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Draft Safety Evaluation of Technical Specifications Task Force Traveler TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control
	ML16175A394
Person / Time
Site:	Technical Specifications Task Force
Issue date:	10/06/2016
From:	Kevin Hsueh; Licensing Processes Branch (DPR)
To:	; Technical Specifications Task Force
	Honcharik M
Shared Package
ML16250A231	List: ML16175A394; ML16250A206;
References
	TAC MF3487
	Download: ML16175A394 (60)
	v • d • e

{{#Wiki_filter:October 6, 2016 Technical Specifications Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852

SUBJECT:

DRAFT SAFETY EVALUATION OF TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-542, REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" (TAC NO. MF3487)

Dear Members of the Technical Specifications Task Force:

By letter dated March 14, 2016 (Agencywide Documents Access and Management System Accession No. ML16074A448), the Technical Specifications Task Force submitted to the U.S. Nuclear Regulatory Commission (NRC) for review and approval traveler TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control. The NRC staff's draft safety evaluation (SE) of the traveler and a draft model SE are enclosed. Thirty calendar days are provided to you to comment on any factual errors or clarity concerns contained in the draft SE. The final SE will be issued after making any necessary changes. The NRC staff's disposition of your comments on the draft SE will be discussed in the final SE. To facilitate the NRC staff's review of your comments, please provide a marked-up copy of the draft SE showing proposed changes and provide a summary table of the proposed changes. If you have any questions, please contact Michelle Honcharik at 301-415-1774 or via e-mail at Michelle.Honcharik@nrc.gov. Sincerely,

                                             /RA/

Kevin Hsueh, Chief Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 753

Enclosures:

As stated cc: See next page

Package: ML16250A231, Cover letter and draft traveler SE: ML16175A394, draft model SE: ML16250A206; *concurred via e-mail NRR-106 OFFICE DPR/PLPB* DPR/PLPB* DSS/SRXB* DSS/STSB* DE/EICB* DORL/BC* NAME MHoncharik DHarrison EOesterle AKlein MWaters DWrona DATE 6/27/16 6/27/16 9/23/16 9/19/16 9/23/16 9/23/16 OFFICE DRA/ARCB* DSS/SBPB* OGC* DPR/PLPB* DPR/PLPB NAME UShoop RDennig DRoth MHoncharik KHsueh DATE 9/23/16 9/22/16 9/21/16 9/26/16 10/6/16

Technical Specifications Task Force Project No. 753 cc: Technical Specifications Task Force Otto W. Gustafson c/o EXCEL Services Corporation Entergy Nuclear Operations, Inc. 11921 Rockville Pike, Suite 100 Palisades Nuclear Power Plant Rockville, MD 20852 27780 Blue Star Memorial Highway Attention: Brian D. Mann Covert, MI 49043 E-mail: brian.mann@excelservices.com E-mail: ogustaf@entergy.com James R. Morris Michael K. Leisure Diablo Canyon Power Plant Duke Energy Building 104/5/21A 526 S. Church Street P.O. Box 56 Mail Code EC2ZF Avila Beach, CA 93424 Charlotte, NC 28202 E-mail: JY1E@pge.com E-mail: mike.leisure@duke-energy.com Lisa L. Williams Kelli A. Roberts Energy Northwest Southern Nuclear Operating Company Columbia Generating Station 42 Inverness Center Parkway PO Box 968 BIN B237 Mail Drop PE20 Birmingham, AL 35242-4809 Richland, WA 99352-0968 E-mail: kroberts@southernco.com E-mail: llwilliams@energy-northwest.com

1 DRAFT SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2 TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 3 TSTF-542, REVISION 2 4 REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL 5 6

1.0 INTRODUCTION

7 8 By letter dated December 31, 2013 (Agencywide Document Access and Management System 9 (ADAMS) Accession No. ML14002A112), the Technical Specifications (TS) Task Force (TSTF) 10 submitted Change Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control, 11 Revision 0, for U.S. Nuclear Regulatory Commission review and approval. By letter dated 12 September 15, 2015, the TSTF submitted Revision 1 to Change Traveler TSTF-542 (ADAMS 13 Accession No. ML15258A850), and by letter dated March 14, 2016, submitted Revision 2 to 14 Change Traveler TSTF 542 (ADAMS Accession No. ML16074A448). Traveler TSTF-542 15 proposes changes to the Standard Technical Specifications (STS) and Bases for boiling water 16 reactor (BWR) designs BWR/4 and BWR/6.1 The changes would be incorporated into future 17 revisions of NUREG-1433, Volumes 1 and 2 and NUREG-1434, Volumes 1 and 2. 18 19 The proposed changes would replace the existing BWR/4 and BWR/6 Specifications related to 20 operations with a potential for draining the reactor vessel (OPDRVs) with revised 21 Specifications for Reactor Pressure Vessel Water Inventory Control (RPV WIC). 22 23 Throughout this safety evaluation (SE), items that are enclosed in square brackets signify 24 plant-specific nomenclature or values. Individual licensees would furnish site-specific 25 nomenclature or values for bracketed items when submitting a license amendment request 26 (LAR) to adopt the changes described in this SE. 27 1 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric BWR/4 Plants, NUREG-1433, Vol. 1, Specifications, Rev. 4.0, April 2012, ADAMS Accession No. ML12104A192. U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric BWR/4 Plants, NUREG-1433, Vol. 2, Bases, Rev. 4.0, April 2012, ADAMS Accession No. ML12104A193. U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric BWR/6 Plants, NUREG-1434, Vol. 1, Specifications, Rev. 4.0, April 2012, ADAMS Accession No. ML12104A195. U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric BWR/6 Plants, NUREG-1434, Vol. 2, Bases, Rev. 4.0, April 2012, ADAMS Accession No. ML12104A196. Enclosure 1

1

2.0 REGULATORY EVALUATION

2 3 2.1 TECHNICAL SPECIFICATIONS 4 5 Section IV, The Commission Policy, of the Final Policy Statement on Technical Specifications 6 Improvements for Nuclear Power Reactors (58 Federal Register 39132), dated July 22, 1993, 7 states in part: 8 9 10 The purpose of Technical Specifications is to impose those 11 conditions or limitations upon reactor operation necessary to 12 obviate the possibility of an abnormal situation or event giving rise 13 to an immediate threat to the public health and safety by 14 identifying those features that are of controlling importance to 15 safety and establishing on them certain conditions of operation 16 which cannot be changed without prior Commission approval. 17 [T]he Commission will also entertain requests to adopt portions of 18 the improved STS [(e.g., TSTF-542)], even if the licensee does 19 not adopt all STS improvements 20 The Commission encourages all licensees who submit Technical 21 Specification related submittals based on this Policy Statement to 22 emphasize human factors principles 23 In accordance with this Policy Statement, improved STS have 24 been developed and will be maintained for [the BWR/4 and 25 BWR/6 designs]. The Commission encourages licensees to use 26 the STS as the basis for plant-specific Technical Specifications 27 [I]t is the Commission intent that the wording and Bases of the 28 improved STS be used [] to the extent practicable. 29 30 31 2.2 SYSTEM DESCRIPTION 32 33 The BWR reactor pressure vessels have a number of penetrations located below the top of 34 active (TAF). These penetrations provide entry for control blades, recirculation flow, and 35 shutdown cooling. Since these penetrations are below the TAF, this gives potential to drain the 36 reactor vessel water inventory and thus lose effective core cooling. The loss of water inventory 37 and effective core cooling can potentially lead to fuel cladding failure and radioactive release. 38 39 During operation in Modes 1 (Power Operation with reactor mode switch position in run), 2 40 (Startup with reactor mode switch position in refuel or startup/hot standby) and 3 (Hot Standby 41 with reactor mode switch position in shutdown), the TS for instrumentation and emergency core 42 cooling systems (ECCS) require operability of sufficient equipment to ensure large quantities of 43 water can be injected into the vessel should level decrease below the preselected value. These 44 requirements are designed to mitigate the effects of a loss-of-coolant accident (LOCA), but also 45 provide protection for other accidents and transients that involve a water inventory loss. 46

1 During BWR operation in Mode 4 (Cold Shutdown with average reactor coolant temperature 2 200 °F), and Mode 5 (Refueling with one or more reactor vessel head closure bolts less than 3 fully tensioned), the pressures and temperatures that could cause a LOCA are not present. 4 During certain phases of refueling (Mode 5) a large volume of water is available above the RPV 5 (i.e., the RPV head is removed, the water level is [23 feet] over the top of the RPV flange, and 6 the spent fuel storage pool gates are removed for BWR/4 plants, or the upper containment pool 7 is connected to the RPV for BWR/6 plants. 8 9 The large volume of water available in and above the RPV (during much of the time when in 10 Mode 5) provides time for operator detection and manual operator action to stop and mitigate an 11 RPV draining event. However, typically at other times during a refueling outage, during cold 12 shutdown (Mode 4) or refueling (Mode 5), there may be a potential for significant drainage paths 13 from certain outage activities, human error, and other events when it is more likely to have some 14 normally available equipment, instrumentation, and systems inoperable due to maintenance and 15 outage activities. There may not be as much time for operator action as compared to times 16 when there are large volumes of water above the RPV. 17 18 In comparison to Modes 1, 2, and 3, with typical high temperatures and pressures (especially in 19 Modes 1 and 2), Modes 4 and 5 generally do not have the high pressure and temperature 20 considered necessary for a LOCA envisioned from a high energy pipe failure. Thus, while the 21 potential sudden loss of large volumes of water from a LOCA are not expected, operators 22 monitor for BWR RPV water level decrease from potential significant or even unexpected 23 drainage paths. These potential drainage paths in Modes 4 and 5 generally would require less 24 water replacement capability to maintain water above TAF. 25 26 To address the drain down potential during Modes 4 and 5, the current BWR STS contain 27 specifications that are applicable during an OPDRV, or require suspension of OPDRVs if certain 28 equipment is inoperable. The term OPDRV is not specifically defined in the TS and historically 29 has been subject to inconsistent application by licensees. The changes discussed in this SE 30 are intended to resolve any ambiguity by creating a new RPV water inventory control TS with 31 attendant equipment operability requirements, required actions and surveillance requirements 32 (SR) and deleting references to OPDRVs throughout the TS. 33 34 2.3 CHANGES TO THE STS 35 36 The proposed changes would (1) provide a definition of a new term, DRAIN TIME; (2) revise 37 and rename STS 3.5.2 as Reactor Pressure Vessel Water Inventory Control; (3) provide a new 38 TS 3.3.5.2, Reactor Pressure Vessel Water Inventory Control Instrumentation; and (4) delete 39 existing references to operations with the potential to drain the reactor pressure vessel 40 throughout the STS. The descriptions of the proposed changes are provided in this section. 41 42 Corresponding changes are proposed to the STS Bases. A summary of the revised STS Bases 43 and the staffs evaluation of the revised Bases are provided in an attachment of this SE. 44 45 2.3.1 Insertion of New Definition of DRAIN TIME 46 47 The following definition of DRAIN TIME would be added to Section 1.1, Definitions Section of 48 the STS: 49

1 2 The DRAIN TIME is the time it would take for the water inventory 3 in and above the Reactor Pressure Vessel (RPV) to drain to the 4 top of the active fuel (TAF) seated in the RPV assuming: 5 6 a) The water inventory above the TAF is divided by the limiting 7 drain rate; 8 9 b) The limiting drain rate is the larger of the drain rate through a 10 single penetration flow path with the highest flow rate, or the 11 sum of the drain rates through multiple penetration flow paths 12 susceptible to a common mode failure (e.g., seismic event, 13 loss of normal power, single human error), for all penetration 14 flow paths below the TAF except: 15 16 1. Penetration flow paths connected to an intact closed 17 system, or isolated by manual or automatic valves are 18 locked, sealed, or otherwise secured in the closed position, 19 blank flanges, or other devices that prevent flow or reactor 20 coolant through the penetration flow paths; 21 22 2. Penetration flow paths capable of being isolated by valves 23 that will close automatically without offsite power prior to 24 the RPV water level being equal to the TAF when actuated 25 by RPV water level isolation instrumentation; or 26 27 3. Penetration flow paths with isolation devices that can be 28 closed prior to the RPV water level being equal to the TAF 29 by a dedicated operator trained in the task, who is in 30 continuous communication with the control room, is 31 stationed at the controls, and is capable of closing the 32 penetration flow path isolation device without offsite power. 33 34 c) The penetration flow paths required to be evaluated per 35 paragraph b) are assumed to open instantaneously and are 36 not subsequently isolated, and no water is assumed to be 37 subsequently added to the RPV water inventory; 38 39 d) No additional draining events occur; and 40 41 e) Realistic cross-sectional areas and drain rates are used. 42 43 A bounding DRAIN TIME may be used in lieu of a calculated 44 value. 45 46 47 2.3.2 Changes to STS Section 3.5: 48 49 2.3.2.1 Title of TS 3.5

