has been modified by addition of a Note.

Proposed ITS 3.6.1.2, ACTIONS Note 2, provides specific instructions to allow separate Condition entry for each air lock to ensure proper application of the ACTIONS for Technical Specification compliance.

Separate Condition entry for each air lock allows the ACTIONS to be applied to each airlock consistent with the reasons for Condition entry.

That is, the specific Condition applicable to each cause of airlock inoperability is allowed to be addressed separately and concurrently for each air lock.

Addition of the Note, in conjunction with addressing "...one or more...air lock...n in the Condition statements avoids the need to provide a second series of Conditions that address inoperability of both air locks in addition to Conditions that address inoperabilty of only one air lock.

Allowing separate Condition entry for each air lock is consistent with Specification 3.6.1.3, Primary Containment Isolation Valves (PCIVs), with regard to allowing separate Condition entry for each penetration and is consistent with NUREG-1434, Revision 1.

TECHNICAL CHANGES - RELOCATIONS None Page 7 of 7 JAFNPP Revision E

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.2 Primary Containment Air Locks NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC) FOR LESS RESTRICTIVE CHANGES I

4

-I NO -SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L1 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change would allow entering and exiting via the OPERABLE door for the purpose of making repairs to a primary containment air lock.

Failure of an air lock is not an initiator of any analyzed event.

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

The change to allow entering and exiting the OPERABLE door for the purpose of making repairs results in a potential increase in consequences should an accident occur while it is open.

This increase is minimized through administrative controls and offset by avoiding the potential consequences of an unnecessary transient during shutdown.

The potential consequences resulting from the combination of:

1) the requency of experiencing an inoperable air lock door such that temporarily opening the OPERABLE door is required for access to repair;

2) the brief period the OPERABLE door would be opened for access (typically on the order of one minute per entry/exit); and 3) the occurrence of an event of sufficient magnitude to cause an immediate containment pressure increase such that an air lock door could not be closed: are not significant.

The allowance is proposed to have strict administrative control which will provide assurance that any associated potential consequences are minimized.

Therefore, these proposed changes do not involve a significant increase in the consequences of an accident previously evaluated.

2.

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

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

The primary containment air lock is designed and assumed to be used for entry and exit. Its operation does not interface with the reactor coolant Revision E JAFNPP Page 1 of 10

t NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li CHANGE

2.

(continued) system (RCS) or any controls which could impact the RCS pressure boundary or its support systems.

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

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

Containment leak rate limits are unaffected.

The proposed change to allow the temporary opening of the one OPERABLE door for the purpose of repairing an inoperable door, is not considered to be a significant reduction in the margin of safety.

The combination of:

1) the frequency of experiencing an inoperable air lock door such that containment entry is required for access to repair; 2) the brief period the OPERABLE door would be opened for access (typically on the order of one minute per entry/exit); and 3) the occurrence of an event of sufficient magnitude to cause an immediate containment pressure increase such that the air lock door could not be closed; are not representative of a significant reduction in the margin of safety.

The allowance is proposed to have strict administrative control. which will provide assurance that any associated safety reduction is further minimized.

Therefore, these proposed changes do not involve a significant reduction in the margin of safety.

Page 2 of 10 Revision E JAFNPP

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change would allow entering and exiting via the OPERABLE door for a limited period of time to perform Technical Specification (TS) Surveillances and Required Actions, as well as other activities inside primary containment that are required by TS or activities that support TS required equipment.

Failure of an air lock is not identified as the initiator of any analyzed event.

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

The change to allow entering and exiting via the OPERABLE door to perform Technical Specifications (TS) Surveillances and Required Actions, as well as other activities inside primary containment that are required by TS or activities that support TS required equipment results in a potential increase in consequences should an accident occur while it is open.

This potential increase is minimized through administrative controls and offset by avoiding the potential consequences of an unnecessary transient during shutdown.

The potential consequences resulting from the combination of: 1) the frequency of experiencing an inoperable air lock door such that temporarily opening the OPERABLE door is required; 2) the brief period the OPERABLE door would be opened for access (typically on the order of one minute per entry/exit); and 3) the occurrence of an event of sufficient magnitude to cause an immediate containment pressure increase such that an air lock door could not be closed: are not considered to be significant.

The allowance is proposed to have strict administrative control, which will provide assurance that any associated potential consequences are minimized.

Therefore, these proposed changes do not involve a significant increase in the consequences of an accident previously evaluated.

2.

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

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing

,1AF'NPP Page 3 of 10 Revision E

,'0 NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 CHANGE

2.

(continued) normal plant operation, or methods of operation.

The primary containment air lock is designed and assumed to be used for entry and exit.

Its operation does not interface with the reactor coolant system (RCS) or any controls which could impact the RCS pressure boundary or its support systems.

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

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

Containment leak rate limits are unaffected.

The proposed change to allow the temporary opening of the one OPERABLE door to perform Technical Specification (TS)

Surveillances and Required Actions, as well as other activities inside primary containment that are required by TS or activities that support TS required equipment is not considered to be a significant reduction in the margin of safety.

The combination of:

1) the frequency of experiencing an inoperable air lock door such that containment entry is required; 2) the brief period the OPERABLE door would be opened for access (typically on the order of one minute per entry/exit); and 3) the containment pressure increase such that the air lock door could not be closed; are not representative of a significant reduction in the margin of safety.

Additionally, providing the ability to eliminate any reduction in safety resulting from the transient of plant shutdown to follow (due to inability to perform the preventive or corrective maintenance) minimizes any reduction in the margin of safety.

The allowance is proposed to have strict administrative control which will provide assurance that any associated safety reduction is further minimized.

Therefore, these proposed changes do not involve a significant reduction in the margin of safety.

Page 4 of 10 Revision E JAFNPP

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L3 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

This change allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the air lock to OPERABLE status prior to requiring a plant shutdown as long as current air lock leakage results are used to determine that overall primary containment leakage rates are acceptable, and one door in the affected air lock(s) is verified closed.

The primary containment air lock is not assumed to be an initiator of any analyzed accident.

Therefore, the change does not involve a significant increase in the probability of an accident previously analyzed.

The change will not allow continuous operation such that it will preclude the air lock function from being performed.

The consequences of an event occurring while the plant is operating during the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is the same as the consequences of an event occurring if the plant were being shutdown.

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

2.

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

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

The system will continue to function in the same way as before the change.

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

3.

Does this change involve a significant reduction in a margin of safety?

This change allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the air lock to OPERABLE status prior to requiring a plant shutdown as long as current air lock leakage results are used to determine that overall primary containment leakage rates are acceptable, and one door in the affected air lock(s) is verified closed.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time allowed to restore the air lock is acceptable based on the small probability of an event requiring the primary containment to function, the desire to minimize plant Revision E JAFNPP Page 5 of 10

NO-SIGNIFICANT HAZARDS CONSIDERATIONS "ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L3 CHANGE

3.

(continued) transients, and the requirement that, if primary containment overall leakage is exceeded, the primary containment actions must be taken (which would require the start of a shutdown within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ).

In addition, the change will require one door to be closed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

As such, any reduction in a margin of safety will be insignificant and offset by the benefit gained from providing some time to restore the air lock.

Page 6 of 10 Revision E 0'.j e

JAFNPP 4'

4 dv

'/

'I, NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES

- LESS RESTRICTIVE (SPECIFIC)

L4 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

The proposed change modifies the Completion Times for Shutdown Actions when a Required Action and associated Completion Time specified in the Technical Specifications cannot be met.

The proposed change does not increase the probability of an accident because the change extends the time allowed for the plant to get to Cold Shutdown from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Shutdown Completion Times are not assumed in the initiation of any analyzed event.

The change will not allow continuous operation with the primary containment inoperable.

The consequences of an accident are not significantly increased because ITS 3.6.1.2. Required Action D.1 will require that the plant be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (M3) once the determination is made that the Required Actions or Completion Times associated with the primary containment air locks cannot be satisfied.

This change reduces the time the reactor would be allowed to continue to operate oncethe condition is identified.

The consequences of a LOCA are significantly mitigated when the reactor is shutdown and a controlled cooldown is already in progress. - In addition, the consequences of an event occurring during the proposed shutdown Completion Time are the same as the consequences of an event occurring during the existing shutdown Completion Time.

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

2.

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

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

The shutdown Completion Times are not assumed to be the initiator of any analyzed accident.

Therefore, this change will not create the possibility of a Page 7 of 10 Revision E JAFNPP

I

/

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L4 CHANGE

2.

(continued) new or different kind of accident from any accident previously evaluated.

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

The change extends the time allowed for the plant to get to Cold Shutdown from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the Required Action or Completion Time associated with inoperable primary containment air lock(s) cannot be satisfied.

There is no significant reduction in the margin of safety because ITS 3.6.1.2, Required Action D.1 will require that the plant be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (1W3) once the determination is made that the Required Actions or Completion Times associated with the primary containment air locks cannot be satisfied.

This concurrent change reduces the time the reactor would be allowed to continue to operate once the condition is identified.

The consequences of a LOCA are significantly mitigated when the reactor is shutdown and a controlled cool down is already in progress.

In addition, this change provides the benefit of a reduced potential for a plant event that could challenge safety systems by providing additional time to reduce pressure in a controlled and orderly manner.

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

Page 8 of 10 Revision E JAFNPP

ji NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L5 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

ITS 3.6.1.2. ACTIONS Note 2. is proposed to be added.

The Note allows separate Condition entry for each air lock.

The change does not involve a significant increase the probability of an accident previously evaluated because allowing separate Condition entry for each air lock does not increase the probability of air lock inoperability and air lock inoperability is not assumed to be the initiator of any accident previously evaluated.

Allowing separate Condition entry for each air lock does not increase the consequences of an accident previously evaluated because the time period 'that an air lock is inoperable is not increased.

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

2.

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

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

The inoperability of one or more air locks or the separate Condition entry to address inoperability of one or more air locks is not assumed to be the initiator of any accident previously evaluated.

Therefore. this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

Page 9 of 10 JAFNPP Revision E

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L5 CHANGE

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change does not involve any physical alteration of plant systems, structures or components. changes in parameters governing normal plant operation. or methods of operation.

The change allows separate Condition entry for each air lock.

As such, the change also allows the concurrent (or over-lapping) inoperability of both air locks to be addressed concurrently and thus potentially reduces the time period during which one or more air locks is inoperable by allowing concurrent Required Actions (corrective actions) to be taken.

In addition, this change provides the benefit of a reduced potential for a plant event that could challenge safety systems by allowing separate Condition entry for each air lock (which would be necessary in the event of conditions resulting in more than one air lock being inoperable at the same time) by reducing the potential for a required shutdown of the plant under ITS 3.0.3 due to none of the Conditions in ITS 3.6.1.2 being applicable.

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

Page 10 of 10 r

zL.T.

3 6J

.. 7--I Revision E JAFNPP

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS)

CONVERSION ITS 3.6.1.2 Primary Containment Air Locks MARKUP OF NUREG-1434, REVISION 1, SPECIFICATION

yd Primary Containment Air Locks 3.6.1.2 C I,O.M.,

L:7. A L11 Ea 5 XJL27A 3.6 CONTAIINENT SYSTEMS 3.6.1.2 Primary Containment Air Locks LCO 3.6.1.2 1T7wo)primary containment air locks shall be OPERABLE.