1 2 The title of Section 3.5 is being revised from Emergency Core Cooling System (ECCS) and 3 Reactor Core Isolation Cooling System (RCIC) to Emergency Core Cooling Systems (ECCS), 4 RPV Water Inventory Control, and Reactor Core Isolation Cooling (RCIC) System. 5 6 2.3.2.2 Title of TS 3.5.2 7 8 The title of TS 3.5.2 is being revised from ECCS - Shutdown to Reactor Pressure Vessel 9 (RPV) Water Inventory Control. 10 11 2.3.2.3 LCO 3.5.2 12 13 STS limiting condition for operation (LCO) 3.5.2 currently states Two low pressure ECCS 14 injection/spray subsystems shall be OPERABLE. The LCO note currently states: One LPCI 15 subsystem may be considered OPERABLE during alignment and operation for decay heat 16 removal if capable of being manually realigned and not otherwise inoperable. 17 18 STS LCO 3.5.2 for NUREG-1433 (BWR/4 STS) would be revised to state: 19 20 21 DRAIN TIME of RPV water inventory to the top of active fuel 22 (TAF) shall be 36 hours. 23 24 AND 25 26 One low pressure ECCS injection/spray subsystem shall be 27 OPERABLE. 28 29 30 The note for LCO 3.5.2 would be revised to state: 31 32 33 A Low Pressure Coolant Injection (LPCI) subsystem may be 34 considered OPERABLE during alignment and operation for decay 35 heat removal if capable of being manually realigned and not 36 otherwise inoperable. 37 38 39 For NUREG-1434 (BWR/6) STS, the phrase low pressure is omitted because the BWR/6 high 40 pressure core spray system may be used to satisfy this requirement. 41 42 2.3.2.4 Applicability of TS LCO 3.5.2 43 44 For NUREG-1433 (BWR/4), LCO 3.5.2 is currently applicable in MODE 4 and in MODE 5, 45 except with the spent fuel storage pool gates removed and water level [23 ft] over the top of 46 the reactor pressure vessel flange. 47

1 For NUREG-1434 (BWR/6), LCO 3.5.2 is currently applicable in Mode 4 and Mode 5 except 2 with the upper containment [cavity to dryer] pool [gate] removed and water level [22 ft 3 8 inches] over the top of the reactor pressure vessel flange. 4 5 The applicability would be revised to be MODES 4 and 5, with no exceptions. 6 7 2.3.2.5 Actions Table of TS 3.5.2 8 9 The existing Actions Table of TS 3.5.2 for NUREG-1433 (BWR/4) states: 10 CONDITION REQUIRED ACTION COMPLETION TIME A. One required ECCS A.1 Restore required ECCS 4 hours injection/spray injection/spray subsystem to subsystem inoperable. OPERABLE status. B. Required Action and B.1 Initiate action to suspend Immediately associated Completion operations with a potential for Time of Condition A not draining the reactor vessel met (OPDRVs). C. Two required ECCS C.1 Initiate action to suspend Immediately injection/spray OPDRVs subsystems inoperable. AND C.2 Restore one ECCS injection/spray 4 hours subsystem to OPERABLE status D. Required Action C.2 and D.1 Initiate action to restore Immediately associated Completion [secondary] containment to Time not met OPERABLE status. AND D.2 [Initiate action to restore one Immediately] standby gas treatment subsystem to OPERABLE status. AND D.3 Initiate action to restore isolation Immediately capability in each required [secondary] containment penetration flow path not isolated. 11 12 The revised TS 3.5.2 Actions Table for NUREG-1433 (BWR/4) would state: 13 CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours injection/spray subsystem injection/spray subsystem to inoperable. OPERABLE status.

B. Required Action and B.1 Initiate action to establish a Immediately associated Completion method of water injection capable Time of Condition A not of operating without offsite met. electrical power. C. DRAIN TIME < 36 hours C.1 Verify [secondary] containment 4 hours and 8 hours. boundary is capable of being established in less than the DRAIN TIME. AND C.2 Verify each [secondary] 4 hours containment penetration flow path is capable of being isolated in less than the DRAIN TIME. AND C.3 Verify one standby gas treatment 4 hours subsystem is capable of being placed in operation in less than the DRAIN TIME. D. DRAIN TIME < 8 hours. D.1 --------------NOTE------------ Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

                              ----------------------------------

Initiate action to establish an Immediately additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours. AND D.2 Initiate action to establish Immediately [secondary] containment boundary AND D.3 Initiate action to isolate each Immediately [secondary] containment penetration flow path or verify it can be manually isolated from the control room.

AND D.4 Initiate action to verify one Immediately standby gas treatment subsystem is capable of being placed in operation. E. Required Action and E.1 Initiate action to restore DRAIN Immediately associated Completion TIME to 36 hours Time of Condition C or D not met. OR DRAIN TIME < 1 hour 1 2 The existing Actions Table of TS 3.5.2 for NUREG-1434 (BWR/6) states: 3 CONDITION REQUIRED ACTION COMPLETION TIME A. One required ECCS A.1 Restore required ECCS 4 hours injection/spray subsystem injection/spray subsystem to inoperable. OPERABLE status. B. Required Action and B.1 Initiate action to suspend Immediately associated Completion operations with a potential for Time of Condition A not met draining the reactor vessel (OPDRVs). C. Two required ECCS C.1 Initiate action to suspend Immediately injection/spray subsystems OPDRVs inoperable. AND C.2 Restore one ECCS 4 hours injection/spray subsystem to OPERABLE status D. Required Action C.2 and D.1 Initiate action to restore Immediately associated Completion [secondary containment] to Time not met OPERABLE status. AND D.2 [Initiate action to restore one Immediately] standby gas treatment subsystem to OPERABLE status. AND Immediately

D.3 Initiate action to restore isolation capability in each required [secondary containment] penetration flow path not isolated. 1 2 The revised TS 3.5.2 ACTIONS Table for NUREG-1434 (BWR/6) would state: 3 CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours injection/spray subsystem injection/spray subsystem to inoperable. OPERABLE status. B. Required Action and B.1 Initiate action to establish a Immediately associated Completion method of water injection Time of Condition A not capable of operating without met. offsite electrical power.. C. DRAIN TIME < 36 hours C.1 Verify [secondary containment] 4 hours and 8 hours. boundary is capable of being established in less than the DRAIN TIME. AND C.2 Verify each [secondary 4 hours containment] penetration flow path is capable of being isolated in less than the DRAIN TIME. AND C.3 [Verify one standby gas 4 hours] treatment subsystem is capable of being placed in operation in less than the DRAIN TIME. D. DRAIN TIME < 8 hours. D.1 --------------NOTE------------ Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

                                   --------------------------------------

Initiate action to establish an Immediately additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours.

AND D.2 Initiate action to establish Immediately [secondary containment] boundary AND D.3 Initiate action to isolate each Immediately [secondary containment] penetration flow path or verify it can be manually isolated from the control room. AND D.4 [Initiate action to verify one Immediately] standby gas treatment subsystem is capable of being placed in operation. E. Required Action and E.1 Initiate action to restore DRAIN Immediately associated Completion TIME to 36 hours. Time of Condition C or D not met. OR DRAIN TIME < 1 hour 1 2 2.3.2.6 TS 3.5.2 Surveillance Requirements 3 4 The NUREG-1433 (BWR/4) TS 3.5.2 currently contains the following SRs: 5 SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required low pressure coolant [12 hours injection (LPCI) subsystem, the suppression pool water level is [12 ft 2 inches]. OR In accordance with the Surveillance Frequency Control Program] SR 3.5.2.2 Verify, for each required core spray (CS) [12 hours subsystem, the: OR

a. Suppression pool water level is

[12 ft 2 inches] or In accordance with the Surveillance Frequency Control Program]

b. ------------------------------NOTE--------------------------

                    -----------Only one required CS subsystem may take credit for this option during OPDRVs.

Condensate storage tank water level is [12 ft]. SR 3.5.2.3 Verify, for each required ECCS injection/spray [31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve. OR In accordance with the Surveillance Frequency Control Program] SR 3.5.2.4 Verify each required ECCS injection/spray [31 days subsystem manual, power operated, and automatic valve in the flow path, that is not locked sealed, or OR otherwise secured in position, is in the correct position. In accordance with the Surveillance Frequency Control Program] 1 2 The revised SRs for NUREG-1433 (BWR/4) would be: 3 SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours. [12 hours OR In accordance with the Surveillance Frequency Control Program] SR 3.5.2.2 Verify, for a required low pressure ECCS [12 hours injection/spray subsystem, the suppression pool water level is [12 ft 2 inches]. OR In accordance with the Surveillance Frequency Control Program] SR 3.5.2.3 Verify, for a required Core Spray (CS) System, the: [12 hours

a. Suppression pool water level is OR

[12 ft 2 inches] or In accordance with the

b. Condensate storage tank water level is Surveillance Frequency

[12 ft]. Control Program] SR 3.5.2.4 Verify, for the required ECCS injection/spray [31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve. OR

In accordance with the Surveillance Frequency Control Program] SR 3.5.2.5 Verify, for the required ECCS injection/spray [31 days subsystem each manual, power operated, and automatic valve in the flow path, that is not locked OR sealed, or otherwise secured in position, is in the correct position. In accordance with the Surveillance Frequency Control Program] SR 3.5.2.6 Operate the required ECCS injection/spray [92 days subsystem through the recirculation line for 10 minutes. OR In accordance with the Surveillance Frequency Control Program] SR 3.5.2.7 Verify each valve credited for automatically isolating [[18] months a penetration flow path actuates to the isolation position on an actual or simulated isolation signal. OR In accordance with the Surveillance Frequency Control Program] SR 3.5.2.8 --------------------------------------NOTE----------------------- [[18] months Vessel injection/spray may be excluded.

               --------------------------------------------------------------------- OR Verify the required ECCS injection/spray subsystem actuates on a manual initiation signal.                               In accordance with the Surveillance Frequency Control Program ]

1 2 The corresponding NUREG-1434 (BWR/6) TS 3.5.2 currently contains the following SRs: 3 SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required low pressure ECCS [12 hours injection/spray subsystem, the suppression pool water level is [12.67 ft]. OR In accordance with the Surveillance Frequency Control Program] SR 3.5.2.2 Verify, for the required High Pressure Core Spray [12 hours (HPCS) subsystem, the: OR

a. Suppression pool water level is [12.67 ft] or

b. Condensate storage tank water level is [18 ft] In accordance with the Surveillance Frequency Control Program]

SR 3.5.2.3 Verify, for the required ECCS injection/spray [31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve. OR In accordance with the Surveillance Frequency Control Program] SR 3.5.2.4 Verify each required ECCS injection/spray subsystem [31 days manual, power operated, and automatic valve in the flow path, that is not locked sealed, or otherwise OR secured in position, is in the correct position. In accordance with the Surveillance Frequency Control Program] SR 3.5.2.5 Verify each required ECCS pump develops the [In accordance with specified flow rate [against a system head the Inservice Testing corresponding to the specified reactor pressure] Program [System Head OR Corresponding to A Reactor [92 days] System Flow Rate Pressure of] LPCS [7115]gpm [290]psig OR LPCI [7450]gpm [125]psig HPCS [7115]gpm [445]psig In accordance with the Surveillance Frequency Control Program] SR 3.5.2.6 ------------------------------------NOTE--------------------------- [18 months Vessel injection/spray may be excluded.

                ----------------------------------------------------------------------- OR Verify each required ECCS injection /spray                              In accordance with the subsystem actuates on an actual or simulated                            Surveillance automatic initiation signal.                                            Frequency Control Program]

1 2 The revised SRs for NUREG-1434 (BWR/6) would be: 3 SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours. [12 hours

OR In accordance with the Surveillance Frequency Control Program] SR 3.5.2.2 Verify, for a required low pressure ECCS [12 hours injection/spray subsystem, the suppression pool water level is [12.67 ft]. OR In accordance with the Surveillance Frequency Control Program] SR 3.5.2.3 Verify, for a required High Pressure Core Spray [12 hours (HPCS) System, the: OR

c. Suppression pool water level is [12.67 ft] or In accordance with the

d. Condensate storage tank water level is Surveillance

[18 ft]. Frequency Control Program] SR 3.5.2.4 Verify, for the required ECCS injection/spray [31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve. OR In accordance with the Surveillance Frequency Control Program] SR 3.5.2.5 Verify, for the required ECCS injection/spray [31 days subsystem each manual, power operated, and automatic valve in the flow path, that is not locked OR sealed, or otherwise secured in position, is in the correct position. In accordance with the Surveillance Frequency Control Program] SR 3.5.2.6 Operate the required ECCS injection/spray [92 days subsystem through the recirculation line for 10 minutes. OR In accordance with the Surveillance Frequency Control Program]

SR 3.5.2.7 Verify each valve credited for automatically isolating a [[18] months penetration flow path actuates to the isolation position on an actual or simulated isolation signal. OR In accordance with the Surveillance Frequency Control Program] SR 3.5.2.8 --------------------------------------NOTE------------------------- [[18] months Vessel injection/spray may be excluded.

                    ----------------------------------------------------------------------- OR Verify the required ECCS injection/spray subsystem actuates on a manual initiation signal.                                 In accordance with the Surveillance Frequency Control Program]

1 2 2.3.3 Changes to STS Section 3.3 3 4 Both NUREG-1433 (BWR/4) and NUREG-1434 (BWR/6) STS contain two versions of certain 5 specifications in Section 3.3, Instrumentation. One is applicable for licensees that have not 6 adopted a Setpoint Control Program (the A version) and the other is applicable for licensees 7 that have adopted a Setpoint Control Program (the B version). In the A version of the STS, 8 the Allowable Value column is retained in the Instrumentation Table, and the Instrumentation 9 Table contains footnotes that provide details regarding SRs. In the B version of the STS, the 10 Allowable Value has been relocated to the Setpoint Control Program, and this column does not 11 appear in the Instrumentation Table. Additionally, in the B version, the footnotes that provide 12 details regarding SRs are not necessary. This convention is retained in the revised STS LCOs 13 discussed in this section. 14 15 For simplicity, the description of changes in this section is presented with the A and B versions 16 combined. 17 18 2.3.3.1 Changes to STS LCOs 3.3.5.1A and 3.3.5.1B, Emergency Core Cooling System 19 (ECCS) Instrumentation (Without and With Setpoint Control Program), 20 respectively 21 22 The STS LCOs 3.3.5.1A and 3.3.5.1B state that "the ECCS instrumentation for each Function in 23 Table 3.3.5.1-1, [Emergency Core Cooling System Instrumentation,] shall be OPERABLE with 24 the applicability as stated in the table. Table 3.3.5.1-1 currently contains requirements for 25 function operability during Modes 4 and 5 when associated ECCS subsystem(s) are required to 26 be operable per LCO 3.5.2, ECCS - Shutdown. Throughout this table, the applicability in 27 Modes 4 and 5 is being deleted because the instrumentation requirements during shutdown are 28 being consolidated into the new STS 3.3.5.2. Conforming changes are made to the ACTIONS 29 Table of STS LCO 3.3.5.1A and 3.3.5.1B. 30 31 2.3.3.2 Insertion of new STS 3.3.5.2A and 3.3.5.2B, Reactor Pressure Vessel (RPV) 32 Water Inventory Control Instrumentation (Without and With Setpoint Control 33 Program), respectively

1 2 A new STS 3.3.5.2 is proposed to provide alternative instrumentation requirements to support 3 manual initiation of the ECCS injection/spray subsystem required in new STS 3.5.2 and 4 automatic isolation of penetration flow paths that may be credited in the determination of drain 5 time. The current TS contain instrumentation requirements related to OPDRVs in four TS. 6 These requirements are being consolidated into new STS 3.3.5.2. 7 8 The existing STS 3.3.5.2, Reactor Core Isolation Cooling (RCIC) System Instrumentation, is 9 being renumbered to 3.3.5.3 in order to maintain the STS numbering conventions in the 10 NUREGs. 11 12 2.3.3.2.1 New TS 3.3.5.2A and B LCO and Applicability 13 14 The proposed LCO 3.3.5.2 states: 15 16 17 The RPV Water Inventory Control instrumentation for each 18 Function in Table 3.3.5.2-1 shall be OPERABLE. 19 20 21 The applicability states, "According to Table 3.3.5.2-1." 22 23 The following sections describe the instrumentation functions contained in the new 24 Table 3.3.5.2-1. 25 26 2.3.3.2.2 BWR/4 New Table 3.3.5.2-1, RPV Water Inventory Control Instrumentation 27 28 2.3.3.2.2.1 Function 1.a, Core Spray System, Reactor Steam Dome Pressure - Low 29 (Injection Permissive), and 30 Function 2.a, Low Pressure Coolant Injection (LPCI) System, Reactor Steam 31 Dome Pressure - Low (Injection Permissive) 32 33 These functions were moved from current STS 3.3.5.1, Function 1.c and Function 2.c. The 34 following changes are made: 35 36

The applicability is changed. The existing STS 3.3.5.1 applicability for these functions in 37 Modes 4 and 5 is modified by a note that limits the applicability to when the associated 38 ECCS subsystem(s) are required to be operable per LCO 3.5.2, "ECCS - Shutdown. The 39 revised applicability is Modes 4 and 5 without exception, to be consistent with the 40 applicability of new LCO 3.5.2, "RPV Water Inventory Control."

41 42

The number of required channels per function is unchanged.

43 44

In the new table, a Channel Check and Channel Functional Test are required at the existing 45 frequency. Calibration of the trip units, Channel Calibration, Logic System Functional Test, 46 and ECCS Response Time tests are no longer required in Modes 4 and 5.

47

1

In new LCO 3.3.5.2A, the Allowable Value is revised to eliminate the low pressure limit and 2 to retain the high pressure limit. The RPV is well below the lower limit in Modes 4 and 5, so 3 the low pressure limit is not needed.

4 5 2.3.3.2.2.2 Function 1.b, Core Spray Pump Discharge Flow - Low (Bypass) and 6 Function 2.b, Low Pressure Coolant Injection Pump Discharge Flow - Low 7 (Bypass) 8 9 These functions were moved from current STS 3.3.5.1, Function 1.d and Function 2.g, 10 respectively. The following changes are made: 11 12

The applicability is changed. The current STS 3.3.5.1 applicability for these functions in 13 Modes 4 and 5 is modified by a note that limits the applicability to when the associated 14 ECCS subsystem(s) are required to be operable per current LCO 3.5.2, "ECCS -

15 Shutdown. The revised applicability is Modes 4 and 5 without exception, to be consistent 16 with the applicability of new LCO 3.5.2, "RPV Water Inventory Control." 17 18

For Function 1.b, the number of required channels per function is changed from [2] or [1 per 19 pump], to [1 per pump]. For Function 2.b, the number of required channels per function is 20 changed from [4] or [1 per pump], to [1 per pump]. Both are modified by a note stating 21 "Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, 'Reactor 22 Pressure Vessel Water Inventory Control.'

23 24

In the new table, a Channel Check and Channel Functional Test are required at the existing 25 frequency. A Channel Calibration and Logic System Functional Test are no longer required 26 in Modes 4 and 5.

27 28

In new LCO 3.3.5.2A, the allowable value is unchanged.

29 30 2.3.3.2.2.3 Function 1.c, Core Spray System, Manual Initiation, and 31 Function 2.c, Low Pressure Coolant Injection (LPCI) System, Manual Initiation 32 33 These functions were moved from current STS 3.3.5.1, Function 1.e and Function 2.h. The 34 following changes are made: 35 36

The applicability is changed. The current STS 3.3.5.1 applicability for these functions in 37 Modes 4 and 5 is modified by a note that limits the applicability to when the associated 38 ECCS subsystem(s) are required to be operable per current LCO 3.5.2, "ECCS -

39 Shutdown. The revised applicability is Modes 4 and 5 without exception, to be consistent 40 with the applicability of new LCO 3.5.2, "RPV Water Inventory Control. 41 42

The number of required channels per function is changed from [2] or [1 per subsystem], to 43 [1 per subsystem] and is modified by a note stating "Associated with an ECCS subsystem 44 required to be OPERABLE by LCO 3.5.2, 'Reactor Pressure Vessel Water Inventory 45 Control.' New LCO 3.5.2 only requires a single ECCS subsystem and the change in 46 required channels reflects that requirement.

47

1

Both the existing STS 3.3.5.1 and the revised STS 3.3.5.2 require a Logic System 2 Functional Test on this function at the same frequency.

3 4

There is no allowable value for this function.

5 6 2.3.3.2.2.4 Function 3.a, RHR System Isolation, Reactor Vessel Water Level - Low, Level 3 7 8 This function was moved from current STS 3.3.6.1, Function 6.b. The following changes are 9 made: 10 11

The function name is changed from "Shutdown Cooling System Isolation Reactor Vessel 12 Water Level - Low, Level 3" to "Residual Heat Removal [RHR] System Isolation Reactor 13 Vessel Water Level - Low, Level 3. The current title is a misnomer in the STSs as the 14 Level 3 instruments isolate more than shutdown cooling isolation valves.

15 16

The applicability is changed. The existing STS 3.3.6.1 applicability for this function in 17 Modes 4 and 5 is being deleted. The revised applicability is "when automatic isolation of the 18 associated penetration flow path is credited in calculating Drain Time."

19 20

The number of required channels is changed from [2], with a column header that states 21 "Required Channels per Trip System," to [2 in one trip system]. This retains the requirement 22 that the two channels must be associated with the same trip system.

23 24

In the new table, a Channel Check and Channel Functional Test are required at the existing 25 frequency. A calibration of the trip unit, Channel Calibration, and Logic System Functional 26 Test are no longer required in Modes 4 and 5.

27 28

The allowable value is unchanged.

29 30 2.3.3.2.2.5 Function 4.a, Reactor Water Cleanup (RWCU) System Isolation, Reactor Vessel 31 Water Level - Low Low, Level 2 32 33 This function exists in the current STS 3.3.6.1 as Function 5.e. The function is inserted into 34 new STS 3.3.5.2 as follows: 35 36

The applicability of the current STS 3.3.6.1 for this function is Modes 1, 2, and 3. The 37 applicability in STS 3.3.5.2 is "when automatic isolation of the associated penetration flow 38 path is credited in calculating Drain Time. In other words, if the drain time calculation 39 assumes the RWCU system will be automatically isolated, this function must be operable to 40 perform that function. This is consistent with the definition of drain time and the TS 3.5.2 41 requirements.

42 43

The number of required channels is changed from [2], with a column header that states 44 "Required Channels per Trip System," to [2 in one trip system]. This retains the requirement 45 that the two channels must be associated with the same trip system. Only one trip system is 46 required to ensure that automatic isolation of one of the two isolation valves will occur on 47 low reactor vessel water level.

48

1

A Channel Check and Channel Functional Test are required at the existing frequency. A 2 calibration of the trip unit, Channel Calibration, Logic System Functional Test, and Isolation 3 System Response Time tests are no longer required in Modes 4 and 5.

4 5

The allowable value is unchanged.

6 7 2.2.3.2.3 BWR/6 New Table 3.3.5.2-1, RPV Water Inventory Control Instrumentation 8 9 2.3.3.2.3.1 Function 1.a, Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core 10 Spray (LPCS) Subsystems, Reactor Steam Dome Pressure - Low (Injection 11 Permissive) and 12 Function 2.a, LPCI B and LPCI C Subsystems, Reactor Steam Dome Pressure - 13 Low (Injection Permissive) 14 15 These functions were moved from current STS 3.3.5.1, Function 1.d and Function 2.d. The 16 following changes are made: 17 18

The applicability is changed. The current STS 3.3.5.1 applicability for these functions in 19 Modes 4 and 5 is modified by a note that limits the applicability to when the associated 20 ECCS subsystem(s) are required to be operable per current LCO 3.5.2, "ECCS -

21 Shutdown. The revised applicability is Modes 4 and 5 without exception, to be consistent 22 with the applicability of new LCO 3.5.2, "RPV Water Inventory Control. Note that the 23 BWR/6 STS does not include the Mode 4 and 5 applicability of this function. This apparently 24 was an oversight in development of the NUREG. 25 26

In the new table, the number of required channels per function remains [3] and is modified 27 by a note stating "Associated with an ECCS subsystem required to be OPERABLE by 28 LCO 3.5.2, 'Reactor Pressure Vessel Water Inventory Control.' New STS 3.5.2 only 29 requires a single ECCS subsystem to be operable and the change reflects that requirement.

30 31

A Channel Check and Channel Functional Test are required at the existing frequency.

32 Calibration of the trip units, Channel Calibration, Logic System Functional Test, and ECCS 33 Response Time tests are no longer required in Modes 4 and 5. 34 35

In new LCO 3.3.5.2A, the allowable value is revised to eliminate the low pressure limit and 36 to retain the high pressure limit.

37 38 2.3.3.2.3.2 Functions 1.b and 1.c, Low Pressure Coolant Injection-A (LPCI) and Low 39 Pressure Core Spray (LPCS) Subsystems, LPCS Pump Discharge Flow - Low 40 (Bypass) and LPCI Pump A Discharge Flow - Low (Bypass), and 41 Function 2.b, LPCI B and LPCI C Subsystems, LPCI Pump B and LPCI Pump C 42 Discharge Flow - Low (Bypass) 43 44 These functions were moved from current STS 3.3.5.1, Function 1.e, 1.f, and 2.e. The following 45 changes are made: 46 47

The applicability is changed. The current STS 3.3.5.1 applicability for these functions is 48 Modes 4 and 5 when the associated ECCS subsystem(s) are required to be operable per

1 LCO 3.5.2, "ECCS - Shutdown. The revised Applicability is Modes 4 and 5 without 2 exception, to be consistent with the Applicability of new LCO 3.5.2, "RPV Water Inventory 3 Control." 4 5

The number of required channels per function is changed from [1] to [1 per pump] and is 6 modified by a note stating "Associated with an ECCS subsystem required to be OPERABLE 7 by LCO 3.5.2, 'Reactor Pressure Vessel Water Inventory Control'. New STS 3.5.2 only 8 requires a single ECCS subsystem and the change in required channels reflects that 9 requirement.

10 11

A Channel Check and Channel Functional Test are required at the existing frequency.

12 Calibrating the trip unit, Channel Calibration and Logic System Functional Test are no longer 13 required in Modes 4 and 5. 14 15

In new LCO 3.3.5.2A, the allowable value is unchanged.

16 17 2.3.3.2.3.3 Function 1.d, Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core 18 Spray (LPCS) Subsystems, Manual Initiation, and Function 2.c, LPCI B and LPCI 19 C Subsystems, Manual Initiation 20 21 These functions were moved from current STS 3.3.5.1, Function 1.g and Function 2.f. The 22 following changes are made: 23 24

The applicability is changed. The current STS 3.3.5.1 Applicability for these Functions in 25 Modes 4 and 5 is modified by a note that limits the applicability to when the associated 26 ECCS subsystem(s) are required to be operable per current LCO 3.5.2, "ECCS -

27 Shutdown. The revised applicability is Modes 4 and 5 without exception, to be consistent 28 with the applicability of new LCO 3.5.2, "RPV Water Inventory Control." 29 30

The number of required channels per function is changed from [1] to [1 per subsystem] and 31 is modified by a note stating "Associated with an ECCS subsystem required to be 32 OPERABLE by LCO 3.5.2, 'Reactor Pressure Vessel Water Inventory Control'. New 33 STS 3.5.2 only requires a single ECCS subsystem and the change in required channels 34 reflects that requirement.

35 36

Both the existing STS 3.3.5.1 and the revised STS 3.3.5.2 require a Logic System 37 Functional Test on this function at the same frequency.

38 39

There is no allowable value for this function.