APPLICABILITY:

MOOES 1. 2, and 3.

ACTIONS

1. ntr an ext i pemisibl

'to erfrS ear.fte fetdarlc

1.

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

2.

Separate Condition entry is allowed for each air lock.

3.

Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment,'

when air lock leakage results in exceeding overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more primary

,OTES contatimbnt air locks

1.

Required Actions A.1, with one primary A.2, and A.3. are not containment air lock applicable if both doors door inoperable.

in the same air lock are inoperable and Condition C is entered.

2. Entry and exit is permissible for 7 days under a nsi ve co rolsjo !r th(r)

(continued)

Rev 1, 04/07/95 REVISION E 1W 41

%IN/6 STS 3.6-3

primary Containment Air Locks 3.6.1.2 ACTIONS CONDITION Tj~ý A. (continued)

B.

One or more primary containment air locks with primary containment air lock interlock mechanim inoperable.

REQUIRED ACTION A.1 Verify the OPERABLE door is closed in the affected air lock.

am A.2 A.

A.3 Lock the OPERABLE door closed in the affected air lock.

NOTE----

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

Verify the OPERABLE door Is locked closed in the affected air lock.

1.

Required Actions 3.1, B.2, and 1.3 are not applicable if both doors in the sam air lock are inoperable and Condition C is entered.

2.

Entry into and exit from

,/ý=

inmnt is pernissibl* under the control of a dedicated individual.

COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 24 hours 4 ce-

-6:1 o s

once per 31 day$

(continued)

Rev 1, 04/07/95 REVISION E WR/A STS 3.6-4

Primary Containment Air Locks 3.6.1.27 C

OND ITION REQUIRED ACTION COPLETION TIME 3dI Verify an OPERABLE door is closed in the affected air lock.

Am 3.2 B.3 Lock an OPERABLE door closed in the affected air lock.

-NOTE-Air lock doors in high radiation areas(

may be verified locked closed by administrative mans.

Verify an OPERABLE door is locked closed in the affected air lock.

L C.

One or more primary containment air locks inoperable for reasons other than-Condition A or B.

C.1 Initiate action to evaluate primary containmnt overall leakage rate per LCO 3.6.1.1, using current air lock test results.

MR C.2 ma Verify a door is closed in the affected air lock.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Once per 31 days Imediately I hour (continued)

Rev 1, 04/07/95 REVISION E (continued)

I I

WO.8 STS 3.6-5 If

.q-0-¸ ii*iUJ

Primary Containment Air Locks 3.6.1.2 ACTIONS CONDITION

c.

(continued)

D. Required Action and associated Completion Tim not mt.

EL;E REQUIRED ACTION C.3 Restore air lock to

______________________________________________________________i 0.1 e in MOOE 3.

0.2 s in NOOE 4.

COMPLETION TIME 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Rev 1, 04/07/95 REVISION E BWR/i STS 3.6-6 OPERABLE status.

t.7.Ai.2..*-J SR 3.6.1.2.1 14Z 1.4e 1.

o

-- 3 3.6.1.2 FREQUENCY r does not

cessful air lock against 1.6.1.1.1 Inment air

cordance SR 0.2 not

"*ITIUm ap icabi rl lock In accordance k

0, with Apix, as 1

a is ifiedy roe W1k Rev 1, 04/07/95 REVISION E

/

.1 BUR/A STS 3.6-7

Primary Containment Air Locks 3.6.1.2

'4 M

Rev 1, 04/07/95 REVISION E P4 VRJ/S STS 3.6-"

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS)

CONVERSION ITS 3.6.1.2 Primary Containment Air Locks JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1434, REVISION 1

/

I JUSTIFICATIONFOR DIFFERENCES FROM NUREG-1434, REVISION 1 ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 Not Used.

PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl The word "primary" has been added for clarity and consistency.

PA2 SR 3.6.1.2.1 has been modified with Note 2 consistent with the allowances in Note 3 of the ITS 3.6.1.2 ACTIONS.

PA3 Brackets have been removed and the plant specific value, nomenclature, or terminolgy inserted where appropriate.

PA4 Changes made to allow verification of closure of the air lock doors by administrative means when the primary containment is inerted to reflect the BWR-4 design.

The change is consistent with NUREG-1434, Revision 1.

PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

ITS 3.6.1.2 Condition A Note 2, that entry and exit is permissible for 7 days under administrative control, has been revised. The Note will not I

include the requirement that both air locks be inoperable.

Access through the narrow emergency escape hatch is severely restricted with regards to personnel and equipment.

Therefore, the 7 days will apply to the use of the inoperable personnel access hatch even when the emergency escape hatch is operable.

DB2 ISTS SR 3.6.1.2.2 and SR 3.6.1.2-4 have been deleted since the FitzPatrick plant design does not include an air lock seal air system.

SR 3.6.1.2-3 has been renumbered to reflect the change.

DIFFERENCE BASED ON AN APPROVED TRAVELER (TA)

TA1 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler number 17, Revision 2, incorporated into the revised Improved Technical Specifications.

TA2 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler number 52 Revision 3 have been incorporated into the revised Improved Technical Specifications.

A Page 1 of 2 JAFNPP Revi si on E

/

JUSTIFICATION-FOR DIFFERENCES FROM NUREG-1434, REVISION 1 ITS: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS DIFFERENCE BASED ON A SUBMITTED, BUT PENDING TRAVELER (TP)

None flTFFFRFNCE FOR ANY REASON OTHER THAN THE ABOVE (X)

None Page 2 of 2 DIFFERENCE FOR ANY RFASON OTHFR JAFNPP Revision E

.17 JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS)

CONVERSION ITS 3.6.1.2 Primary Containment Air Locks MARKUP OF NUREG-1434, REVISION 1, BASES

Primary Contaitme-t Air Locks B 3.6.1.2 8 3.6 C

PNTAI ry SYSTEMS (v

ee

)

B 3.6.1.2 Primary Containment Air Locks wtj4 c.eca.

~~Ck '

BACKRMW0 Two double door primary containment air locksjhave been built into the primary containment to provide personnel access to the primary contai t and to provide primary e

containment isolation during the process of personnel entry and exit. The air locks are designed to withstandd the same loads, temperatures, and peak daesign e

I and part of pressures as the primary containment z par of the primary containment, the air oc lint*4th release of radioactive material to the environment during normal unit operation and through a range of transients and accidents up to and including postulated Design Basis Accidents (0BAs).

Each air lock door has been designed and tested to certify its ability to withstand pressure in excess of the maxi mu expected pressure following a DBA in primary containment.

j*an oT ue aoors intlante swa's Tha are a~nl ofl I> 60] psig by the seal a~

fask and paetuatij system.

Which is maintained at a/pressure 2

[901 psg' Each door 7has two seals to en they are sngle fai )re _proof in Each air lock is nominally a right circular cylinde tj n

ith doors at each end thatare

-preven simultaneous opening.

The air locks ari ooviedwit) lImit switches on both doors_ in each-air

'lqUTi-fu be OPRALE, he air lock interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods vwn frequent primary containment entry is necessary.

Under some conditions, as allowed by this LCo, the primary containment say be accessed through the air lock vhen the door interlock mechanism has failed, by manually performing the interlock function.

The primary containmnt air locks form part of the primary containment pressure boundary.

As such, air lock inqtelari,,'y, and Ink tightness are essential for ma intain ing~r mry containment leakage rate to within limits in the event of a (continued)

WR16 STS B 3.6"6 Rev 1, 04/07/95 REVISION E WQLZ

Primary Containment Air Locks gAlt Locks B 3.6.1.2 BASES BACKGROUND DUA.

Not maintaining air lock Integrity or leak tightness

~AI (continued) ma result in a leakage rate in excess of that assumed in m ato f st a e

t.

Tepiaraysi ofthsacinment, air ocs arereuired toa prier APPICBL 714alMon

SOEIS uh uma release of raiat iveo Pea irnlack to con sdro ed OPERAB LE the airolac interloSk mriachaismth mast be OEAnr LE h

a O ain loc moucste o

lit the Type B airo loc leakage rate st, and bothy airt lokdorautbeOnABE h

intr sc allows nlyMon ai l okdoroble opena t a t11me.

Thi provisionensures tat a gros breach o primary ontainmen dmary c

ntainm ntaismrepqu redsub 06..%;*

Soe Loch.

f sallowable'lagertfom hy D

s*

or

a

, criteria imposed on the Ss*

asociated vir air lock&.

PraE contlosi ar lock OPERABILITY es also required to mitnimize the iount of fission product gases that may escape N~b.*o*Citin**)

primary containmet through th air lock and contaminate and pres.-

su-ize the secondry containut.

6Prim containment a3r 3

_ocks7 sais Criterion 3 of the/7/

L As part of the primary ontainwn4 the air'lock's safety

{

7function is related to control of containment leakage rates toe C-F& To.-

foiloikngtl OBA.

Thus, the air lock's structural integrity (t,

M\\ 0,0

r. \\ t-?

q and lea tightness are essential to the successful

_*'l*-I.It'*.J*

mitigation of such an event.

The primary otatImnt air locks are required to be OPERABLE.

For each air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lack must be in compliance with the Type 8 air lock leakage test, and both air lack doors must be OPERlABLE.

The interlock allows only one air lock door to be open at a time.

This provision ensures that a gross breach of primary containment does not exist ti primary contaiment is required to be OPERABlLE.

Cleauro of a single door in each air lock is (continued) iBtR6 STS 8 3.6-7 Rev 1, 04/07/9S

--7 REISO E

Primary Containmet Air Locks B 3.6.1.2 BASES LCO (continued) sufficient to provide a leak tight barrier following postulated events.

Nevertheless, both doors are kept closed oen the air lock is not being used for normal entry into

(.fr0am pr p%_ntainmeflt.

ýlO-r~

APPLICABILITY In HODES 1, 2, and 3, a OP could cause a release of radioactive material to primary containment.

In MODES 4 and 5, the probability and consequences of these events ai reduced due to the pressure and temperature limitations o0 these MODES.

Therefore, the primary containment air locIN not required to be OPERABLE in HOOES 4 and 5 to prevent leakage of radioactive material from primary containment.

The ACTIONS are modified by Note 1, which allows entry and exit to perform repairs of the affected air lock component.

If the outer door is inoperable, then it may be easily accessed for most repairs.

It is preferred that the air lock be accessed from inside primary containment by entering through the other OPERABLE air lock.

However, if this is not practicable, or if repairs on either door must be performed from the barrel side of the door, then it is permissible to enter the air lock through the OPERABLE door, which means there is a short time during which the primary containment boudar not tact durng access thrah the OPERABLE door).

T The UP door.

even if it means the priary ma iiitailment boundary is orarily not intact, is acceptable due to the low probability of an event that could pressurize the primary containment during the short time in which the OPERABLE door is expected to be open.

After-each entry and exit, the OPERABLE door must be immediately closed.

Note 2 has been included to provide clarification that, for this LCO, separate Condition entry is allowed for each air lock.

This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable air lock.

Complying with the Required Actions may allow for continued operation, and a subsequent inoperable air lock is governed by -subsequent Condition entry and application of associated Required Actions.