40 41 2.3.3.2.3.4 Function 3.a, High Pressure Core Spray (HPCS) System, Reactor Vessel Water 42 Level - High, Level 8 43 44 This function was moved from current STS 3.3.5.1, Function 3.c. The following changes are 45 made: 46 47

The applicability is changed. The current STS 3.3.5.1 applicability for this function is 48 Modes 4 and 5 when the associated ECCS subsystem(s) are required to be operable per

1 existing LCO 3.5.2, "ECCS - Shutdown. The revised applicability is Modes 4 and 5 without 2 exception, to be consistent with the applicability of new LCO 3.5.2, "RPV Water Inventory 3 Control." 4 5

The number of required channels per function is changed from [2] to [1] and is modified by a 6 note stating "Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, 7 'Reactor Pressure Vessel Water Inventory Control'. New STS 3.5.2 only requires a single 8 ECCS subsystem and the change in required channels reflects that requirement.

9 10

A Channel Check and Channel Functional Test are required at the existing frequency.

11 Calibration of the trip units, Channel Calibration, and Logic System Functional Test tests are 12 no longer required in Modes 4 and 5. 13 14

The allowable value in new LCO 3.3.5.2A is unchanged.

15 16 2.3.3.2.3.5 Function 3.b, High Pressure Core Spray (HPCS) System, Condensate Storage 17 Tank Level - Low 18 19 This function was moved from current STS 3.3.5.1, Function 3.d. The following changes are 20 made: 21 22

The applicability is changed. The current STS 3.3.5.1 applicability for this function is 23 Modes 4 and 5 when the associated ECCS subsystem(s) are required to be operable per 24 current LCO 3.5.2, "ECCS - Shutdown. The revised applicability is Modes 4 and 5 when 25 HPCS is operable for compliance with new LCO 3.5.2 and aligned to the Condensate 26 Storage Tank. If HPCS is not being credited for meeting the new LCO 3.5.2 requirement for 27 an operable ECCS subsystem, or if HPCS is being credited but is aligned to the suppression 28 pool, this function is unneeded.

29 30

The number of required channels per function is changed from [2] to [1]. New STS 3.5.2 31 only requires a single ECCS subsystem to be operable, and the change in required 32 channels reflects that requirement.

33 34

A Channel Check and Channel Functional Test are required at the existing frequency.

35 Calibration of the trip units, Channel Calibration, and Logic System Functional Test are no 36 longer required in Modes 4 and 5. 37 38

The allowable value in new LCO 3.3.5.2A is unchanged.

39 40 2.3.3.2.3.6 Functions 3.c and 3.d, High Pressure Core Spray (HPCS) System, HPCS Pump 41 Discharge Pressure - High (Bypass) and HPCS System Flow Rate - Low 42 (Bypass) 43 44 These functions were moved from current STS 3.3.5.1, Function 3.f and 3.g. The following 45 changes are made: 46 47

The applicability is changed. The current STS 3.3.5.1 applicability for this function is 48 Modes 4 and 5 when the associated ECCS subsystem(s) are required to be operable per

1 current LCO 3.5.2, "ECCS - Shutdown. The revised applicability is Modes 4 and 5 without 2 exception, to be consistent with the applicability of new LCO 3.5.2, "RPV Water Inventory 3 Control." 4 5

The number of required channels per function is changed from [1] to [1 per pump] and is 6 modified by a note stating "Associated with an ECCS subsystem required to be OPERABLE 7 by LCO 3.5.2, 'Reactor Pressure Vessel Water Inventory Control'. New STS 3.5.2 only 8 requires a single ECCS subsystem and the change in required channels reflects that 9 requirement.

10 11

A Channel Check and Channel Functional Test are required at the existing frequency.

12 Calibration of the trip units, Channel Calibration, and Logic System Functional Test are no 13 longer required in Modes 4 and 5. 14 15

The allowable value is unchanged.

16 17 2.3.3.2.3.7 Function 3.e, High Pressure Core Spray (HPCS) System, Manual Initiation 18 19 This function is moved from current STS 3.3.5.1, Function 3.h. The following changes are 20 made: 21 22

The applicability is changed. The current STS 3.3.5.1 applicability for these functions in 23 Modes 4 and 5 is modified by a note that limits the applicability to when the associated 24 ECCS subsystem(s) are required to be operable per existing LCO 3.5.2, "ECCS -

25 Shutdown. The revised applicability is Modes 4 and 5 without exception, to be consistent 26 with the applicability of new LCO 3.5.2, "RPV Water Inventory Control." 27 28

The number of required channels per function is changed from [1] to [1 per subsystem] and 29 is modified by a note stating "Associated with an ECCS subsystem required to be 30 OPERABLE by LCO 3.5.2, 'Reactor Pressure Vessel Water Inventory Control'. New 31 STS 3.5.2 only requires a single ECCS subsystem and the change in required channels 32 reflects that requirement.

33

Both the existing STS 3.3.5.1 and the revised STS 3.3.5.2 require a Logic System 34 Functional Test on this function at the same frequency.

35 36

There is no allowable value for this function.

37 38 2.3.3.2.3.8 Function 4.a, RHR System Isolation Reactor Vessel Water Level - Low, Level 3 39 40 This function was moved from current STS 3.3.6.1, Function 5.c. The following changes are 41 made: 42 43

The function name is changed from "Shutdown Cooling System Isolation Reactor Vessel 44 Water Level - Low, Level 3" to "Residual Heat Removal System Isolation Reactor Vessel 45 Water Level - Low, Level 3. This is a misnomer in the STSs as the Level 3 instruments 46 isolate more than shutdown cooling isolation valves.

47

1

The applicability is changed. The current STS 3.3.6.1 applicability for this function is 2 Modes 4 and 5. The revised applicability is "when automatic isolation of the associated 3 penetration flow path is credited in calculating drain time.

4 5

The number of required channels is changed from [2], with a column header that states 6 "Required Channels per Trip System," to [2 in one trip system]. This retains the requirement 7 that the two channels must be associated with the same trip system. Only one trip system is 8 required to ensure automatic isolation of one of the two isolation valves will occur on low 9 reactor vessel water level.

10 11

A Channel Check and Channel Functional Test are required at the existing frequency. A 12 calibration of the trip unit, Channel Calibration, Logic System Functional Test, and Isolation 13 System Response Time tests are no longer required in Modes 4 and 5.

14 15

The existing allowable value is retained in new STS 3.3.5.2.

16 17 2.3.3.2.3.9 Function 5.a, Reactor Water Cleanup (RWCU) System Isolation, Reactor Vessel 18 Water Level - Low Low, Level 2 19 20 This function exists in the current STS 3.3.6.1 as Function 4.k. The function is inserted into 21 new STS 3.3.5.2 as follows: 22 23

The applicability of the current STS 3.3.6.1 Function 4.k is Modes 1, 2, and 3. The 24 applicability in STS 3.3.5.2 is "when automatic isolation of the associated penetration flow 25 path is credited in calculating Drain Time. In other words, if the drain time calculation 26 assumes the RWCU system would be automatically isolated, this function must be operable 27 to perform that function. This is consistent with the definition of drain time and the new 28 STS 3.5.2 requirements.

29 30

The number of required channels is changed from [2], with a column header that states 31 "Required Channels per Trip System," to [2 in one trip system]. This retains the requirement 32 that the two channels must be associated with the same trip system. Only one trip system is 33 required to ensure that automatic isolation of one of the two isolation valves will occur on 34 low reactor vessel water level.

35 36

A Channel Check and Channel Functional Test are required at the existing frequency. A 37 calibration of the trip unit, Channel Calibration, Logic System Functional Test, and Isolation 38 System Response Time tests are no longer required in Modes 4 and 5.

39 40

The existing allowable value is retained in LCO 3.3.5.2A.

41 42 2.3.3.2.4 New TS 3.3.5.2A and B ACTIONS Table 43 44 Condition A is applicable when one or more instrument channels are inoperable from 45 Table 3.3.5.2-1. Required Action A.1 directs immediate entry into the condition referenced in 46 Table 3.3.5.2-1 for that channel. 47

1 Condition B is entered when the RHR system isolation and RWCU system isolation functions 2 operability requirements are not met when automatic isolation of the associated penetration flow 3 path is credited in calculating drain time. If the instrumentation is inoperable, Required 4 Action B.1 directs an immediate declaration that the associated penetration flow path(s) are 5 incapable of automatic isolation. Required Action B.2 requires an immediate calculation of drain 6 time. 7 8 Condition C is entered when the Low Reactor Steam Dome Pressure Injection Permissive 9 Functions necessary for ECCS subsystem manual initiation operability requirements are not 10 met. The channel must be placed in the trip condition within one hour. 11 12 For BWR/4s, Condition D is entered when the operability requirements for the Core Spray Pump 13 Discharge Flow - Low Bypass, Low Pressure Coolant Injection Pump Discharge Flow - Low 14 Bypass, or manual initiation of these functions operability requirements are not met. The 15 Required Action is to restore the channel to operable status within 24 hours. 16 17 For BWR/6s, Condition D is entered when the Condensate Storage Tank Level -Low operability 18 requirements are not met. Required Action D requires declaring the HPCS inoperable and 19 aligning the HPCS pump suction to the suppression pool within one hour. 20 21 For BWR/4s, Condition E is entered if the required Action and associated Completion Time of 22 Condition C or D, are not met. Required Action E.1 requires the associated low pressure ECCS 23 injection/spray subsystem to be declared inoperable immediately. 24 25 For BWR/6s, Condition E is entered if the Reactor Vessel Water Level - High Level 8 26 instrumentation operability requirements are not met. Action E.1 requires declaring the HCPS 27 system inoperable in 1 hour and restoring the channel to Operable status within 24 hours. 28 29 For BWR/6s, Condition F is entered if the LPCS Pump Discharge Flow Low (Bypass), LPCI 30 Pump A Discharge Flow Low (Bypass), LPCI Pump B and LPCI Pump C Discharge Flow - Low 31 (Bypass), HPCS Pump Discharge Pressure - High (Bypass) HPCS System Flow Rate - Low - 32 (Bypass) or Manual Initiation associated with these Functions operability requirements are not 33 met. The required action is to restore the channel to OPERABLE status within 24 hours. 34 35 For BWR/6s, Condition G is entered if the required action and associated completion time of 36 Condition C, D, E, or F is not met. Required Action G.1 requires the associated ECCS 37 injection/spray subsystem to be declared inoperable immediately. 38 39 2.3.3.2.5 New Surveillance Requirements SR 3.3.5.2.1, 3.3.5.2.2 and 3.3.5.3 40 41 New Table 3.3.5.2-1 specifies which SRs apply for each ECCS function. 42 43 SR 3.3.5.2.1 requires the performance of a Channel Check at a Frequency of [12 hours or in 44 accordance with the Surveillance Frequency Control Program.] 45 46 SR 3.3.5.2.2 requires the performance of a Channel Functional Test at a Frequency of [[92] 47 days or in accordance with the Surveillance Frequency Control Program.] 48

1 SR 3.3.5.2.3 requires the performance of a Logic System Functional Test at a Frequency of 2 [[18] months or in accordance with the Surveillance Frequency Control Program.] 3 4 2.3.3.3 Changes to Containment, Containment Isolation Valve and Standby Gas 5 Treatment System Requirements 6 7 The following TS are applicable during OPDRVs and/or contain Actions to suspend OPDRVS 8 when the LCO is not met: 9 10 NUREG-1433 (BWR/4 plants) 11 3.6.1.3, Primary Containment Isolation Valves (PCIVs) 12 3.6.4.1, [Secondary] Containment 13 3.6.4.2, Secondary Containment Isolation Valves (SCIVs) 14 3.6.4.3, Standby Gas Treatment System 15 16 NUREG-1434 (BWR/6 plants) 17 3.6.1.3, Primary Containment Isolation Valves (PCIVs) 18 3.6.4.1, [Secondary] Containment 19 3.6.4.2, Secondary Containment Isolation Valves (SCIVs) 20 3.6.4.3, Standby Gas Treatment System 21 22 For each of these TS, the applicability and required action sections are being revised to delete 23 references to OPDRVs. 24 25 2.3.3.4 Changes to Control Room Habitability and Temperature Control Requirements 26 27 NUREG-1433 (BWR/4 plants) 28 3.7.4, [Main Control Room Environmental Control (MCREC)] System 29 3.7.5, [Control Room Air Conditioning (AC)] System 30 31 NUREG-1434 (BWR/6 plants) 32 3.7.3, [Control Room Fresh Air (CRFA)] System 33 3.7.4, [Control Room AC] System 34 35 These LCOs are currently applicable during OPDRVs and contain required actions to 36 immediately initiate action to suspend OPDRVs when certain conditions of the LCO are not met. 37 38 The references to OPDRVs are being deleted from the applicability and required actions of 39 these TS. 40 41 2.3.3.5 Changes to Electrical Sources Requirements 42 43 NUREG-1433 (BWR/4 plants) and NUREG-1434 (BWR/6 plants) 44 3.8.2, AC Sources - Shutdown 45 3.8.5, DC Sources - Shutdown 46 3.8.8, Inverters - Shutdown 47 3.8.10, Distribution Systems - Shutdown 48