(continued)

B 3.6-8 Rev 1, 04/07/95 REVISION E I2)

ACTIONS eWR/4 STS rS 7,c-f 2)

priar cniin~ntise Peeing r Containmen fr ok LCtD 36.1, rmr Conanmn' to be take6inthi ev-ent.i ACTcIntS T

e bCIOSarrer moisfmintied by atidNtheushicf ansOurAes (cntnud)aiprloprkadoor.mThisl actions masetaken competoed iti1hor Ther1ehoureCtmpletinT is adeconseqistnr ihte ACTIONS ofr LCD 3.6.1.1, *hcPeqie ta rimary contai nment.0t betaeinhs Wnaditione thear cnainfente air lock peneratinoneal mus bne is olaed brmay'okainmloedntheOEAL air locksth0 E!

door within, thMe 24hourd clompetio Time.

Athe2iour CoMplto Tia is conidre resnbenforelckn thatPRAL a

la igprilack r

has ba bei n

isolinained by the us* of an lOckEdAL

~~~~air l ock door.

This atooubensurlees wthat anhur acceptable hchreure ta primary containment lekgebudayi maintained. the CompALEstuswtion TIm hounepr.3asi bnasdditon, eninern aff~ete and ioc consietrediadequatbe isola1thedb lowklikelihood ofe OEAB locked c

door beingn this4osrtCompetiand oTher adiiTraie c4 ontrComls.oTmi considered ractonal Ao3 ilodifing byaNthe thRALEatr lsct ai okdoorosidlocagthed inRAL high

-o raition arfease airlc thsbein doorstoibed erifed.lce lse yueo t:* a" iitrdActivontos A

lloin enuehtterifiectdation byk a~sratit conros bwisconsideed accetabe, usincealo&

acoessd hs airea isc tyialyretice.

Th ereforetha a

thceproablepitay ofntialignment ofakthe budoorync iths beentveified to bhe C

aion Th mo ne pr per position is sal bsdon enierngJdmntadi cnieedaeut

_Ffrl ~

helo lik.elihod~A ofalce doen

"B 3.6.1.2 BASES ACTIONS A.-. A.2. and A.3 (continued)

The Required Actions have been modified by two Notes.

Note 1 ensures that only the Required Actions and associated SCompletion Tinmes of Condition C are required if both doors in the air n

ock are inoperable.

Wsth both doors in the aired ClDr

's re c

lock inopernale, an OPERABLE door is not evailable to. b closed.

nit Actions C.1 and r

.2 are the appcipriate

v C*1A&

W 0*4o

~remedial actions.

T requxc edt equipmeNo t

.oes no t

affect tracking the Completion Tim from the initial entry into wa SCondition A; only the requmleant to compty wperform a Required Actions.

Note 2 allos use of the i

c l

4dueA to exth low prodabilitydof admnievetrtativ coutrld prsuiz C %U

,bthe piar cntainen dur ing thshr ieta h

riesth n irlo in t ehloc mecond im lock is scoveo 0_.% I e:*=

f-,* avia.

o th Primary containm ent airy may he re Reired to pe tonm.

specificalin Condictio A.

vilne-

.Rqie Acthons, as ei ll As otner a*b*evmiie**d.by.two Notes.

N cont1ns ment that arte required Ati ToSor andasviate d

Comp l tion sTm s ort TS-reqio red equipmentd if is b

oth is

<441-L W" -e.*

nof i*-ndedo p'reclude performing other act.ivi.ties (i.e.,

e06.

/~.

non-TS-related activities) if the primary contaiment was intored naim ok e t

noM preble rocki to peiror h

an Slock alloancd is accvpaleo ble due to the moi probability of an event that oound pressurize the primary containment during the short time that the OPERABILE door is expected to be open.

With an air lock interlock mechanism inoperable in on* or both primary containme(t air locks, the Required Actions and associated Completion Times are consistent with those specified in Condition A.

The Rewired Actions have ben modified by t 1o Notes.

Note 1 ensures that only the RewRred Actions and associated Completion Tins of Condition C are required if both doors in one air lock are inoerale. With both doors in the air lock inoprable, an *OPEABLE door is not available to be closed.

Required Actions C.1 and C.2 are the appropriate remedial acetions.

Note 2 allows entry into and exit from the primary containment under the control of a dedicated (continued)

SWIG6 STS 3.6-10 Rev 1, 04/07/95 REVISION E

Primary Containment Air Locks 4

8 3.6.1.2 BASES R.I. 9.2. and 3.3 (continued)

Y individual stationed at the air lock to ensure that only one door is opened at a time (i...,

the individual performs the

0* L~o5

A'.411 function of the interlock).

-16 e-6 Required Action 3.3 is modified by a Note that applies to L-0 "*

Cve",

air lock doors located in high radiation are and allows these doors to be verified locked closed by use of administrative controls.

Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted.

Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small.

C-1. C.2. and C.3 With one or more air locks inoperable for reasons other than those described in Condition A or B, Required Action C.!

requires action to be imediately initiated to evaluate containment overall leakage rates using current air lock leakage test results.

An evaluation is acceptable since it is overly conservative to imediately declare the primary containment inoperable if both doors in an air lock have failed a seal test or if the overall air lock leakage is not within limits.

In many Instances (e.g.. only one seal per door has failed) primary containment rmains OPERABLE, yet only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (according to LCO 3.6.1.1) would be provided to restore the air lock door to OPERABLE status prior to requiring a plant shutdown.

In addition, even with both doors failing the seal test, the overall containment leakage ra411 L-l -4b-4.

14 Uli l IIl*

Required Action C.2 requires that one door in the affected primary containment air locks must be verified closed.

This Required Action must be comleted within the I hour Copletion Tim.

This specified tim period is consistent with the ACTIONS of LCO 3.6.1.1, which require that primary r4..c-#

containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

~ C.V)Addt 21_1y the air lock must be restored to OPERABLE flatus wlthln -V no The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Tim is reasonable for restoring an inoperable air lock to OPERABLE status considering that at least one door is maintained closed in each affected air lock.

(continued)

SM/6 STS B 3.6-1l Rev 1, 04/07/95 REVISION E l

Primary Containment Air Locks B 3.6.1.2 BASES ACTIONS (continued)

.1. and W.2 If the inoperable primary containment air lock cannot be restored to OPERABLE status within the associated Completion Tim, 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 MOVE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to 1O0E 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

Maintaining primary containment air locks OPE]ASLE requires The SR has been modified by two Notes.

Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a DBA.

Note 2 has been added to this SR, requiring the 7Peresuts toae evaluated against the acceptance criteria SK 3.6.1.1.1.A This ensures that air lock leak ae is properly accounted for in determining the primary containment leakage rate.

BlR/G STS

Primary Contaiment Air Locks B 3.6.1.2 BASES SURVEILLASN36CE2.

REQUIRENI S[I (continue)

The se~al a 14flask pressu si verified~t be at z 190] psig//

S every 7 jys to enutt*

the seal s Jtem remains viable/

S[

I ~It must(I Chuce beae at could bl I down during oa/

S"

[

i access the air lack) which occurs regular The day F ency has shown to be Saccep a throug opera ing experien and is consid red

~a a in vie of*

the bther indi ri~ons available )

0

-tosprsonnel t*

he s' air fakpres a' is The air lock interlock mechanism is designed to prevent simultaneous opening of both doors in the air lock.

Since 41-.0-L-ov-fvtliy both the inner and outer doors-of air lock are designed to withstand the maXimum ad post accident primary containment pressure (Ref.

_ osure of either door will support primary containment OPERABILITY.

Thus, the

/~e..d -ov

£'iv/

interlock feature supports primary containment OPERABILITY d

-while the air lock is being used for personnel transit in Ipie

-e t.

and out of the contatnment.

Periodic testing of this interlock demonstrates that the interlock vwil function as S.L-r;c-t " k

,-e-.._e designed and that simultaneous inner and outer door opening S*o s;v 4eoX-will not inadvertently occur.

Due to the purely mechanical

-64 nature of th s interlock, and given that the interlock i

challengd when the primary containment air lck doorFTFQUý Ithis test is only required to be more*

o 184 requency s

ased on "nering i

- S n

norro REVISION E

.BR/6 STS B 3.6-13 Rev 1, 04/07/95

INSERT BSR 36122 every 24 months.

The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage, and the potential for loss of primary containment OPERABILITY if the Surveillance were performed with the reactor at power.

Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.

j~(A.I S -rs) ",C Insert Page B 3.6-13 REVISION E 5I I'

-row N

Primary Containment Air Locks B 3.6.1.2 SUcreILAC SURVEILLANC REUIREMENTS I

REFERENCES 11AFSAR, Section (R N...

2.-O f

q0!W-fld p4-A L------------

bj--

4%

cu.

3.:+

CcWc NcaW;-L6ge-I S 3.6-14 Rev 1, 04/07/95 REVISION E 31W1/6 STS DACr*

Ithe S ~eHace were pefpe wit thne p or at m*

Ithe i

-I I

lance whe armedo a:

[181xu monthn rru;e-n;,

Lstandpoint.

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS)

CONVERSION ITS 3.6.1.2 Primary Containment Air Locks JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1434, REVISION 1, BASES d'.

JUSTIFICATION -FOR DIFFERENCES FROM NUREG-1434, REVISION 1 ITS BASES: 3.6.1.2 -

PRIMARY CONTAINMENT AIR LOCKS RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 Not used.

CLB2 The bracketed values have been corrected consistent with the Primary 1-4 Containment Leakage Rate Testing Program.

PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the plant specific system/structure/component nomenclature, equipment identification, or description.

PA2 Editorial change made for enhanced clarity or to be consistent with similar statements in other places in the Bases.

PA3 Typographical or grammatical error corrected.

PA4 These words have been deleted since the primary containment may need to be entered for reasons related to Technical Specifications that are not specifically on "equipment."

This could include sampling and inspections.

The intent has not changed in that it must still be related to Technical Specifications.

PA5 Editorial changes have been made to be consistent with the wording in the Specification.

PA6 SR 3.6.1.2.1 has been modified with Note 2 consistent with the allowances in Note 3 of the ITS 3.6.1.2 ACTIONS.

The Bases has been revised to reflect this modification.

PA7 Changes made to allow verification of the closure of air lock doors by

-S administrative means when the primary containment is inerted to reflect the BWR-4 design.

The change is consistent with NUREG-1433, Revison 1.

PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB1 ITS 3.6.1.2 has been revised to reflect plant specific differences based on the JAFNPP design of the Primary Containment air locks.

JAFNPP primary containment contains two air locks, the personnel access hatch.

used for normal entry and exit, and the emergency escape hatch that may Page 1 of 3 JAFNPP Revision E

I, JUSTIFICATION-FOR DIFFERENCES FROM NUREG-1434, REVISION 1

+-

ITS BASES: 3.6.1.2 - PRIMARY CONTAINMENT AIR LOCKS PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB1 (continued) be used for entry and exit.

The changes are consistent with the format and content of NUREG-1434, ISTS 3.6.1.2. which addresses designs with two air locks, but with one exception.

ITS 3.6.1.2 Condition A Note 2, that entry and exit is permissible for 7 days under administrative control, will not include the requirement that both air locks be inoperable.

Access through the narrow emergency escape hatch is severely restricted with regards to personnel and equipment.

Therefore, the 7 days will apply to the use of the personnel access hatch as well as the emergency escape hatch.

DB2 ITS 3.6.1.2 has been revised to reflect a specific JAFNPP design difference.

JAFNPP does not provide indication in the control room to alert the operator when an air lock interlock mechanism is defeated.

Therefore this information in the Background has been deleted.

DB3 The personnel access and emergency escape airlock are shaped as right circular cylinders but have different dimensions (10'-4" and 6'-2m OD, respectively).

These details are not included in the Bases since this information does not provide any pertinent information concerning the Operability of the airlocks.

DB4 ISTS SR 3.6.1.2.2 Bases and SR 3.6.1.2.4 Bases have been deleted since

\\.*

the FitzPatrick plant design does not include an air lock seal air system.

SR 3.6.1.2.3 Bases has been renumberd to reflect the change.

DB5 ITS 3.6.1.2 has been revised to reflect the specific JAFNPP reference requirements of UFSAR, Section 5.2, Primary Containment System.

{

J DIFFERENCE BASED ON AN APPROVED TRAVELER (TA)

TAI The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler number 17, Revision 2 have been incorporated into the revised Improved Technical Specifications.

TA2 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler number 52, Revision 3 have been incorporated into the revised Improved Technical Specifications.