1 These TS are applicable in Modes 4 and 5 and currently contain a required action to initiate 2 action to suspend operations with a potential for draining the reactor vessel immediately if 3 certain conditions are not met. 4 5 TS 3.8.2 currently requires, in part, with one required offsite circuit inoperable or one required 6 diesel generator inoperable, to initiate action to suspend operations with a potential for draining 7 the reactor vessel immediately. 8 9 TS 3.8.5 currently requires, in part, with one [or more] required DC electrical power 10 subsystem[s] inoperable for reasons other than an inoperable battery charger, to initiate action 11 to suspend operations with a potential for draining the reactor vessel immediately 12 13 TS 3.8.3 currently requires, in part, with one [or more] [required] inverter[s] inoperable, to initiate 14 action to suspend operations with a potential for draining the reactor vessel immediately. 15 16 TS 3.8.10 currently requires, in part, with one or more required AC, DC, [or AC vital bus] 17 electrical power distribution subsystems inoperable, to initiate action to suspend operations with 18 a potential for draining the reactor vessel immediately. 19 20 These required actions are being deleted. 21 22 2.4 APPLICABLE REGULATORY REQUIREMENTS 23 24 The regulation at 10 CFR Section 50.36(a)(1) requires an applicant for an operating license to 25 include in the application proposed technical specifications in accordance with the requirements 26 of 10 CFR 50.36. The applicant must include in the application, a summary statement of the 27 bases or reasons for such specifications, other than those covering administrative controls. 28 However, per 10 CFR 50.36(a)(1), these technical specification bases shall not become part of 29 the technical specifications. Per 10 CFR 50.90, whenever a holder of a license desires to 30 amend the license, application for an amendment must be filed with the Commission, fully 31 describing the changes desired, and following as far as applicable, the form prescribed for 32 original applications. 33 34 Additionally, 10 CFR 50.36(b) requires: 35 36 37 Each license authorizing operation of a utilization facility will 38 include technical specifications. The technical specifications will 39 be derived from the analyses and evaluation included in the safety 40 analysis report, and amendments thereto, submitted pursuant to 41 10 CFR 50.34 [Contents of applications; technical information]. 42 The Commission may include such additional technical 43 specifications as the Commission finds appropriate. 44 45 46 Per 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the 47 applicant, the Commission will be guided by the considerations which govern the issuance of 48 initial licenses to the extent applicable and appropriate. 49

1 The categories of items required to be in the TSs are provided in 10 CFR 50.36(c). As required 2 by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability 3 or performance levels of equipment required for safe operation of the facility. Per 10 CFR 4 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the 5 reactor or follow any remedial action permitted by the TSs until the condition can be met. 6 7 The regulations at 10 CFR 50.36(c)(2)(ii) state that LCOs must be established for each item 8 meeting one of four criteria: 9 10 11 Criterion 1. Installed instrumentation that is used to detect, and 12 indicate in the control room, a significant abnormal degradation of 13 the reactor coolant pressure boundary. 14 15 Criterion 2. A process variable, design feature, or operating 16 restriction that is an initial condition of a design basis accident or 17 transient analysis that either assumes the failure of or presents a 18 challenge to fission product barrier integrity. 19 20 Criterion 3. A structure, system, or component that is part of the 21 primary success path and which functions or actuates to mitigate a 22 design basis accident or transient that either assumes the failure of 23 or presents a challenge to the integrity of a fission product barrier. 24 25 Criterion 4. A structure, system, or component which operating 26 experience or probabilistic safety assessment has shown to be 27 significant to public health and safety. 28 29 30 The regulation at 10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs, 31 which are requirements relating to test, calibration, or inspection to assure that the necessary 32 quality of systems and components is maintained, that facility operation will be within safety 33 limits, and that the LCOs will be met. Also, the regulation at 10 CFR 50.36(a)(1) states that a 34 summary statement of the bases or reasons for such specifications, other than those covering 35 administrative controls, shall also be included in the application, but shall not become part of the 36 TSs. 37 38 As described in the Commissions Final Policy Statement on Technical Specifications 39 Improvements for Nuclear Power Reactors, recommendations were made by NRC and industry 40 task groups for new STS that include greater emphasis on human factors principles in order to 41 add clarity and understanding to the text of the STS, and provide improvements to the Bases 42 Section of Technical Specifications, which provides the purpose for each requirement in the 43 specification. Subsequently, improved vendor-specific STS were developed and issued by the 44 NRC in September 1992. The improved STS were published as the following NRC Reports: 45 46 - NUREG-1430, Standard Technical Specifications, Babcock and Wilcox Plants 47 48 - NUREG-1431, Standard Technical Specifications, Westinghouse Plants 49

1 - NUREG-1432, Standard Technical Specifications, Combustion Engineering Plants 2 3 - NUREG-1433, Standard Technical Specifications, General Electric Plants, BWR/4 4 5 - NUREG-1434, Standard Technical Specifications, General Electric Plants, BWR/6 6 7 These improved STS were the result of extensive technical meetings and discussions among 8 the NRC staff, industry owners groups, vendors, and NUMARC. The Commission recognizes 9 the advantages of improved technical specifications. Clarification of the scope and purpose of 10 technical specifications has provided useful guidance to both the NRC and industry and has 11 served as an important incentive for industry participation in a voluntary program to improve 12 technical specifications. It has resulted in improved STS that are intended to focus licensee and 13 plant operator attention on those plant conditions most important to safety. This should also 14 result in more efficient use of agency and industry resources. 15 16 The NRC staffs guidance for review of TSs is in Chapter 16, Technical Specifications, of 17 NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for 18 Nuclear Power Plants (SRP), dated March 2010, (ADAMS Accession No. ML100351425). As 19 described therein, as part of the regulatory standardization effort, the NRC staff has prepared 20 STS for each of the light-water reactor nuclear designs. NUREG-1433, Revision 4, contains the 21 STS for BWR/4 plants and NUREG 1434, Revision 4, contains the STS for BWR/6 plants. 22 23

3.0 TECHNICAL EVALUATION

24 25 3.1 DRAIN TIME DEFINITION 26 27 The proposed drain time is the time it would take the RPV water inventory to drain from the 28 current level to the TAF assuming the most limiting of the RPV penetrations flow paths with the 29 largest flow rate, or a combination of penetration flow paths that could open due to a common 30 mode failure, were to open. 31 32 The NRC staff reviewed the proposed drain time definition from the traveler. For the purpose of 33 NRC staff considerations, the term break describes a pathway for water to drain from the RPV 34 that has not been prescribed in the DRAIN TIME definition proposed in TSTF-542. All RPV 35 penetrations below the TAF are included in the determination of drain time as potential 36 pathways. Attachment 2 to the RAI responses dated March 14, 2016 (ADAMS Accession 37 No. ML16074A448), provided an example bounding drain time calculations for three examples: 38 (1) water level at or below the reactor flange; (2) water level above RPV flange with fuel pool 39 gates installed, and; (3) water level above reactor flange with fuel pool gates removed. The 40 drain time is calculated by taking the water inventory above the break and dividing by the 41 limiting drain rate until the TAF is reached. The limiting drain rate is a variable parameter 42 depending on the break size and the reduction of elevation head above break location during 43 the drain down event. The discharge point will depend on the lowest potential drain point for 44 each RPV penetration flow path on a plant-specific basis. This calculation provides a 45 conservative approach to determining the drain time of the RPV. 46 47 Additionally, Attachment 2 to the RAI responses, provides a proposed example table to pair with 48 the drain time calculation. This table correlates the drain time (hours) to the penetration flow 49 path diameter (inches) and the reactor vessel water level (inches above the TAF). The

1 proposed example table is color coded to visually show if LCO 3.5.2 is met, or which LCO 2 condition the licensee would be in. This proposed example table provides operators with a 3 correlation to relate the calculated drain time to the RPV water level and where in the LCO the 4 operators should be. Based on these considerations, the NRC staff finds the proposed drain 5 time definition with supporting calculation and table to be acceptable. 6 7 3.2 WATER SOURCES 8 9 The proposed LCO 3.5.2 states that for BWR/4 TSs, one low pressure Emergency Core Cooling 10 System (ECCS) injection/spray subsystem shall be OPERABLE. For BWR/6 TSs, one ECCS 11 injection/spray subsystem shall be OPERABLE. It should be noted that the term low pressure 12 does not appear in the BWR/6 LCO because the BWR/6 High Pressure Core Spray (HPCS) 13 System may be used to satisfy the LCO. 14 15 The NRC staff reviewed the water sources that would be applicable to the proposed TS 3.5.2. 16 The ECCS pumps are high-capacity pumps, with flow rates of thousands of gallons per minute 17 (gpm). Most RPV penetration flow paths would have a drain rate on the order of tens or 18 hundreds of gpm. The automatic initiation of an ECCS pump would provide the necessary 19 water source to counter these expected drain rates. The LPCI subsystem is to be considered 20 operable during alignment and operation for decay heat removal if capable of being manually 21 realigned and not otherwise inoperable. Decay heat removal in MODEs 4 and 5 is not affected 22 by the proposed change in TSTF-542 as these requirements on the number of RHR shutdown 23 cooling subsystems that must be operable and in operation to ensure adequate decay heat 24 removal from the core are unchanged. These requirements can be found in the BWR/4 STS 25 TS 3.4.9, Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown, 26 TS 3.9.8, Residual Heat Removal (RHR) - High Water Level, and TS 3.9.10, Residual Heat 27 Removal (RHR) - Low Water Level. For the BWR/6 STS, the applicable TS are TS 3.4.10, 28 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown, TS 3.9.8, 29 Residual Heat Removal (RHR) - High Water Level, and TS 3.9.10, Residual Heat Removal 30 (RHR) - Low Water Level. Based on these considerations, the NRC staff finds the water 31 sources provide assurances that the lowest functional capability required for safe operation is 32 maintained and protecting the safety limit. 33 34 3.3 TS 3.5.2 - REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL 35 36 The proposed TS 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control, LCO 37 contains two parts. The first part states that DRAIN TIME of RPV water inventory to the top of 38 active (TAF) shall be 36 hours, and the second part states that for BWR/4, one low pressure 39 ECCS injection/spray subsystem shall be OPERABLE, and for BWR/6, one ECCS 40 injection/spray subsystem shall be OPERABLE. The proposed applicability for TS 3.5.2 is 41 MODEs 4 and 5. 42 43 The NRC staff reviewed the proposed STS 3.5.2, focusing on ensuring the fuel remains covered 44 with water and the changes made compared to the current STS. The proposed STS 3.5.2 45 contains Conditions A through E based on either required ECCS injection/spray subsystem 46 operability or drain time. 47 48 The current STS LCO for BWR/4 and BWR/6 plants state that two ECCS injection/spray 49 subsystems shall be operable, whereas the proposed LCO 3.5.2 states that only one ECCS

1 injection/spray subsystem shall be operable. This change is reflected in Condition A. The 2 change from two ECCS injection/spray subsystem to one ECCS injection/spray subsystem is 3 because this redundancy is not required. With one ECCS injection/spray subsystem and 4 non-safety related injection sources, defense-in-depth will be maintained. The defense-in-depth 5 measure is consistent with other events considered during shutdown with no additional single 6 failure assumed. The drain time controls, in addition to the required ECCS injection/spray 7 subsystem, provide reasonable assurance that an unexpected draining event can be prevented 8 or mitigated before the RPV water level would be lowered to the TAF. 9 10 The proposed Condition A states that if the required ECCS injection/spray subsystem is 11 inoperable, it is to be restored to operable status within 4 hours. Proposed Condition B states 12 that if Condition A is not met, a method of water injection capable of operating without offsite 13 electrical power should be established immediately. The proposed Condition B for TS 3.5.2 is 14 different from the STS, which states to initiate action to suspend OPDRVs. The proposed 15 Condition B provides adequate assurance of an available water source should Condition A not 16 be met within the 4-hour completion time. 17 18 The proposed Condition C states that for a drain time < 36 hours and 8 hours, to (1) verify 19 [secondary containment] boundary is capable of being established in less than 4 hours, and 20 (2) verify each [secondary containment] penetration flow path is capable of being isolated in less 21 than 4 hours, and (3) verify one standby gas treatment subsystem is capable of being placed in 22 operation in less than 4 hours. The current STS Condition C states if two ECCS injection/spray 23 subsystem are inoperable then restore one to operable status within 4 hours. The proposed 24 Condition C provides adequate protection should the DRAIN TIME be < 36 hours and 8 hours 25 because of the ability to establish secondary containment, isolate additional flow paths, and 26 have the standby gas treatment subsystem operable. 27 28 The proposed Condition D states that when drain time < 8 hours to (1) immediately initiate 29 action to establish an additional method of water injection with water sources capable of 30 maintaining RPV water level > TAF for 36 hours, (2) immediately initiate action to establish 31 [secondary] containment boundary, (3) immediately initiate action to isolate each [secondary] 32 containment penetration flow path or verify it can be manually isolated from the control room, 33 and (4) immediately initiate action to verify one standby gas treatment subsystem is capable of 34 being placed in operation. Additionally, there is a note stating that required ECCS 35 injection/spray subsystem or additional method of water injection shall be capable of operating 36 without offsite electrical power, which is similar to proposed Condition B. The current STS for 37 Condition D are similar to the proposed for when Required Action C.2 is not met. The proposed 38 Condition D provides adequate protection should the DRAIN TIME be < 8 hours because of the 39 ability to establish secondary containment, isolate additional flow paths, and have the standby 40 gas treatment subsystem operable. 41 42 The proposed Condition E states that when the required action and associated completion time 43 of Condition C or D is not met, or the drain time is < 1 hour, then initiate action to restore drain 44 time to 36 hours immediately. The proposed Condition E is new, as it is not present in the 45 current BWR/4 or BWR/6 STS. The proposed Condition E is acceptable as it provides the 46 necessary step to restore the drain time to 36 hours should the other conditions not be met, or 47 if the drain time is < 1 hour. 48