1 Page 2 of 3 JAFNPP Revision E

JUSTIFICATIONFOR DIFFERENCES FROM NUREG-1434, REVISION 1 ITS BASES: 3.6.1.2 - PRIMARYoCONTAINMENT AIR LOCKS DIFFERENCE BASED ON A SUBMITTED, BUT PENDING TRAVELER (TP)

None DIFFERENCE FOR ANY REASON OTHER THAN THE ABOVE (X)

X1 NUREG-1434, Revision 1, Bases reference to "the NRC Policy Statement" has been replaced with 10 CFR 50.36(c)(2)(ii), in accordance with 60 FR 36953 effective August 18, 1995.

X2 The bracketed method to establish the air lock leakage limits in SR 3.6.1.2.1 has been revised to be consistent with plant specific method.

A Reference has been added as a result of this modification.

Page 3 of 3 I

4 JAFNPP Revi si on E

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.2 Primary Containment Air Locks RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES

Primary Containment Air Locks 3.6.1.2 3.6 CONTAINMENT SYSTEMS 3.6.1.2 Primary Containment Air Locks LCO 3.6.1.2 APPLICABILITY:

Two primary containment air locks shall be OPERABLE.

MODES 1. 2. and 3.

ACTIONS NOTES..........................

1.

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

2.

Separate Condition entry is allowed for each air lock.

3.

Enter applicable Conditions and Required Actions of LCO 3.6.1.1. "Primary Containment," when air lock leakage results in exceeding overall containment leakage rate acceptance criteria.

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

containment air locks

1.

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

2.

Entry and exit is permissible for 7 days under administrative controls.

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

AND (continued)

Amendment (Rev. E)

JAFNPP 3.6-3

Primary Containment Air Locks 3.6.1.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

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

AND A.3

........ NOTE.........

Air lock doors in high radiation areas or areas with limited access due to inerting may be verified locked closed by administrative means.

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

B.

One or more primary NOTES............

containment air locks

1.

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

2.

Entry into and exit from primary containment is permissible under the control of a dedicated individual.

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

(continued)

Amendment JAFNPP 3.6-4

Primary Containment Air Locks 3.6.1.2 f

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.

(continued)

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

AND B.3

........ NOTE.........

Air lock doors in high radiation areas or areas with limited access due to inerting may be verified locked

-closed by admini strative means.

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

C.

One or more primary C.1 Initiate action to Immediately containment air locks evaluate primary inoperable for reasons contai nment overall other than Condition A leakage rate per or B.

LCO 3.6.1.1, using current air lock test results.

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

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

(continued)

Amendment JAFNPP 3.6-5

Primary Containment Air Locks 3.6.1.2 ACTIONS -(continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

AND D.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.2.1

NOTE..................

1.

An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2.

Results shall be evaluated against criteria applicable to SR 3.6.1.1.1.

Perform required primary containment air In accordance lock leakage rate testing in accordance with the with the Primary Containment Leakage Rate Primary Testing Program.

Containment Leakage Rate Testing Program SR 3.6.1.2.2 Verify only one door in the primary 24 months containment air lock can be opened at a time.

JAFNPP 3.6-6 Amendment

,IV

Primary Containment B 3.6 CONTAINMENT SYSTEMS B 3.6.1.2 Primary Containment Air Locks BASES BACKGROUND Two double door primary containment air locks (personnel access hatch and emergency escape hatch) have been built into the primary containment to provide personnel access to the drywell and to provide primary containment isolation during the process of personnel entering and exiting the drywell.

The air locks are designed to withstand the same loads, temperatures. and peak design internal and external pressures as the primary containment (Ref. 1).

As part of the primary containment, the air locks limit the release of radioactive material to the environment during normal plant operation and through a range of transients and accidents up to and including postulated Design Basis Accidents (DBAs).

Each air lock door has been designed and tested to certify its ability to withstand a pressure in excess of the maximum expected pressure following a DBA in primary containment.

Each of the personnel access hatch doors contains double gasketed seals and local leakage rate testing capability to ensure pressure integrity.

To effect a leak tight seal, the air lock design uses pressure seated doors (i.e., an increase in primary containment internal pressure results in increased sealing force on each door).

Each air lock is nominally a right circular cylinder, with doors at each end that are interlocked to prevent simultaneous opening.

The air locks are provided with limit switches on both doors in each airlock that provide control room indication of door position.

During periods when primary containment is not required to be OPERABLE, the air lock interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent primary containment entry is necessary.

Under some conditions as allowed by this LCO, the primary containment may be accessed through the air lock. when the interlock mechanism has failed, by manually performing the interlock function.

The primary containment air locks form part of the primary containment pressure boundary.

As such, air lock integrity and leak tightness are essential for maintaining the primary containment leakage rate to within limits in the event of a (continued)

Revision 0 (Rev. E)

Air Locks B 3.6.1.2 I

jw)

N

'3

,JAFNPP 8 3.6-6

Primary Containment Air Locks B 3.6.1.2 BASES BACKGROUND DBA.

Not maintaining air lock integrity or leak tightness (continued) may result in a leakage rate in excess of that assumed in the plant safety analysis.

APPLICABLE The postulated DBA that results in the maximum release of SAFETY ANALYSES radioactive material within primary containment is a LOCA.

In the analysis of this accident, it is assumed that primary containment is OPERABLE. such that release of fission products to the environment is controlled by the rate of primary containment leakage.

The maximum allowable leakage rate (L,) for the primary containment is 1.5% by weight of the containment air per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at the peak containment pressure (Pa) of 45 psig (Primary Containment Leakage Rate Testing Program).

This allowable leakage rate forms the basis for the acceptance criteria imposed on the SRs associated with the air locks.

Primary containment air lock OPERABILITY is also required to minimize the amount of fission product gases that may escape primary containment through the air lock and contaminate and pressurize the secondary containment.

The primary containment air locks satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 2).

LCO As part of the primary containment pressure boundary, the air lock's safety function is related to control of containment leakage following a DBA.

Thus, the air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event.

The primary containment air locks are required to be OPERABLE.

For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test.

and both air lock doors must be OPERABLE.

The interlock allows only one air lock door to be opened at a time.

This provision ensures that a gross breach of primary containment does not exist when primary containment is required to be OPERABLE.

Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events.

Nevertheless, both doors are kept closed (continued)

JAFNPP B 3.6-7 Revision 0 (Rev. E) 4

Primary Containment Air Locks B 3.6.1.2 BASES LCO when the air lock is not being used for normal entry or (continued) exit from primary containment.

APPLICABILITY In MODES 1. 2, and 3, a DBA could cause a release of radioactive material to primary containment.

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

Therefore. the primary containment air locks are not required to be OPERABLE in MODES 4 and 5 to prevent leakage of radioactive material from primary containment.

ACTIONS The ACTIONS are modified by Note 1. which allows entry and exit to perform repairs of the affected air lock component.

If the outer door is inoperable, then it may be easily accessed for most repairs.

It is preferred that the air lock be accessed from inside primary containment by entering through the other OPERABLE air lock.

However, if this is not practicable, or if repairs on either door must be performed from the barrel side of the door, it is permissible to enter the air lock through the OPERABLE door, which means there is a short time during which the primary containment boundary is not intact (during access through the OPERABLE outer door).

The allowance to open the OPERABLE door, even if it means the primary containment boundary is temporarily not intact, is acceptable due to the low probability of an event that could pressurize the primary containment during the short time in which the OPERABLE door is expected to be open.

The OPERABLE door must be immediately closed after each entry and exit.

Note 2 has been included to provide clarification that, for this LCO, separate Condition entry is allowed for each air lock.

This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable air lock.

Complying with the Required Actions may allow for continued operation, and a subsequent inoperable air lock is governed by subsequent Condition entry and application of associated Required Actions.

The ACTIONS are modified by a third Note, which ensures appropriate remedial measures are taken when necessary, if (continued)

Revision 0 (Rev. E)

JAFNPP B 3.6-8

Primary Containment Air Locks B 3.6.1.2 BASES ACTIONS air lock leakage results in exceeding overall containment (continued) leakage rate acceptance criteria.

Pursuant to LCO 3.0.6.

actions are not required, even if primary containment leakage is exceeding L.

Therefore, the Note is added to require ACTIONS for LCb 3.6.1.1, "Primary Containment." to be taken in this event.

A.1. A.2. and A.3 With one primary containment air lock door inoperable in one or more primary containment air locks, the OPERABLE door in each affected air lock must be verified closed (Required Action A.1).

This ensures that a leak tight primary containment barrier is maintained by the use of an OPERABLE air lock door.

This action must be completed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Co:pletion Time is consistent with the ACTIONS of LCO 3.6.1.1, which requires that primary containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

In addition, the affected air lock penetration must be isolated by locking closed the OPERABLE air lock door within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is considered reasonable for locking the OPERABLE air lock door, considering the OPERABLE door of the affected air lock is being maintained closed.

Required Action A.3 ensures that the affected air lock penetration has been isolated by the use of a locked closed OPERABLE air lock door.

This ensures that an acceptable primary containment leakage boundary is maintained.

The Completion Time of once per 31 days is based on engineering judgment and is considered adequate given the low likelihood of a locked door being mispositioned and other administrative controls.

Required Action A.3 is modified by a Note that applies to air lock doors located in high radiation areas or areas with limited access due to Inerting and allows these doors to be verified locked closed by use of administrative controls.

Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted.

Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position. is small.

(continued)

Revision 0 (Rev. E)

B 3.6-9 JAF'NPP

Primary Containment Air Locks B 3.6.1.2 BASES ACTIONS A.1. A.2. and A.3 (continued)

The Required Actions have been modified by two Notes.

Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the air lock are inoperable.

With both doors in the air lock inoperable, an OPERABLE door is not available to be closed.

Required Actions C.1 and C.2 are the appropriate remedial actions.

The exception of Note 1 does not affect tracking the Completion Time from the initial entry into Condition A; only the requirement to comply with the Required Actions.