1 Based on the NRC staffs review, the proposed changes to TS 3.5.2 are acceptable based on 2 the actions taken to mitigate the water level reaching the TAF with the water sources available 3 and maintaining drain time 36 hours. The LCO correctly specifies the lowest functional 4 capability or performance levels of equipment required for safe operation of the facility. There is 5 reasonable assurance that the required actions to be taken when the LCO is not met can be 6 conducted without endangering the health and safety of the public. 7 8 The existing TS 3.3.5.2, "RCIC System Instrumentation," is renumbered as TS 3.3.5.3. This 9 increases consistency within the BWR TS as the Reactor Core Isolation Cooling (RCIC) System 10 is discussed in the section on TS 3.5.3. 11 12 3.4 STS 3.3.5.2, REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL 13 INSTRUMENTATION 14 15 The proposed TS and associated LCO in TS Section 3.3, Instrumentation, contains A and B 16 versions of TS 3.3.5.2. The A version is for TS without a Setpoint Control Program and 17 Table 3.3.5.2-1 has a column for listing Allowable Value. The B version is for TS with a Setpoint 18 Control Program and Table 3.3.5.2-1 has no allowable value column, because the Setpoint 19 Control Program dictates the setpoint value. In a like manner the associated LCO 3.3.5.2 has A 20 and B versions. The actions and SRs for both versions A and B are the same for BWR/4 and 21 BWR/6. 22 23 The purpose of the RPV Water Inventory Control Instrumentation is to support the requirements 24 of new STS LCO 3.5.2, and the definition of drain time. There are instrumentation and controls 25 and their signal functions that are required for manual initiation or required as a permissive or 26 operational controls on the equipment of the systems that provide water injection capability, 27 certain start commands, and isolation functions. These instruments are required to be operable 28 if the systems that provide water injection and isolation functions are to be considered operable 29 as described in the safety evaluation of new STS 3.5.2. In some cases the reactor operators 30 have alternate, often more complex means, of starting and injecting water than the preferred 31 simple push button start. 32 33 Specifically, the BWR/4 the RPV Water Inventory Control Instrumentation supports operation of 34 the Core Spray and LPCI including manual initiation when needed as well as the system 35 isolation of the RHR system and the RWCU system. The equipment involved with each of 36 these systems is described in the safety evaluation of TS 3.5.2 and the Bases for LCO 3.5.2. 37 38 Specifically, the BWR/6 the RPV Water Inventory Control Instrumentation supports operation of 39 the LPCI with subsystems LPCI A, LPCI B, and LPCI C, LPCS, and HPCS, including manual 40 initiation when needed as well as the system isolation of the RHR system and the RWCU 41 system. The equipment involved with each of these systems is described in the safety 42 evaluation of TS 3.5.2 and the Bases for LCO 3.5.2. 43 44 TSTF-542, Section 3.3, Proposed TS 3.3.5.2, Reactor Pressure Vessel Water Inventory 45 Control Instrumentation, describes and justifies the instrumentation requirements associated 46 with and needed to support TS 3.5.2 and LCO 3.5.2, Reactor Pressure Vessel Water Inventory 47 Control. Section 3.3.1 addresses the proposed TS 3.3.5.2 LCO and applicability. Section 3.3.2 48 discusses the proposed actions of TS 3.3.5.2. Section 3.3.3, addresses the proposed TS 49 3.3.5.2 surveillances. Section 3.3.4 discusses the proposed Table 3.3.5.2-1. The NRC staff

1 finds the instrumentation and actions required to support TS 3.3.2, as presented in Section 3.3, 2 sufficient and necessary as discussed below. 3 4 3.4.1 Proposed TS 3.3.5.2 LCO and Applicability 5 6 The proposed LCO 3.3.5.2 states, The RPV Water Inventory Control instrumentation for each 7 Function in Table 3.3.5.2-1 shall be OPERABLE. 8 9 The applicability states, "According to Table 3.3.5.2-1." 10 11 Section 3.3.1 of TSTF-542, states: 12 13 14 Table 3.3.5.2-1 contains those instrumentation Functions needed 15 to support manual initiation of the ECCS injection/spray 16 subsystem required by LCO 3.5.2, and automatic isolation of 17 penetration flow paths that may be credited in a calculation of 18 Drain Time. The Functions in Table 3.3.5.2-1 are moved from 19 existing TS 3.3.5.1, "ECCS Instrumentation," and TS 3.3.6.1, 20 "Primary Containment Isolation Instrumentation" Functions that 21 are required in Modes 4 or 5 or during OPDRVs. Creation of 22 TS 3.3.5.2 places these Functions in a single location with 23 requirements appropriate to support the safety function for 24 TS 3.5.2. 25 26 If plant-specific design and TS require different functions to 27 support manual initiation of an ECCS subsystem, those functions 28 should be included in TS 3.3.5.2. 29 30 31 3.4.2 Proposed TS 3.3.5.2 Actions for BWR/4 and BWR/6 32 33 TS 3.3.5.2 contains actions to be followed when the LCO is not met. 34 35 Section 3.3.2, Proposed TS 3.3.5.2 Actions, of TSTF-542 discusses the actions of TS 3.3.5.2 36 and LCO 3.3.5.2. The NRC staff finds these actions are sufficient and necessary, because 37 when one or more instrument channels are inoperable the equipment and function controlled by 38 these instruments cannot complete the required function in the normal manner and these 39 actions direct the licensee to take appropriate actions as necessary and enter immediately into 40 the Conditions referenced in Table 3.3.5.2-1. These actions satisfy the requirements of 10 CFR 41 50.36(c)(2)(i) by providing a remedial action permitted by the TS until the LCO can be met. The 42 remedial actions provide reasonable assurance that an unexpected draining event can be 43 prevented or mitigated before the RPV water level would be lowered to the TAF. 44 45 3.4.3 Proposed TS 3.3.5.2 Actions for BWR/4 46 47 The following summarizes the proposed actions of Section 3.3.2 for BWR/4. 48

1 Section 3.3.2, Proposed TS 3.3.5.2 Actions, of TSTF-542, Revision 2, discusses the actions of 2 TS 3.3.5.2 and LCO 3.3.5.2. The NRC staff finds these actions are sufficient and necessary, 3 because when one or more instrument channels are inoperable the equipment and function 4 controlled by these instruments cannot complete the required function in the normal way, and 5 these actions direct the licensee to take appropriate actions as required. The actions provide 6 reasonable assurance that an unexpected draining event can be prevented or mitigated before 7 the RPV water level would be lowered to the TAF. 8 9 Action A is applicable when one or more instrument channels are inoperable from 10 Table 3.3.5.2-1 and directs the licensee to immediately enter the Condition referenced in 11 Table 3.3.5.2-1 for that channel. 12 13 Action B (concerning the RHR system Isolation and RWCU system Isolation functions) are 14 applicable when automatic isolation of the associated penetration flow path is credited as not 15 having to be considered as a path for potential drainage in calculating drain time. If the 16 instrumentation is inoperable, Required Action B.1 directs an immediate declaration that the 17 associated penetration flow path(s) are incapable of automatic isolation. Required Action B.2 18 requires a re-calculation of drain time, but automatic isolation of the affected penetration flow 19 paths cannot be credited. 20 21 Action C (concerning low reactor steam dome pressure permissive Functions necessary for 22 ECCS subsystem manual initiation) addresses an event in which the permissive is inoperable 23 and manual initiation of ECCS using the control board pushbuttons is prevented. The function 24 must be placed in the trip condition within one hour. With the permissive function instrument in 25 the trip condition, manual initiation may now be performed using the preferred control board 26 pushbuttons. This one-hour completion time is acceptable, because despite the preferred start 27 method being prevented, the reactor operator can take manual control of the pump and the 28 injection valve to inject water into the RPV and achieve the safety function. The time of one 29 hour also provides reasonable time for evaluation and placing the channel in trip. 30 31 Action D (concerning pump discharge flow bypass Functions and the manual initiation 32 Functions) addresses actions when the bypass is inoperable and then there is a risk that the 33 associated ECCS pump could overheat when the pump is operating and the associated 34 injection valve is not fully open. In this condition, the operator can take manual control of the 35 pump and the injection. Similar to justification in Action C, while this is not the preferred 36 method, if a manual initiation function is inoperable, the ECCS subsystem pumps can be started 37 manually and the valves can be opened manually. The 24-hour completion time is acceptable, 38 because the functions can be performed manually and it allows time for the operator to evaluate 39 and have necessary repairs completed. Unlike the failure of a pushbutton that may concern 40 electronic component repairs, mechanical components may be involved in repairs, testing, and 41 return to service of pumps and valves. This further justifies a 24-hour completion time as 42 appropriate. 43 44 Action E is needed and becomes necessary, if the required action and associated completion 45 time of Condition C or D, are not met. If they are not met, then the associated low pressure 46 ECCS injection/spray subsystem may be incapable of performing the intended function, and the 47 ECCS subsystem must be declared inoperable immediately. 48 49 3.4.4 Proposed TS 3.3.5.2 Actions for BWR/6

1 2 TS 3.3.5.2 contains proposed actions to be followed when the LCO is not met for a BWR/6. 3 4 Section 3.3.2, Proposed TS 3.3.5.2 Actions, of TSTF-542, Revision 2, discusses the Actions of 5 TS 3.3.5.2 and LCO 3.3.5.2. The NRC staff finds these actions are sufficient and necessary, 6 because when one or more instrument channels are inoperable the equipment and function 7 controlled by these instruments cannot complete the required function in the normal way and 8 these actions direct the licensee to take appropriate actions as required. The actions provide 9 reasonable assurance that an unexpected draining event can be prevented or mitigated before 10 the RPV water level would be lowered to the TAF. 11 12 Action A is applicable when one or more instrument channels are inoperable from Table 3.3.5.2 13 and directs the licensee to immediately enter the condition referenced in Table 3.3.5.2-1 for that 14 channel. 15 16 Action B (concerning the RHR system isolation and RWCU system isolation functions) are 17 applicable when automatic isolation of the associated penetration flow path is credited as not 18 having to be considered as a path for potential drainage in calculating drain time. If the 19 instrumentation is inoperable, Required Action B.1 directs an immediate declaration that the 20 associated penetration flow path(s) are incapable of automatic isolation. Required Action B.2 21 requires a re-calculation of drain time, but automatic isolation of the affected penetration flow 22 paths cannot be credited. 23 24 Action C (concerning low reactor steam dome pressure permissive Functions necessary for 25 ECCS subsystem manual initiation) addresses an event in which the permissive is inoperable 26 and manual initiation of ECCS using the control board pushbuttons is prevented. The function 27 must be placed in the trip condition within one hour. With the permissive function instrument in 28 the trip condition, manual initiation may now be performed using the preferred control board 29 pushbuttons. This one hour completion time is acceptable, because despite the preferred start 30 method being prevented, the reactor operator can take manual control of the pump and the 31 injection valve to inject water into the RPV and achieve the safety function. The time of one 32 hour also provides reasonable time for evaluation and placing the channel in trip. 33 34 Action D (concerning loss of adequate water supply for the HPCS System), addresses an event 35 in which there is an inadequate water supply. The instrumentation functions have the ability to 36 detect low-water setpoint in the Condensate Storage Tank and actuate valves to realign HPCS 37 suction water source to the Suppression Pool. The Condensate Storage Tank Level - Low 38 Function indicates multiple, inoperable channels within the same Function resulting in a loss of 39 the automatic ability to swap suction to the Suppression Pool. The HPCS system must be 40 declared inoperable within one hour or the HPCS pump suction must be realigned to the 41 Suppression Pool, since, if realigned, the Function is already performed. This one hour is 42 acceptable, because it provides sufficient time to take the action in order to minimize the risk of 43 HPCS being needed without an adequate water source by allowing time for restoration or 44 alignment of the HPCS pump suction to the suppression pool. 45 46 Action E (concerning HPCS high water level Function in the RPV) addresses actions when this 47 instrument function is inoperable. HPCS Reactor Vessel Water Level - High, Level 8 function 48 ensures that appropriate actions are taken if the HPCS Reactor Vessel Water Level - High, 49 Level 8 Function is inoperable. If the inoperability results in the channel being tripped, the

1 HPCS pump discharge valve will not open and HPCS injection is prevented. In that case the 2 HPCS System must be declared inoperable within one hour, and the function must be restored 3 to operable status within 24 hours. The one hour completion time is acceptable, because of the 4 ability to manually start the HPCS pumps and open the discharge valve. The 24-hour 5 completion time is acceptable, because it allows time for the operator to evaluate and arrange 6 for repairs. 7 8 Action F (concerning pump discharge flow bypass Functions and the manual initiation 9 Functions) addresses an event in which the bypass is inoperable and there is a risk that the 10 associated ECCS pump could overheat when the pump is operating and the associated 11 injection valve is not fully open. In this condition, the operator can take manual control of the 12 pump and the injection. Similar to justification in Action C, while this is not the preferred 13 method, if a manual initiation function is inoperable, the ECCS subsystem pumps can be started 14 manually and the valves can be opened manually. The 24-hour completion time is acceptable, 15 because the functions can be performed manually and it allows time for the operator to evaluate 16 and have necessary repairs completed. Unlike the failure of a pushbutton that may concern 17 electronic component repairs, mechanical components may be involved in repairs, testing, and 18 return to service of pumps and valves further justifying a 24-hour completion time as 19 appropriate. 20 21 Action G is needed and becomes necessary, if the required action and associated completion 22 time of Condition C, D, E, or F are not met. If they are not met, then the associated low 23 pressure ECCS injection/spray subsystem may be incapable of performing the intended 24 function, and the ECCS subsystem must be declared inoperable immediately. 25 26 3.4.5 Proposed TS 3.3.5.2 Surveillances for BWR/4 and BWR/6 27 28 Section 3.3.3, Proposed TS 3.3.5.2 Surveillances, of TSTF-542 discusses the SR of TS 29 3.3.5.2. The TS 3.3.5.2 SR include Channel Checks, Channel Functional Tests, and Logic 30 System Functional Tests. There are three SRs numbered SR 3.3.5.2.1, SR 3.3.5.2.2, and SR 31 3.3.5.2.3. The NRC staff finds these tests are sufficient and adequate, because they are 32 essential to ensure the Functions of TS 3.3.5.2 are operable (i.e., capable of performing the 33 specified safety function in support of TS 3.5.2, Drain Time, and the protection from a potential 34 drain down of the RPV in Modes 4 and 5). The NRC staff finds the proposed TS 3.3.5.2 35 surveillances of LCO 3.5.2 as described in Section 3.3.3 satisfies 10 CFR 50.36(c)(3) by 36 providing the specific SRs relating to test, calibration, or inspection to assure that the necessary 37 quality of systems and components is maintained. 38 39 The following summarizes the notable characteristics of the surveillances described in 40 Section 3.3.3 of TSTF-542, which were reviewed by the NRC staff. 41 42 SR 3.3.5.2.1 requires a Channel Check and is applied to all functions except manual initiation. 43 Performance of the Channel Check ensures that a gross failure of instrumentation has not 44 occurred. A Channel Check is normally a comparison of the parameter indicated on one 45 channel to a similar parameter on other related channels. A Channel Check is significant in 46 assuring that there is a low probability of an undetected complete channel failure and is a key 47 safety practice to verifying the instrumentation continues to operate properly between each 48 Channel Functional Test. The frequency of 12 hours, or in accordance with the Surveillance