Note 2 allows use of the affected air lock for entry and exit for 7 days under administrative controls.

Primary containment entry may be required to perform Technical Specifications (TS) Surveillances and Required Actions, as well as other activities inside primary containment that are required by TS or activities that support TS-required equipment.

This Note is not intended to preclude performing other activities (i.e., non-TS-related activities) if the primary containment was entered, using the inoperable air lock, to perform an allowed activity listed above.

The required administrative controls consist of stationing a dedicated individual to assure closure of the OPERABLE door except during the entry and exit, and to assure the OPERABLE door is relocked after completion of the containment entry and exit. This allowance is acceptable due to the low probability of an event that could pressurize the primary containment during the short time that the OPERABLE door is expected to be open.

B.1. B.2. and B.3 With an air lock interlock mechanism inoperable in one or both primary containment air locks, the Required Actions and associated Completion Times are consistent with those specified in Condition A.

(continued)

Revision 0 (Rev. E)

JAFNPP B83.6-10

Primary Containment Air Locks B 3.6.1.2 BASES ACTIONS B.1, B.2. and B.3 (continued)

The Required Actions have been modified by two Notes.

Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the same air lock are inoperable.

With both doors in the same air lock inoperable, an OPERABLE door is not available to be closed.

Required Actions C.1 and C.2 are the appropriate remedial actions.

Note 2 allows entry into and exit from the primary containment under the control of a dedicated individual stationed at the air lock to ensure that only one door is opened at a time (i.e., the individual performs the function of the interlock).

Required Action B.3 is modified by a Note that applies to air lock doors located in high radiation areas or areas with limited access due to inerting and allows these doors to be verified locked closed by use of administrative controls.

Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted.

Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small.

C.1. C.2. and C.3 With one or more air locks inoperable for reasons other than those described in Condition A or B, Required Action C.1 requires action to be inmmediately initiated to evaluate containment overall leakage rates using current air lock leakage test results.

An evaluation is acceptable since it is overly conservative to immediately declare the primary containment inoperable if both doors in an air mOCK have failed a seal test or if the overall air lock leakage is not within limits.

In many instances (e.g.. only one seal per door has failed), primary containment remains OPERABLE, yet only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (according to LCU 3.6.1.1) would be provided to restore the air lock door to OPERABLE status prior to requiring a plant shutdown.

In addition, even with both doors failing the seal test, the overall containment leakage rate can still be within limits.

Rieuired Action C.2 requires that one door in the affected primary containment air locks must be verified closed. This Required Action must be completed within the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Coletion Time.

This specified time period is consistent with the ACTIONS of LCO 3.6.1.1 which require that primary containent be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

(continued)

Revision 0 B 3.6-11 JAFNPP

Primary Containment Air Locks B 3.6.1.2 BASES ACTIONS C.1. C.2. and C.3 (continued)

Additionally, the air lock must be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Required Action C.3).

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable for restoring an inoperable air lock to OPERABLE status considering that at least one door is maintained closed in each affected air lock.

D.1 and D.2 If the inoperable primary containment air lock(s) cannot be restored 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 at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

SURVEILLANCE SR 3.6.1.2.1 REQUIREMENTS Maintaining primary containment air locks OPERABLE requires compTiance with the leakage rate test requirements of the Primary Containment Leakage Rate Testing Program.

This SR reflects the leakage rate testing requirements with respect to air lock leakage (Type B leakage tests).

The acceptance criteria were approved in License Amendment 97 (Ref. 3).

The periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overall Drimary containment leakage rate.

The Frequency is required y the Primary Containment Leakage Rate Testing Program.

,it The SR has been modified by two Notes.

Note 1 states that an inoperable air lock door does not invalidate the previous.

successful performance of the overall air lock leakage test. 6 This is considered reasonable since either air lock door is W

capable of providing a fission product barrier in the event

x of a DBA.

Note 2 has been added to this SR, requiring the 0

results to be evaluated against the acceptance criteria which is applicable to SR 3.6.1.1.1 (Primary Containment Leakage Rate Testing Program).

This ensures that air lock leakage is progerly accounted for in determining the combified Ty0e and C primary containment leakage.

(continued)

Revision 0 (Rev. E) 1.4 /

JAFNPP B 3.6-12

Primary Containment Air Locks B 3.6.1.2 BASES SURVEILLANCE SR 3.6.1.2.2 REQUIREMENTS (continued)

The air lock interlock mechanism is designed to prevent simultaneous opening of both doors in the air lock.

Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident primary containment pressure (Ref. 1). closure of either door will support primary containment OPERABILITY.

Thus, the interlock feature supports primary containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment.

Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous inner and outer door opening will not inadvertently occur.

Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is not normally challenged when primary containment air lock is used for entry and exit (procedures require strict adherence to single door opening), this test is only required to be performed every 24 months.

The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage, and the potential for loss of primary containment OPERABILITY if the Surveillance were performed with the reactor at power.

Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.

The 24 month Frequency is based on engineering judgment and is considered adequate given that the interlock is not challenged during use of the air lock.

REFERENCES

1.

UFSAR, Section 5.2.

2.

10 CFR 50.36(c)(2)(ii).

3.

NRC Letter dated November 21, 1985, Issuance of Amendment 97 to the Facility Operating License DPR-59 for James A. FitzPatrick Nuclear Power Plant.

Revision 0 (Rev. E)

JAFN1PP B 3.6-13

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

DISCUSSION OF CHANGES (DOCs) TO THE CTS NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC)

FOR LESS RESTRICTIVE CHANGES MARKUP OF NUREG-1433, REVISION 1, SPECIFICATION JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION I MARKUP OF NUREG-1433, REVISION 1, BASES.

JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION 1, BASES RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES

11 /

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

cNýOTE: ýSee Ktsfolw~aa~e.ý5 Amendment No. 1( 4*

9,0, 106, W20, 1G3 10 1, 190, 227t, 2 yr 79 I

To re. / 0 1

peci1c4L I) g lndtlaly once every month until acceptance failure ratedata are available: theremftero a request may be made to the NRC to I

change the test frequency. The compilation of Instrument I

failure rate data may Include data obtained from other boiling "

water reactors for which the sme design instruments operate) in a erwironment ekelW to that of JAFNP, Functional teats e not mquired when then instrunmnts wre not required to be operadle or er tripped. Functional tests OWal be perfomed within seven 171 days prior to each startup.

Calibrations we nst mrqued when these instruments ea not required to be operable or we tipped. Calibratlon testshai be perfonned wh seven 171 days prior to each startup or

56. This I*struentatl* is exempt tron te nincuonu test definition. The functional test will consist of Infecting a sim"ulted elect"ical into the measurement channel.

6. The instrumenft h ell be calibrated using *lulat~d eletrial Signals onc every three months.

Co-. Reactor low wtrlvl n

ihdyeiIeseeae*

Included on Table 4.2-1 since they are listed on Tebm%!--

9.

The logic system functional tests shall Include a calibration---'*

of time delay relays and timers necessary for proper functioning of the trip systems.&

11. Perform a calibration once per 24 months using a radiation source. Perform en Instrument channel alignment once every 3 month using a current source.

14*.--t*GR ensor calibration once per 24 months. Masterlslave trip unit calibration once per 6 months.

I C16.The quarterly calibration of the temperature sensor consists

-)of comparing the active temperature signal with a k.redundant temperature signal.or 7 Simulated automatic actuation shall be performed once per 24 233 Anmndnmnt NO-4r"9

09. "It

.1 JAFNPP

(.6 t, -

Erg Atli 84

7) jGF, 'P. l i

/ \\

/

/.

JAI*I*P.

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See 0 o,6 I*

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r od withdr a

hal

" e ma d 0 O W N tho aod e 8

e I

N t hee t h amtor ie t hat ler v

leo.

h M o lo t p

)te e, t le m th e tr lo" e h e is io rh mawb e I

seruiice f

orUS A

Syatem. subs ystem, train.

omponent t

or d" vi c l be to R r Ofr have 0PRiAoIL11r

, Ma ue Mad e -

t h"Is me "

M re ao t

or iS whth shoom It Is ca peble of pe rforlm a

g Ith r

peclate d

- e e

m e at oramt he ageaor Mee th e s i foctl NOm). implicit to this deci nition *hall m

o

.be tho a Oseraptio na ma that a s y tte d n

o oa.er protectise on edtitem Is aebiove oith istrmtortio.

Cmotrols. Nireal dad fmruactss wih Proect o

sing oeeb the ipsrt ree1t eletriecl Poi r oeerous. oollo of seat attr,

b.

Cilk E

ulmu maip) ad co diie Ms l a

boves in prkm yla ltre ewustecdo n

wihm e

moercela t

-o et lar ief lo e

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oto e ther elo hesbeu ftert ip

) at t

auxiliary eqtipmeit thmt tre w

N.

llre ird fo a

t c statems t so laytemi tralv, ca Sn-re o i tprato e

or de ice i to perfom ita fcac tconditi dam ~ ~ ~

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es cepum b..

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_a bloeq O o1 prorte lta their reateod support do s

of-o o

m Wos u

Nef

sw r* ita Is to*lO l

l are cloed me" poa etlmy.

I.

hge

--- a~i_

l.

friU;Ml

- Otoratiy gnoases that a system or ae, I.le shton nm codtoso Coffomnt Is Perforsing Its Intendd functions in With V(zr coolant

/1poret1o,>nr.

Its required mraS.

b.

Cold sota"~M momonditions o

-818~n L.

ft&mgCI

- ittorval between the end of one W i t h r e s -c u e C o o l e t u se r s uret r

of n qorm a l i s No t h e a n d o

h o

u 0 nn ALiPI. sa the reactor vessel vested.

fuln

- /

_o tesbeu f ten rtIVI, si.db -,

u.torti e

h low..*:.*

0~ a" IM aILEro wiier tit hean Re. )g'. f i

134 i**

S 3

.'.*, -'--ee-

1.

All Smuenl CO~tt sest Isolation valvol on

,.}.*

lines connected to the Reactor Coolant*

Ssystem of conttioist which are not required S*. /.3, to bie MRSoaedrial pleat accident conditionsi 0

ailoe.

.ot, Atmendment No.,M"

,134,

,Vote 2-,$£3.(,l 3s.

Ut 4

,V

i '/'1 JAFWPP v7

,or4 / h A cn,IJJ (cont'di boh t.

J3 3.6,.

Z -oimed to perform necessry operational AtSl

1.

1,3 j'o 36.

J. 2. 3*~

'16 "Ge b&in N.at,,

Power-R.A.fod power refers to operation at a Neaor f-56

. This is also termed 100 pero_.

power enwd Is ith mai*mum power level authorized by Ithe opaft eee. Raed *team fow, rated calnt

.ow.

rate p

macerytm pressure. refer to the valuea of tOh pa ametr when the reactor is at rated power (Reference O.

RoRaic*

otor power operation Is any aper wih t moo Switch In the St.*.W

_..tp t

StaIdby or AIm positi with the reactor critical and above Spercet rated h power.

P.

fA-AmnLfaa i Mh - U-doss otherwe ditWe.d.,

ome vili pre.

edn the Technical SpeiEIcel~S m' thoae measured by the reactor vessel iteim Ipam esneor.

0 o

Ngup oll is the peiood of time the startup of the plan subseqent. to thot refueling.

fl SifegLJJWlilA-The safety Emits are limits within which A.

"go,-0-maintenac of the fuel cladding Integrity and the reactor coolant system Integrity are assured.

Violation of such a imit is causloe unit shutdown and review by the Nuclear latory C1ommis before r.sWi o of wit OpSI~I.

operation beyond such a Unit may not In Itsel rmt In serious consWene but it)

The surveliflnce frequency notations IIntervals used-in these specifications re defined as follows:

Noallon Intaad Frnunc D

Daily At least once per 24 howis W

Weekly At least once per 7 days M

Monthly At boat once per 31 as a

Ourtarly or At least once par 92 days every 3 months SA Selannually or At least once par 184 days every S months A

Annually or Yearly At leas once per 366 days 19M I$ Month At log once per 18 mitholll deays)

R Op*eratng Cycle At besmt one* Par 24 month 4731 77-

.,-,.1r Anmendment No. 14.

121, Is$, a227.

231. 239 Id4~~

t,

l,

",P

5' r cc I fn C sk.1-1 a&,%

Pdmam Contakvmnt Isolation Ve q

AnmvknogNo. *54,03,406,232.233 242 165 PAIA.-

ý- " -F

N JAFNPP Freauency Qi

1 Fast close each main In accordance with steam isolation valve, the Inservice Testing and verify closure Program time.

Whenever a containment isolation valve is inoperable, the position of at least one o valve in each line having an inoperable valve shall be C_.,q

, AC.,-aM A3 2.

"Isolate each affected penetration withiriA use of at least one deactivated automatic fiueou in m e CiOSeO posmon.

so1ation vw

]closed to satisfy these requirements may I lreopened on an intermittent basis underf Isolate each affected penetration withir*

Sfuse of at least one closed manual valve or

{flange.

I C)'o*_ if Vo(l*.

4!I

3.

If Specifications 3.7.D.1 or 3.7.D.2 cannot be n acor shallb ' the cold condition within*

Amend

'No.

M.4 19,"4 -,.

242,

-60 I

I,'

4 REVISION E 1 -ý V,

L 0 ý 9 J

Se-e-f q; Cý 0ýt;"

3-10.1. 3

['S M Z J, A -I - 41d.

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poo eouuate 1he le6 ge to~ow mus be.1 reduce to beo be northnmcalervlv hn ieu (3).

Th reacto oile at sc e

45m anyg atampeereaeuting.la codiio IfI~

do had 10pestr repche pa Iav OOhdosmlaly lda PW"~~.3 pugU atl amben be esued ntimthe.a tempratmet Io. reduced 239o h nra oe r.S 0 alloatio M*

Pdft'i" II 800ve166, 141~~~~~~

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oratr Pto"Wo~~Kev~ie.

vesl@

etols mS aem ally

.Y

,/, -3 1

,

7 JAFNPP 3.1 (Contd) 4.7 (Contd)

(1)

The drywell to torus differential pressure shall be established within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ot exceeding 15%

rated thermal power during startup. The diferential pressure nay be reduced to less than the limit up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing thermal power to less than 15% of rated before a plant 7"/-5 3,6. *,

shutdown.

(2)

The differential pressure may be decreased to less than 1.7 psid for a maximum of four (4) hours during required operablhlity testing ot the HPCI, RCIC, and Suppression Chamber Drywel Vacuum Breaker System.

(3)

N 3.7.A.7.11 above cannot be met, restore the differentil pressure to within limits withn eight Shours or reduce thermal power to less than 15%

"of rated within fth next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

8.

It the specificaltios at cano. b met the reactor shall be the cold conditioni withinff

)J~)YET) hours.

-j Amendment No'. X,3,W. 221 180a

'1

.1 5P"C " 'hj fS " "g.

4,15 LA-117,

)

JAFNPP 3.7 icont'd) 4.7 (cont'dl v-.

b.

If in Refuel or Cold Shutdown mode, reactor operation or Irradiated fuel handling is permissible only during the succeeding 31 days unless such circuit is sooner made operable, provided that during such 31 days

3. C,,

1_

all active components of the other Standby Gas Treatment Circuit shall be operable.

3.

If Specifications 3.7.B.1 and 3.7.B.2 are not met, the

3. Intentionally Blank reactor shall be placed in the cold condition and irradiated fuel handling operations and operations that could reduce the shutdown margin shall be ohibited.

4.

Whenever primary containment integrity is require 1

sh as specified in Section 3.7.A.2. Valve 27MOV-1 2 containment integrity shall be used for inerting or deinerting.

month.

N co.

tu R.

q 4 <

Amendment No. 444, 269 REVISION E 183a

'-I 4

all be verified closed when is established, and then once per I

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

DISCUSSION OF CHANGES (DOCs) TO THE CTS I

4 I

DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

ADMINISTRATIVE CHANGES Al In the conversion of the James A. FitzPatrick Nuclear Power Plant (JAFNPP) Current Technical Specifications (CTS) to the proposed plant

-specific Improved Technical Specifications (ITS) certain wording preferences or conventions are adopted that do not result in technical changes.

Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the conventions in NUREG-1433.

"Standard Technical Specifications, General Electric Plants. BWR/4",

Revision 1 (i.e., Improved Standard Technical Specifications (ISTS)).

A2 Three Notes have been added to CTS 3.7.D.

Proposed ITS 3.6.1.3 ACTIONS Notes 2, 3, and 4 have been included consistent with NUREG-1433, Revision 1.

These Notes facilitate the use and understanding of the proposed ACTIONS and the relationship between INOPERABLE PCIVs and system OPERABILITY.

ITS 3.6.1.3 Note 2, which allows separate Condition entry for each penetration flow path, provides explicit instructions for proper application of the ACTIONS for Technical Specification compliance.

In conjunction with the proposed Specification 1.3, "Completion Times," this Note provides direction consistent with the intent of the existing ACTIONS for inoperable isolation valves.

ITS 3.6.1.3 Note 3. to enter applicable Conditions and Required Actions for systems made inoperable by PCIVs, establishes the need to verify individual system OPERABILITY based on the affect of an INOPERABLE PCIV.

This requirement is consistent with individual CTS Surveillance Requirements to verify valve OPERABILITY and/or correct position.

ITS 3.6.1.3 Note 4. to enter the applicable Conditions and Required Actions of ITS 3.6.1.1, Primary Containment, when PCIV leakage exceeds the overall Primary Containment leakage rate acceptance criteria, establishes the need to consider the Primary Containment OPERABILITY if the PCIV leakage acceptance criteria Is not being met.

This change is consistent with the relationship of containment integrity and PCIV OPERABILITY established in the CTS 1.0.M definition of Containment Integrity.

In addition Note 4, clarifies that "systems" include the primary containment.

Since proposed LCO 3.0.6 waives the requirement to cascade, the intent of the CTS would not necessarily apply.

The clarification is consistent with the intent and interpretation of the existing Technical Specifications, and is therefore considered admi nistrati ve.

Page 1 of 14 Revision E JAFNPP

-A DISCUSSION OF CHANGES ITS: 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVS)

ADMINISTRATIVE CHANGES A3 CTS 3.7.D.2 requirement, to maintain at least one isolation valve operable in each affected penetration that is open, is being deleted.

-Proposed ITS 3.6.1.3 Condition A Note has been provided to restrict the applicability to penetrations with two PCIVs. where a second valve is available.

This Note is consistent with the Notes provided in the new proposed ITS 3.6.1.3 Condition B (L3) for two valves inoperable in a penetration with two PCIVs, and ITS 3.6.1.3 Condition C (L4) for penetrations with only one PCIV.

The addition of this Note identifying the applicable configuration, in conjunction with the separate and specific requirements provided in the proposed Conditions, is consistent with the format of NUREG-1433, Revision 1.

Since there is no change in any technical requirements, this change is considered administrative.

A4 The requirement in CTS 3.7.D.2.a, to "restore the inoperable valve(s) to operable status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ," has been deleted since this is always an option.

Since the time requirements on the alternative actions (CTS 3.7.D.2.b and 3.7.D.2.c are identical this change is considered admi ni strative.

A5 The requirement to record the results in CTS 4.7.D.2 (ITS 3.6.1.3 Required Actions A.2 and C.2) is proposed to be deleted.

This requirement duplicates the requirements of 10 CFR 50 Appendix B, Section XVII (Quality Assurance Records) to maintain records of activities affecting quality, including the results of tests/verifications.

Compliance with 10 CFR 50 Appendix B is required by the JAFNPP Operating License.

The details of the regulations within the Technical Specifications are repetitious and unnecessary.

Therefore, retaining the requirement to perform the associated verifications and eliminating the details from Technical Specifications that are found in 10 CFR 50 Appendix B is considered a presentation preference, which is admi ni strati ve.

A6 CTS 4.7.A.2.b details, specifying the MSIV leakage limit and test pressure, have been deleted.

ITS SR 3.6.1.3.10 requires the MSIV leakage be within the limits of the Primary Containment Leakage Rate Testing Program.

Since identical values are identified in CTS 6.20 and in proposed ITS 5.5.6, Primary Containment Leakage Rate Testing Program, this change is a presentation preference and is considered administrative.

A7 Not Used.

AB CTS 3.7.A.2 (3.7.D.1) requirement for primary containment isolation valves (PCIVs) to be Operable, has been revised.

Proposed ITS LCO 3.6.1.3 provides an exception for reactor building-to-suppression Revision E Page 2 of 14 3AFNPP

'p DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

ADMINISTRATIVE CHANGES AB (continued)

-chamber vacuum breakers.

Although, reactor building-to-suppression chamber vacuum breakers isolate primary containment penetrations, they are excluded from this specification.

This change is acceptable since reactor building-to-suppression chamber vacuum breakers OPERABILITY requirements are currently specified in CTS 3.7.A.4 and retained in proposed ITS 3.6.1.6.

Along with this change the explicit requirement in CTS 3.7.D.1 that all instrument line excess flow check valves must be Operable has been deleted from the current LCO requirements.

Since the valves are considered PCIVs, there is no need to explicitly identify them.

Proposed ITS SR 3.6.1.3.8 will ensure the current requirements in CTS 4.7.D.1.b concerning instrument excess flow check valves are met.

This change constitutes a presentation preference, consistent with NUREG-1433. Revision 1, and therefore, is considered to be administrative.

A9 CTS 4.7.D.l.a requirement, to test PCIVs that are power operated and automatically initiated for simulated automatic initiation per the IST Program, is being revised to present the requirements as intended.

Since the IST Program does not specify the method used to initiate a test for closure timing (ITS SR 3.6.1.3.5), proposed ITS SR 3.6.1.3.7 verification that each automatic PCIV actuates to the isolation position on an actual or simulated isolation signal is provided.

The Frequency of 24 months has been included consistent with the ITS Program, and the requirements of CTS Table 4.2-1 (Note 7), Primary Containment Isolation System Instrumentation Test Cali bration Requirements. which specifies that actual (Li) or simulated automatic actuation shall be performed once per 24 months.

This change represents a presentation preference consistent with format and content provided in NUREG-1433, Revision 1.

and therefore, is considered to be administrative.

A1O CTS 4.7.D.1.c. specifying that all normally ?pen power operated isolation valves (except for the main steam isolation valves) shall be fully closed and reopened, at a Frequency in accordance with the IST Program, is considered to be encompassed by CTS 4.7.D.l.a. proposed ITS SR 3.6.1.3.5 (Verify the isolation time of each automatic PCIV, except for MSIVs, is within limits).

Since SR 3.6.1.3.5 will require closing each automatic PCIV in order to determine the isolation time, even normally open valves will be verified, on a Frequency consistent with the IST Program.

Since the valves are normally open, they will be closed and then reopened while performing the SR and therefore the stroking requirement is being met.

Since no technical changes are being made this change is considered to be administrative.

Page 3 of 14 Revision E JAFNPP

-I DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVS)

ADMINISTRATIVE CHANGES All CTS 3.7.A.2 reference to 'Primary Containment Integrity" has been deleted since the CTS definition of Primary Containment Integrity in CTS 1.0.M is incorporated into ITS 3.6.1.1, 3.6.1.2 and 3.6.1.3 and is no longer maintained as a separate definition in the ITS.

Proposed ITS 3.6.1.3 requires each primary containment isolation valve to be OPERABLE.

The definition of OPERABLE and the subsequent ITS 3.6.1.3 LCO, ACTIONs, and Surveillances are sufficient to encompass the requirements of the CTS definition.

This change removes any confusion which may exist between the definition and the specific requirements of the LCO and is a presentation preference consistent with NUREG-1433.

Revision 1.

Since all aspects of the Primary Containment Integrity definition requirements, along with the remainder of the LCOs in the Containment Systems Primary Containment section (i.e.. primary.