1 Frequency Control Program, is consistent with the existing requirements and supports operating 2 shift situational awareness. 3 4 SR 3.3.5.2.2 requires a Channel Functional Test and is applied to all functions except manual 5 initiation. A Channel Functional Test is the injection of a simulated or actual signal into the 6 channel as close to the sensor as practicable to verify operability of all devices in the channel 7 required for channel operability. It is performed on each required channel to ensure that the 8 entire channel will perform the intended function. The frequency is in accordance with the 9 Surveillance Frequency Control Program or 92 days. The applicant states, This is acceptable 10 because it is consistent with the existing requirements for these Functions and is based upon 11 operating experience that demonstrates channel failure is rare. Since periods in MODEs 4 and 12 5 as refueling outages are often in the order of 30 days or less, licensees could include this SR, 13 if desired, as part of a refueling activity. 14 15 SR 3.3.5.2.3 requires a Logic System Functional Test and is only applied to the manual initiation 16 functions. The Logic System Functional Test is a test of all logic components required for 17 operability of a logic circuit, from as close to the sensor as practicable up to, but not including, 18 the actuated device, and demonstrates the operability of the required manual initiation logic for 19 a specific channel. The ECCS subsystem functional testing performed in proposed SR 3.5.2.7 20 overlaps this surveillance to complete testing of the assumed safety function. The traveler 21 states: 22 23 24 The Frequency of [18] months, or in accordance with the 25 Surveillance Frequency Control Program, is consistent with the 26 existing requirements, and is based upon operating experience 27 that that has shown that these components usually pass the 28 Surveillance when performed at this Frequency. 29 30 31 There are no SRs included to verify or adjust the instrument setpoint derived from the allowable 32 value using a Channel Calibration or a surveillance to calibrate the trip unit. The traveler states, 33 34 35 A draining event in Mode 4 or 5 is not an analyzed accident and, 36 therefore, there is no accident analysis on which to base the 37 calculation of a setpoint. The purpose of the Functions is to allow 38 ECCS manual initiation or to automatically isolate a penetration 39 flow path, but no specific RPV water level is assumed for those 40 actions. Therefore, the Mode 3 Allowable Value was chosen for 41 use in Modes 4 and 5 as it will perform the desired function. 42 Calibrating the Functions in Modes 4 and 5 is not necessary, as 43 TS 3.3.5.1 and TS 3.3.6.1 continue to require the Functions to be 44 calibrated on an [18] month Frequency. 45 46 And: 47

1 A draining event in Mode 4 or 5 is not an analyzed accident and, 2 therefore, there are no accident analysis assumptions on 3 response time. 4 5 6 This is acceptable, because this is adequate to ensure the channel responds with the required 7 pumping systems to inject water when needed and isolation equipment to perform when 8 commanded. 9 10 ECCS Response Time and Isolation System Response Time testing ensure that the individual 11 channel response times are less than or equal to the maximum values assumed in the accident 12 analysis. TS 3.3.5.2 does not include SRs to participate in any ECCS Response Time testing 13 and Isolation System Response Time testing. This is acceptable because the purpose of these 14 tests are to ensure that the individual channel response times are less than or equal to the 15 maximum values assumed in the accident analysis, but a draining event in Mode 4 or 5 is not an 16 analyzed accident and, therefore, there are no accident analysis assumptions on response time 17 and there are alternate manual methods for achieving the safety function. A potential draining 18 event in MODEs 4 and 5 is a slower event than a LOCA. More significant protective actions are 19 required as the calculated drain time decreases. 20 21 3.4.6 Conclusion of NRC Staff Review of TS 3.3.5.2 22 23 The NRC staff finds that proposed TS 3.3.5.2 and LCO 3.3.5.2 satisfies Criterion 4 of 24 10 CFR 50.36(c)(3), because specific instrumentation is provided that helps prevent or mitigate 25 a potential RPV drain down event. Operating experience highlights that RPV draining events 26 are potentially significant to public health and safety, as established in the following NRC 27 documents: 28 29 1. Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in 30 Boiling Water Reactors During Shutdown and Startup," November 1984. 31 2. Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of 32 Misalignment of RHR Valves," August 1986. 33 3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water 34 Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f)," August 1992. 35 4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level 36 draining event in Mode 4 Instrumentation in BWRs," May 1993. 37 38 The NRC staff finds that proposed LCO 3.3.5.2 correctly specifies the lowest functional 39 capability or performance levels of equipment required for safe operation of the facility. There is 40 reasonable assurance that the required actions to be taken when the LCO is not met can be 41 conducted without endangering the health and safety of the public. 42 43 3.5 TABLE 3.3.5.2-1, "RPV WATER INVENTORY CONTROL INSTRUMENTATION" 44 45 In order to support the requirements of TS 3.5.2, and LCO 3.5.2, Reactor Pressure Vessel 46 (RPV) Water Inventory Control, and the definition of DRAIN TIME; the instrumentation 47 requirements are designated in Table 3.3.5.2-1. These instruments are required to be operable 48 if the systems that provide water injection and isolation functions are to be considered operable 49 as described in the NRC staffs safety evaluation of TS 3.5.2.

1 2 Table 3.3.5.2-1 specifies the instrumentation that shall be operable for each function in the table 3 for Modes 4 and 5 (or other specified conditions), the required number of channels per function, 4 conditions referenced from required action A.1, SR for the functions, the allowable value (if 5 version A), and footnotes concerning items of the table. 6 7 Table 3.3.5.2-1 for BWR/4 and BWR/6 differ only in that version A has a column for the 8 allowable value and B does not. Version A has a potential or generic allowable value in 9 brackets. The brackets indicate that a plant-specific value should be used in the LAR to adopt 10 TSTF-542. 11 12 Section 3.3.4, Proposed Table TS 3.3.5.2-1, RPV Water Inventory Control Instrumentation of 13 TSTF-542, presents details on the functions required to support the equipment and functions of 14 TS 3.5.2 for BWR/4 and BWR/6. The NRC staff finds the presentation in this table acceptable, 15 because this section sufficiently discusses the purpose of the functions, the applicability, the 16 number of required channels, the references to the Condition to be entered by letter (e.g., A, B, 17 C) if the function is inoperable, the applicable SRs, the selection of the allowable value, if 18 applicable, and justification of differences between the existing and proposed TS functions. 19 This RPV Water Inventory Control Instrumentation set is acceptable, because it is adequate to 20 ensure the instruments of the channels responds with the required accuracy permitting pumps 21 systems to operate to inject water when needed and isolation of equipment when commanded 22 to support the prevention of or mitigate a potential RPV draining event. 23 24 Each of the ECCS subsystems in the BWR/4 and BWR/6 in MODEs 4 and 5 are initiated by 25 manual pushbutton. The traveler states, automatic initiation of an ECCS injection/spray 26 subsystem, with injection rates of thousands of gpm, may be undesirable as it can lead to 27 overflowing the RPV cavity. Thus, there is adequate time to take manual actions (e.g., hours 28 versus minutes). Considering the action statements as the drain time decreases (the proposed 29 TS 3.5.2, Action E, prohibits plant conditions that could result in drain times less than one hour), 30 therefore, there is sufficient time for the reactor operators to take manual action to stop the 31 draining event, and to manually start an ECCS injection/spray subsystem or the additional 32 method of water injection as needed. Consequently, there is no need for automatic initiation of 33 ECCS to respond to an unexpected draining event. This is acceptable, because a draining 34 event is a slow evolution when compared to a design basis LOCA assumed to occur at a 35 significant power level. 36 37 3.5.1 Proposed Table 3.3.5.2-1 Functions for BWR/4 38 39 The following summarizes notable characteristics of the RPV Water Inventory Control 40 Instrumentation as discussed in Section 3.3.4 of TSTF-542, Revision 2. 41 42 For the Table 3.3.5.2-1 Functions 1.a and 2.a, BWR/4 CS and LPCI Systems, Reactor Steam 43 Dome Pressure - Low (Injection Permissive), these signals are used as permissives and 44 protection for these low pressure ECCS injection/spray subsystem manual initiation functions. 45 This function ensures that the reactor pressure has fallen to a value below these subsystems' 46 maximum design pressure before permitting the operator to open the injection valves of the low 47 pressure ECCS subsystems. Even though during MODEs 4 and 5 the reactor steam dome 48 pressure is expected to virtually always be below the ECCS maximum design pumping

1 pressure, the Reactor Steam Dome Pressure - Low signals are required to be operable and 2 capable of permitting initiation of the ECCS. 3 4 For the Table 3.3.5.2-1 Functions 1.b and 2.b, BWR/4 CS and LPCI Systems, Pump Discharge 5 Flow - Low (Bypass), these minimum flow instruments are provided to protect the associated 6 low pressure ECCS pumps from overheating when the pump is operating and the associated 7 injection valve is not fully open. The minimum flow line valve is opened when low flow is 8 sensed, and the valve is automatically closed when the flow rate is adequate to protect the 9 pump. Where applicable, allowable values (version A) specified are high enough to ensure that 10 the pump flow rate is sufficient to protect the pump, yet low enough to ensure that the closure of 11 the minimum flow valve is initiated to allow full flow into the core. Brackets around allowable 12 value indicate the actual value is to be plant-specific and dependent on actual equipment. The 13 LPCI minimum flow valves are time delayed such that the valves will not open for 10 seconds 14 after the switches detect low flow. This time delay is acceptable, because it is provided to limit 15 reactor vessel inventory loss during the startup of the RHR shutdown cooling mode. 16 17 For the Table 3.3.5.2-1 Functions 1.c and 2.c, BWR/4 CS System Manual Initiation and LPCI, 18 System Manual Initiation, the manual initiation pushbutton channels introduce signals into the 19 appropriate ECCS logic to provide manual initiation capability. There is one push button for 20 each of the CS and LPCI subsystems (i.e., two for CS and two for LPCI). There is no allowable 21 value for this Function since the channels are mechanically actuated based solely on the 22 position of the push buttons. An instrument channel of the Manual Initiation Function (one 23 channel per subsystem) is required to be Operable in MODEs 4 and 5 when the associated 24 ECCS subsystems are required to be Operable per LCO 3.5.2. 25 26 For the Table 3.3.5.2-1 Function 3.a, BWR/4 RHR System Isolation, Reactor Vessel Water 27 Level - Low, Level 3, the function is only required to be operable when automatic isolation of the 28 associated penetration flow path is credited in the drain time calculation. The number of 29 required instrument channels is [2 in one trip system], which retains the requirement that the two 30 instrument channels must be associated with the same trip system. Each trip system isolates 31 one of two redundant isolation valves, and only one trip system is required to be operable to 32 ensure that automatic isolation of one of the two isolation valves will occur on low reactor vessel 33 water level indication. The allowable value (version A) was chosen to be the same as the 34 Primary Containment Isolation Instrumentation Reactor Vessel Water Level - Low, Level 3 35 Allowable Value from LCO 3.3.6.1. 36 37 For the Table 3.3.5.2-1 Function 4.a, BWR/4 RWCU, System Isolation, Reactor Vessel Water 38 Level - Low Low, Level 2, the function is only required to be operable when automatic isolation 39 of the associated penetration flow path is credited in the drain time calculation. The number of 40 required channels is [2 in one trip system], which retains the requirement that the two instrument 41 channels must be associated with the same trip system. Only one trip system is required to be 42 operable to ensure that automatic isolation of one of the two isolation valves will occur on low 43 reactor vessel water level. Allowable value (version A) was chosen to be the same as the 44 ECCS Reactor Vessel Water Level - Low Low, Level 2 Allowable Value from LCO 3.3.5.1. 45 46 3.5.2 Proposed Table 3.3.5.2.-1 Functions for BWR/6 47 48 The following summarizes notable characteristics of the RPV Water Inventory Control 49 Instrumentation as discussed in Section 3.3.4 of TSTF-542, Revision 2.