containment air locks, suppression pool, etc.) are maintained in subsequent Specifications of ITS this change is considered to be administrative only.

TECHNICAL CHANGES - MORE RESTRICTIVE M1 CTS 3.7.D.1 requires the primary containment isolation valves to be Operable whenever the primary containment integrity is required by CTS 3.7.A.2.

The Applicability in CTS 3.7.A.2 is at all times when the reactor is critical or when the reactor water temperature is above 212OF and whenever fuel is in the reactor vessel.

In addition, there is an exception in CTS 3.7.A.2. to not require primary containment integrity to be met during low power physics tests at atmospheric pressure and power levels not to exceed 5 IMt, however any change to this requirement is discussed in the Discussion of Changes for ITS 3.10.8.

The scope of the current Applicability covers MODE 1. 3 and portions of MODE 2 operations.

The Applicability in ITS 3.6.1.3 is MODES 1, 2 and 3.

This change is considered more restrictive since the containment will be required to be Operable at all times in MODE 2 even prior to any plant startup when reactor coolant temperature may be below 2120F.

In addition, a new Applicability is added to the current requirements.

ITS 3.6.1.3 Applicability, includes the condition for when associated instrumentation is required to be OPERABLE per LCO 3.3.6.1.

Since, in MODES 4 and 5. the probability and consequences of events which require primary containment isolation are reduced due to the pressure and temperature limitations of these MODES, most PCIVs are not required to be OPERABLE.

Only those PCIVs which isolate to prevent reactor vessel draindown are required in MODES 4 and 5.

Therefore, this change adds a MODES 4 and 5 requirement for RHR Shutdown Cooling System isolation valves.

In addition, ITS 3.6.1.3 ACTION G has been added for when Required Action and associated Completion Time of Condition A or B Revision E Page 4 of 14 JAFNPP

-d

-I DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVS)

TECHNICAL CHANGES - MORE RESTRICTIVE M1 (continued)

-cannot be met for PCIVs required to be OPERABLE during MODES 4 and 5.

This change places the plant in a condition in which the LCO does not apply.

In this case, suspension of operations with a potential for draining the reactor vessel (OPDRVs) is required to minimize the probability of a vessel draindown and subsequent potential fission product release.

Suspending an OPDRV may result in closing the RHR SDC isolation valves.

Therefore, an alternative Required Action is provided to immediately initiate action to restore the valve(s) to OPERABLE status.

This allows RHR to remain in service while ACTIONS are being taken to restore the valve.

These added requirements are necessary to ensure that PCIVs are OPERABLE during events when the primary containment penetrations may need to be isolated in MODES 4 and 5.

These changes are consistent with NUREG-1433, Revision 1.

M2 CTS 4.7.D.l.b Surveillance Requirement, to test for proper operation of the instrument line EFCVs, is being supplemented.

ITS SR 3.6.1.3.8 04 specifies acceptance criteria that the EFCV actuate to the isolate position on a simulated instrument line break.

The addition of acceptance criteria to a Technical Specification Surveillance Requirement, imposes additional operational requirements, and constitutes a more restrictive change.

This change is not considered to result in any reduction to safety.

M3 CTS 4.7.D.l.d Surveillance Requirement. to fast close each MSIV. one at a time, and verify closure time, is being supplemented.

Proposed ITS SR 3.6.1.3.6 specifies MSIV isolation time is m 3 seconds and s 5 seconds.

This change is acceptable since the isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the DBA and transient analysis.

The addition of acceptance criteria to a Technical Specification Surveillance Requirement, imposes additional operational requirements, and constitutes a more restrictive change.

This change is not considered to result in any reduction to safety.

M4 The CTS 4.7.D Surveillance Requirements and requirements in CTS 1.O.M.1 and 1.O.M.4 are being supplemented.

ITS 3.6.1.3 is adding the following four Surveillance Requirements:

l3 0

SR 3.6.1.3.2. verify (each 31 days) each PCIV manual isolation valve, or blind flange that is located outside of primary containment and not locked, sealed or otherwise secured and is required to be closed during accident conditions is closed.

Page 5 of 14 Revision E JAFNPP

DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - MORE RESTRICTIVE M4 (continued)

-0 SR 3.6.1.3.3, verify (prior to entering MODE 2 or 3 from MODE 4 if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days) each PCIV manual isolation valve, or blind flange that is located inside of primary containment and not locked, sealed or otherwise secured and is required to be closed during accident conditions is closed.

SR 3.6.1.3.4, verify (each 31 days) continuity of the traversing incore probe (TIP) shear isolation valve explosive charge.

SR 3.6.1.3.9. remove and test (each 24 months on a STAGGERED TEST BASIS) the explosive squib from each shear isolation valve of the Tip System.

These SRs provide the means of ensuring the PCIVs are OPERABLE and able to perform their safety function which is to provide primary containment isolation.

The addition of new Surveillance Requirements, imposes additional operational requirements, and constitutes a more restrictive change.

This change is not considered to result in any reduction to safety.

M5 CTS 3.7.D.3 (CTS 3.7.A.8) requirement, that the reactor to be in the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the requirements of CTS 3.7.D.1 or 3.7.D.2 (CTS 3.7.A.1 through 3.7.A.5) associated with inoperable PCIVs cannot be met, is being changed.

Allowances have been added to the current requirements to allow additional time to restore inoperable PCIVs, however these changes are addressed in Li. L3, L4, L9, and L10.

ITS 3.6.1.3 Required Action F.1 requires the plant to be in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the Required Action and associated Completion Times for Condition A, B, C, D, or E are not met in MODE 1. 2, or 3.

In addition, ITS 3.6.1.3 Required Action F.2 places the plant in MODE 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (L7).

The allowed Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable, based on operating experience, to reach the required plant condition from full power conditions in an orderly manner without challenging plant systems and is consistent with the requirements of NUREG-1433. Revision 1.

Since, this change imposes additional operational and time requirements it is considered to be more restrictive.

This change is not considered to result in any reduction to safety.

M6 Not Used.

Page 6 of 14 Revision E JAFNPP

ii DISCUSSION OF CHANGES

-ITS: 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - MORE RESTRICTIVE M7 CTS 4.7.B.4 requirement, that 27MOV-120 (12 inch, full-flow valve) be verified closed when containment integrity is established, and then once

-per month, is being revised.

ITS SR 3.6.1.3.1. requires verification that each 20 and 24 inch primary containment purge and vent valve is closed every 31 days.

Since the purge and vent valves are the actual primary containment isolation valves (PCIVs) associated with these penetrations, this change is appropriate.

Since CTS 3.7.B.4 allows inerting and de-inerting operations only with valve 27MOV-121 (6 inch, low flow valve) it is understood that the primary containment purge and vent valves must be opened for these operations.

Therefore, a Note has been added to proposed SR 3.6.1.3.1 which allows these operations to occur as long as the full-flow line (27MOV-120) is closed for protection of the SGT filter trains from over pressure concerns.

This change is considered more restrictive since the primary containment vent and purge valves are required to be closed when these operations are not underway.

This is consistent with current practice and in accordance with the UFSAR safety analyses.

This assures that the requirements of the LOCA are met and ensures these valves are opened for a valid reason.

This change is not considered to result in any reduction to safety.

TECHNICAL CHANGES LESS RESTRICTIVE (GENERIC)

LA1 Not Used.

LA2 Not Used.

LA3 Not Used.

LA4 Not Used.

Page 7 of 14 Revision E JAFNPP

DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVS)

TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC)

LA5 Details in CTS 1.0.M.3, definition of Primary Containment Integrity (OPERABILITY),

concerning automatic containment isolation valves (a de activated valve in the isolated position ensures containment integrity) is being relocated to the Bases.

The details for valve OPERABILITY are not necessary to ensure the Primary Containment Isolation Valves are OPERABLE.

The requirements of ITS 3.6.1.3 which require the PCIVs to be OPERABLE and the definition of OPERABILITY suffice.

ITS LCO 3.6.1.3 Bases clearly states that an automatic isolation valve is OPERABLE if de-activated and secured in the closed position.

As such, these details are not required to be in the ITS to provide adequate protection of public health and safety.

Changes to the Bases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the ITS.

LA6 Design details in CTS 3.7.D.1, which provide the containment vent and purge Valve Numbers and Maximum Opening Angle limitations, are to be relocated to the UFSAR.

These design details are not necessary to be included in the Technical Specifications to ensure the OPERABILITY of these Primary Containment Isolation Valves.

The requirements of ITS 3.6.1.3 are adequate to ensure the PCIVs are maintained OPERABLE.

The design details are not required to be in the ITS to provide adequate protection of public health and safety.

Changes to the UFSAR will be controlled by the provisions of 10 CFR 50.59.

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li CTS 4.7.D.1.a and CTS Table 4.2-1 Note 7, for actuation testing of PCIVs, stipulates a simulated automatic actuation test shall be performed.

ITS SR 3.6.1.3.7 allows for use of an actual isolation signal, in addition to the simulated automatic initiation signal, for verifying that each PCIV actuates on an automatic initiation signal.

This allows satisfactory actual automatic system initiations to be used to fulfill the Surveillance Requirements.

Operability is adequately demonstrated in either case since the PCIVs cannot discriminate between Page 8 of 14 Revision E JAFNPP

DISCUSSION OF CHANGES "ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVS)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L1 (continued)

"actual* or "simulated" signals.

This change, to allow the use of actual automatic initiation signals, provides increased latitude for operations to complete the Surveillance Requirement and is therefore considered to be less restrictive.

L2 Not Used.

L3 CTS 3.7.D does not provide specific ACTIONS for those penetrations with two inoperable PCIVs unless the penetration is closed and no operable valves are required (CTS 3.7.D.2).

ITS 3.6.1.3 ACTION B, to isolate the affected penetration flow path within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months when one or more penetration flow paths exist with two PCIVs inoperable, for reasons other than Conditions D and E, is being added.

Currently entry into CTJ 3.7.D.3 is required and the plant must be in cold condition in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The additional 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months allowed to isolate the affected penetration flow path provides a period of time to correct the problem commensurate with the importance of maintaining primary containment OPERABILITY during MODES 1, 2, and 3.

Additionally, the one hour period ensures that the probability of an accident (requiring primary containment OPERABILITY) occurring during periods where primary containment is inoperable is minimized.

This change, to allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to isolate the affected penetration, provides relief for the current operational requirements to commence a plant shutdown, and therefore, is considered to be less restrictive.

L4 CTS 3.7.D does not provide specific ACTIONS for those penetration flow paths with one PCIV.

Currently entry into CTS 3.7.D.3 is required and the plant must be in cold condition in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ITS 3.6.1.3 ACTION C requires the affected penetration flow path to be isolated, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is acceptable since the associated penetrations are part of a closed system which will act as a barrier.

During the allowed time, a limiting event would still be assumed to be within the bounds of the safety analysis.

Allowing this extended time potentially avoiding a plant transient caused by the immediate forced shutdown, is reasonable based on the low probability of an event, and does not represent a significant decrease in safety.

In addition, to ensure the affected penetration are isolated on a periodic basis, Required Action C.2 has been added.

Required Action C.2 will require the verification that each affected penetration flow path is isolated once per 31 days.

The 31 day Frequency is acceptable since the devices are operated under administrative controls and the probability of misalignment is low.

Page 9 of 14 Revision E 3AFNPP

oi'l DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVS)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L5 CTS 3.7.D.2.b Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , to isolate each affected penetration has been extended for certain penetrations (ITS 3.6.1.3 ACTION A).

For penetrations with two PCIVs, proposed Required Action A.1 allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main steam line penetrations and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for other penetrations.

During the allowed time, the limiting event would still be assumed to be within the bounds of the safety analysis since a second valve is available for isolation or in the case of EFCV penetrations. no credit is taken for isolation since the installed orifice will limit the leakage to within limits.

This change is acceptable since the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time for MSIVs allows time to repair or reduce power to isolate the affected penetration.

Allowing this additional time potentially avoids a plant transient caused by a reduction in power to close the MSIVs.

L6 A new method of isolating penetrations is proposed to be added to CTS 3.7.D.2.c when one or more penetration flow paths with one PCIV is inoperable (except for when MSIV or hydrostatically tested valve leakage is not within limits).

ITS 3.6.1.3 Required Action A.1 allows the penetration to be isolated by a check valve with flow through the valve secured.

This is acceptable for penetrations with only one PCIV inoperable because the other PCIV remains Operable, the likelihood of an event occurring in which a containment isolation is required is remote.

the penetration is isolated by a check valve, and the remaining Operable PCIV not being able to also isolate the penetration is remote.

This description has also been added to the Bases to describe a passive PCIV.

L7 CTS 3.7.D.3 (CTS 3.7.A.8) requirement, that the reactor be in the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the requirements of CTS 3.7.D.1 or 3.7.D.2 (3.7.A.1 through 3.7.A.5) with respect to PCIVs cannot be met, is being relaxed.

Allowances have been added to the current requirements to allow additional time to restore inoperable PCIVs, however these changes are addressed in L, 1.3, L4, L9, and L10. Proposed ITS 3.6.1.3 Required Action F.2 allows the plant 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to reach COLD SHUTDOWN (MODE 4) if the Required Action and Completion Time of Condition A, B. C, D, or E cannot be met in MODE 1. 2, or 3.

However. ITS 3.6.1.3 Required Page 10 of 14 Revision E JAFNPP

DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVS)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L7 (continued)

-Action F.1 requires the plant to be in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (M5).

This change is less restrictive because it extends the time for the plant to be in MODE 4 from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36.

The allowed Completion Times in Required Actions F.1 and F.2 are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

The consequences of an accident are not significantly increased because ITS 3.6.1.3, Required Action F.1 will require the plant be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months once the determination is made that the Required Action or Completion Time associated with the PCIVs cannot be satisfied.

This change reduces the time the reactor would be allowed to continue to operate once the condition is identified.

The consequences of a LOCA are significantly mitigated when the reactor is shutdown and a controlled cooldown is already in progress.

This change is consistent with NUREG-1433, Revision 1.

L8 The periodic verification that a penetration is isolated to comply with CTS 4.7.D.2 (proposed LCO 3.6.1.3 Required Actions A.2 and C.2) is proposed to be changed from a daily recording requirement to a monthly verification or a verification Prior to entering MODE 2 or 3 from MODE 4, if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment.

These valves are under administrative controls and are operated in strict accordance with plant procedures.

To verify that these valves are still isolated on a daily basis places an undue burden on plant operations with little if any gain in safety, since these valves are rarely found in the unisolated condition, once closed.

L9 CTS 3.7.0.2 does not provide specific ACTIONS for those penetration flow paths with leakage limits of one or more MSIVs exceeded.

As a result, entry into CTS 3.7.A.8 is required and the plant must be in cold condition in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ITS 3.6.1.3 ACTION D, establishes the Condition for one or more penetration flow paths with one or more MSIVs not within leakage rate limits.

Associated ITS 3.6.1.3 Required Action D.1.

requires restoring leakage rate to within limit, within a Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The Completion Time is consistent with the time provided in Required Action A.1 for other inoperabilities associated with the MSIVs (BS).

The additional 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months allowed to restore leakage within the limit provides a period of time to correct the problem commensurate with the importance of maintaining primary containment Operability during MODES 1. 2, and 3.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable considering the time required to restore the leakage by Page 11 of 14 Revision E JAFNPP

DISCUSSION OF CHANGES "ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L9 (continued)

-isolating the penetration, the fact that MSIV closure will result in isolation of the main steam line(s) and a potential for plant shutdown, and the relative importance of leakage to the overall containment function.

This change is acceptable since the closure of one MSIV in each penetration flow path will ensure the consequences of a design basis accident will be bounded by the USFAR analysis.

LIO A new ACTION has been added to CTS 3.7.A.2 (ITS 3.6.1.3 ACTION E) which will allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore leakage rate to within limit for one or more air operated testable check valves associated with the Low Pressure Coolant Injection and Core Spray Systems injection penetrations.

The additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore leakage within the limit provides a period of time to correct the problem commensurate with the importance of maintaining primary containment Operability in MODES 1, 2 and 3.

The associated penetrations are normally isolated during plant operations by a motor operated PCIV.

In addition, there is an additional motor operated valve (which is hydrostatically leak tested under the IST program) available to isolate the penetration.

Therefore, excessive leakage will be minimized by this closed motor operated PCIV and therefore ALARA concerns in the reactor building will be minimized.

In the event of a pipe rupture outside of containment gross leakage is limited by the air operated testable check valve inside containment,.

however if it is inoperable the motor operated PCIV will also minimize V

the leakage.

The reactor building includes radiation monitors which will provide audible and visual alarms to the control room.

The Keep Full low level alarms and the reactor building floor drain sump high level alarms are available to indicate excessive primary coolant leakage.

Therefore, since isolation methods exists to limit the leakage and since the plant is instrumented with diverse methods to detect leaks within the reactor building this 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowance is acceptable.

This time is consistent with the Completion Times for other penetration flow paths with two PCIVs (one PCIV inoperable for reasons other than leakage) as indicated in ITS 3.6.1.3 Action A.

L11 CTS 4.7.D.2,Surveillance Requirement. to verify (each 31 days) that a penetration flow path with an inoperable PCIV is isolated, is being supplemented.

ITS 3.6.1.3 Required Actions A.2 and C.2 include two Notes. Note 1 allows isolation devices in high radiation areas to be verified by use of administrative means.

This allowance is considered acceptable since access to these areas is typically restricted, and therefore the probability of misalignment once they have been verified to be in the proper position is low and the allowance is also consistent k

Page 12 of 14 Revision E

,1AFN1PP

i I/

DISCUSSION OF CHANGES

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVS)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L11 (continued)

-with Note 1 provided in the new proposed ITS SR 3.6.1.3.2 and SR 3.6.1.3.3 (W4).

Note 2 allows isolation devices that are locked, sealed, or otherwise secured to be verifiecd by administrative means.

This allowance is considered acceptable since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertantly mispositioned.

These changes provide plant operations additional latitude in verifying isolation device position, and therefore, are considered to be less restrictive.

L12 The specific valve numbers of the Low Pressure Coolant Injection and Core Spray System in CST 4.7.A.2.c are proposed to be deleted.

It is unnecessary for the Technical Specifications to prescribe component identification numbers since these details are not necessary to ensure the associated leakage limits are met.

ITS SR 3.6.1.3.11 which requires the verification that the leakage rate of each air operated testable check valve associated with the Low Pressure Coolant Injection and Core Spray System vessel injection penetrations is < 10 gpm at 1035 psig when hydrostatically tested.or 11 scfm when pneumatically tested is sufficient ensure the appropriate testing is performed.

L13 The CTS 4.7.D.2.c requirement to demonstrate the leakage rate of the Low M

Pressure Coolant Injection (LPCI) System and Core Spray System injection penetration air operated testable check valves is within limits once per 24 months is proposed to be relaxed.

ITS SR 3.6.1.3.11 Frequency of leakage rate testing of the valves is proposed to be changed to "In Accordance with the Primary Containment Leakage Rate Testing Program.*

These air operated testable check valves have been subjected to 10 CFR 50, Appendix 3, Type C testing (using the alternate test methods and acceptance criteria stated in CTS 4.7.D.2.c) since approval of CTS Amendment 40 on November 9, 1978.

Under the Primary Containment Leakage Rate Testing Program valves subjected to Type C testing are tested once every 30 months (and the 30 month test interval may be extended to 60 months with satisfactory test performance). The operating experience gained by more than 20 years of testing, as required by CTS 4.7.D.2.c and under the Inservice Test (IST) Program requirements, has demonstrated reliable operation, leak tightness. and structural integrity of the valves. The associated penetrations are normally isolated during plant operations by motor operated PCIVs.

In addition.

there is an additional motor operated valve (which is hydrostatically leak tested under the IST program) available to isolate each Page 13 of 14 Revision E JAFNPP

/

DISCUSSION OF CHANGES

--ITS: 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L13 (continued) penetration.

Excessive leakage in an air operated testable check valve would be detected during testing of the normally closed PCIV as required by the IST Program and significant leakage to the Secondary Containment (reactor building) would result in actuation of radiation monitors which will provide audible and visual alarms to the control room.

Further, reactor building floor drain sump high level alarms are available to indicate excessive reactor coolant leakage.

The small increase in the test interval (6 months, until test results indicate additional relaxation is acceptable), testing over a long time period that has demonstrated reliability, other isolation methods that exist to limit potential leakage, and diverse instrumentation methods to detect potential leaks within the reactor building, make the proposed relaxation of the test Frequency acceptable.

TECHNICAL SPECIFICATIONS RELOCATIONS None Page 14 of 14 JAFNPP Revision E

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