1 2 For the Table 3.3.5.2-1 Functions 1.a and 2.a, BWR/6 LPCS and LPCI Systems, Reactor Steam 3 Dome Pressure - Low (Injection Permissive), these signals are used as permissives and 4 protection for these low pressure ECCS injection/spray subsystem manual initiation functions. 5 This function ensures that the reactor pressure has fallen to a value below these subsystems' 6 maximum design pressure before permitting the operator from opening the injection valves of 7 the low pressure ECCS subsystems. Even though during MODEs 4 and 5 the reactor steam 8 dome pressure is expected to virtually always be below the ECCS maximum design pumping 9 pressure, the Reactor Steam Dome Pressure - Low signals are required to be operable and 10 capable of permitting initiation of the ECCS. 11 12 For the Table 3.3.5.2-1 Functions 1.b, 1.c, and 2.b, BWR/6 LPCS and LPCI Systems Low 13 Pressure Coolant Injection and Low Pressure Core Spray Pump Discharge Flow - Low 14 (Bypass), these instruments are provided to protect the associated low pressure ECCS pump 15 from overheating when the pump is operating and the associated injection valve is not fully 16 open. The minimum flow line valve is opened when low flow is sensed, and the valve is 17 automatically closed when the flow rate is adequate to protect the pump. Where applicable 18 allowable values (version A) specified are high enough to ensure that the pump flow rate is 19 sufficient to protect the pump, yet low enough to ensure that the closure of the minimum flow 20 valve is initiated to allow full flow into the core. Brackets around allowable value indicate the 21 actual value is to be plant-specific and dependent on actual equipment. 22 23 For the Table 3.3.5.2-1 Functions 1.d and 2.c, BWR/6 LPCS and LPCI Systems, Manual 24 Initiation, the manual initiation pushbutton channels introduce signals into the appropriate ECCS 25 logic to provide manual initiation capability. There is one pushbutton for each subsystem in the 26 two divisions of low pressure ECCS (i.e., Division 1 ECCS, LPCS and LPCI A; Division 2 ECCS, 27 LPCI B and LPCI C). There are four subsystems, thus four pushbuttons for the low pressure 28 ECCS. The only manual initiation function required to be operable is that associated with the 29 ECCS subsystem that is required to be operable by LCO 3.5.2. Since the channels are 30 mechanically actuated based solely on the position of the pushbuttons, there is no allowable 31 value (version A) for this function. When this instrument function is inoperable, manual initiation 32 with the control board push buttons is inoperable. However, the ECCS pumps can be started 33 manually and valves can be opened manually by the reactor operator. This is not the preferred 34 condition. 35 36 For the Table 3.3.5.2-1 Functions 3.a, BWR/6 HPCS System Reactor Vessel Water Level - 37 High, Level 8, the High RPV water level, Level 8 signal, is used to close the HPCS injection 38 valve to prevent overflow into the main steam lines (MSLs). One instrument channel associated 39 with the HPCS system is required to be operable to support LCO 3.5.2. The LCO 3.3.5.2 40 allowable value (version A) is chosen to isolate flow from the HPCS system prior to water 41 overflowing into the MSLs. 42 43 For the Table 3.3.5.2-1 Functions 3.b, BWR/6 HPCS System, Condensate Storage Tank 44 Level - Low, the low level signal in the Condensate Storage Tank (CST) indicates the lack of an 45 adequate supply of makeup water from this primary source for HPCS. Normally, the water 46 source for the suction for HPCS is the CST. If the water level in the CST falls below a 47 preselected level, instrumentation logic controls valves so suction is then pulled from the 48 Suppression Pool. First the Suppression Pool suction valve is automatically opened and then 49 the CST suction valve is automatically closed in a manner to ensure that an adequate supply of

1 makeup water is available to the HPCS pump. The Condensate Storage Tank Level - Low 2 signals are initiated from two level transmitters. The Condensate Storage Tank Level - Low 3 Function Allowable Value is high enough to ensure adequate pump suction head while water is 4 being taken from the CST. 5 6 For the Table 3.3.5.2-1 Functions 3.c and 3.d, BWR/6 HPCS System, HPCS Pump Discharge 7 Pressure - High (Bypass) and HPCS System Flow Rate - Low (Bypass), the minimum flow 8 instruments are provided to protect the HPCS pump from overheating when the pump is 9 operating and the associated injection valve is not fully open. The minimum flow line valve is 10 opened when low flow and high pump discharge pressure are sensed, and the valve is 11 automatically closed when the flow rate is adequate to protect the pump or the discharge 12 pressure is low (indicating the HPCS pump is not operating). 13 14 For the Table 3.3.5.2-1 Function 3.e, BWR/6 HPCS System, Manual Initiation, the Manual 15 Initiation push button channel introduces a signal into the HPCS logic to provide manual 16 initiation capability. There is one pushbutton for the HPCS system. 17 18 For the Table 3.3.5.2-1 Function 4.a, BWR/6 RHR System Isolation, Reactor Vessel Water 19 Level - Low, Level 3, the Function is only required to be operable when automatic isolation of 20 the associated RHR system penetration flow path is credited in calculating drain time. The 21 definition of drain time allows crediting the closing of penetration flow paths that are capable of 22 being automatically isolated by RPV water level isolation instrumentation prior to the RPV water 23 level dropping below the TAF, but if the instrument function is inoperable, a closed path cannot 24 be credited and a drain time calculation must be re-performed. 25 26 For the Table 3.3.5.2-1 Function 5.a, BWR/6 RWCU System Isolation, Reactor Vessel Water 27 Level - Low Low, Level 2, the Function is only required to be Operable when automatic isolation 28 of the associated RWCU system penetration flow path is credited in calculating drain time. The 29 definition of drain time allows crediting the closing of penetration flow paths that are capable of 30 being automatically isolated by RPV water level isolation instrumentation prior to the RPV water 31 level dropping below the TAF, but if the instrument function is inoperable, a closed path cannot 32 be credited and a drain time calculation must be re-performed. This function is not applicable in 33 MODEs 4 or 5 in TS 3.3.6.1, but is being added to TS 3.3.5.2 to support crediting the automatic 34 isolation of the RWCU system in calculating drain time. 35 36 3.6 OTHER DIFFERENCES BETWEEN THE CURRENT AND PROPOSED TS 37 38 Section 3.4., Evaluation of other Differences between the Current and Proposed TS, of TSTF-39 542, presents and discusses other differences between the current TS requirements related to 40 OPDRVs and the proposed TS requirements for RPV WIC. The current STS contain 41 requirements related to instrumentation that are applicable during OPDRVs and are applicable 42 when the existing LCO 3.5.2 is applicable. They do not specifically impact the focus on TS 43 3.3.5.2 and the associated LCO 3.5.2 and Table 3.3.5.2-1. 44 45 3.7 STS 3.5.2 - REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL 46 47 The categories of items required to be in the TSs are provided in 10 CFR 50.36(c). As required 48 by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability 49 or performance levels of equipment required for safe operation of the facility. Per 10 CFR

1 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the 2 reactor or follow any remedial action permitted by the TSs until the condition can be met. 3 4 The regulations at 10 CFR 50.36(c)(2)(ii) state that LCOs must be established for each item 5 meeting one of four criteria: 6 7 8 Criterion 1. Installed instrumentation that is used to detect, and 9 indicate in the control room, a significant abnormal degradation of 10 the reactor coolant pressure boundary. 11 12 Criterion 2. A process variable, design feature, or operating 13 restriction that is an initial condition of a design basis accident or 14 transient analysis that either assumes the failure of or presents a 15 challenge to fission product barrier integrity. 16 17 Criterion 3. A structure, system, or component that is part of the 18 primary success path and which functions or actuates to mitigate 19 a design basis accident or transient that either assumes the failure 20 of or presents a challenge to the integrity of a fission product 21 barrier. 22 23 Criterion 4. A structure, system, or component which operating 24 experience or probabilistic safety assessment has shown to be 25 significant to public health and safety. 26 27 28 Technical Specification Safety Limit 2.1.1.3 requires that reactor vessel water level shall be 29 greater than the top of active irradiated fuel. Maintaining water level above the TAF ensures 30 that the fuel cladding fission product barrier is protected during shutdown conditions. The 31 changes to the STS described in traveler TSTF-542 establish specifications for equipment and 32 associated instrumentation that ensure the reactor vessel water level is maintained above the 33 TAF during MODE 4 and 5 operations. 34 35 NUREG-0800, Revision 3, Standard Review Plan (March 2010) (ADAMS Accession 36 No. ML100351425), describes LOCAs as postulated accidents that would result from the loss of 37 reactor coolant, at a rate in excess of the capability of the normal reactor coolant makeup 38 system, from piping breaks in the reactor coolant pressure boundary. During operation in 39 MODEs 4 and 5, the reactor coolant system is at a low operating temperature (<200 ° 40 Fahrenheit) and is depressurized. An event involving a loss of inventory while in the shutdown 41 condition is judged to not exceed the capacity of one ECCS subsystem. The accidents that are 42 postulated to occur during shutdown conditions, the Fuel Handling Accident and the Waste Gas 43 Decay Tank Rupture, do not involve a loss of inventory. The equipment and instrumentation 44 associated with the Reactor Vessel Water Inventory Control TS do not provide detection or 45 mitigation related to these design basis accidents. 46 47 The revised STS LCO 3.5.2 contains requirements for operability of one ECCS subsystem 48 along with requirements to maintain a sufficiently long drain time that plant operators would 49 have time to diagnose and mitigate an unplanned draining event. The NRC staff has

1 determined that the LCO 3.5.2 and 3.3.5.2 provide alternatives for the lowest functional 2 capability or performance levels of equipment required for safe operation of the facility. On this 3 basis, the NRC staff concludes that the requirements of 10 CFR 50.36(c)(2)(i) are met. 4 5 Additionally, the revised STS LCOs 3.5.2 and 3.3.5.2 provide remedial actions to be taken in the 6 event the LCO is not satisfied, therefore meeting the requirements of 10 CFR 50.36(c)(2)(i). 7 The NRC staff has found that the remedial actions provide reasonable assurance that an 8 unexpected draining event can be prevented or mitigated before the RPV water level would be 9 lowered to the TAF. 10 11 The regulation at 10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs, 12 which are requirements relating to test, calibration, or inspection to assure that the necessary 13 quality of systems and components is maintained, that facility operation will be within safety 14 limits, and that the LCOs will be met. The NRC staff reviewed the SRs associated with the 15 revised LCOs 3.5.2 and 3.3.5.2. The NRC staff reviewed the new SRs and determined that 16 they are appropriate for ensuring the operability of the equipment and instrumentation specified 17 in LCOs 3.5.2. Therefore, the NRC staff concludes that the requirements of 10 CFR 50.36(c)(3) 18 are met. 19 20 The regulation at 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons 21 for such specifications, other than those covering administrative controls, shall also be included 22 in the application, but shall not become part of the TSs. Traveler TSTF-542 contains TS Bases 23 changes that describe the basis for the affected TS. A summary of the NRC staffs evaluation of 24 the TS Bases changes is provided in an attachment to this SE. 25 26 The NRC staffs guidance for review of TSs is in Chapter 16, Technical Specifications, of 27 NUREG-0800, Revision 3, Standard Review Plan (March 2010) (ADAMS Accession 28 No. ML100351425). As described therein, as part of the regulatory standardization effort, the 29 NRC staff has prepared STS for each of the light-water reactor nuclear designs. NUREG-1433, 30 Revision 4, contains the STS for BWR/4 plants and NUREG 1434, Revision 4, contains the STS 31 for BWR/6 plants. The changes to the STS were reviewed for technical clarity and consistency 32 with customary terminology and format with the existing requirements. The NRC staff found 33 that the proposed changes were consistent with the existing framework. 34 35

4.0 CONCLUSION

36 37 The NRC staff reviewed traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water 38 Inventory Control, which proposed changes to NUREG-1433, Volumes 1 (STS for BWR/4) and 39 2 (Bases) and NUREG-1434 Volumes 1 (STS for BWR/6) and 2 (Bases). The NRC staff 40 determined that the proposed changes to the STS for BWR/4 and the STS for BWR/6 met the 41 standards for TS in 10 CFR 50.36(b). The proposed LCOs appropriately specify the lowest 42 functional capability or performance levels of equipment required for safe operation of the 43 facility, as required by 10 CFR 50.36(c)(2)(i). The remedial actions to be taken when an LCO is 44 not met action statements provide adequate protection to the health and safety of the public, 45 thereby satisfy the Act and 10 CFR 50.36(c)(2)(i). The proposed surveillance requirements 46 assure that the necessary quality of systems and components is maintained, that facility 47 operation will be within safety limits, and that the LCOs will be met, and satisfy 10 CFR 48 50.36(c)(3). 49

1 The proposed bases, which will be added to future revisions to NUREG-1433, Volume 2, and 2 NUREG-1434, Volume 2, satisfy the Commissions Policy Statement by addressing the 3 questions specified in the policy statement, and cite references to appropriate licensing 4 documentation to support the Bases. 5 6 Technical contacts: Matt Hardgrove, NRR/DSS/SRXB 7 Eugene Eagle, NRR/DE/EICB 8 9

Attachment:

Basis for Accepting the Proposed Changes to the Standard Technical 10 Specification Bases, Volume 2 of NUREGs 1433 and 1434 11 12 Date: October 6, 2016

1 ATTACHMENT 2 3 BASIS FOR ACCEPTING THE PROPOSED CHANGES TO THE STANDARD TECHNICAL 4 SPECIFICATION BASES, VOLUME 2 OF NUREGS 1433 AND 1434 5 6

1.0 INTRODUCTION

7 8 Traveler TSTF-542 proposes changes to Standard Technical Specifications, General Electric 9 BWR/4 Plants, BWR/4 NUREG-1433, Volume 2, Bases, Revision 4.0, April 2012, ADAMS 10 Accession No. ML12104A193 and Standard Technical Specifications, General Electric BWR/6 11 Plants, BWR/6 NUREG-1434, Volume 2, Bases, Revision 4.0, April 2012, ADAMS Accession 12 No. ML12104A196. The changes would be incorporated into future revisions of NUREG-1433, 13 Volume 2, and NUREG-1434, Volume 2. A summary of the changes and the staffs evaluation 14 of those changes are presented in this Attachment. 15 16

2.0 REGULATORY EVALUATION

17 18 2.1 Applicable Regulations and Guidance 19 20 The regulation at 10 CFR 50.36(a)(1) states that each applicant for a license authorizing 21 operation of a production or utilization facility shall include in his application proposed technical 22 specifications in accordance with the requirements of this section. A summary statement of the 23 bases or reasons for such specifications, other than those covering administrative controls, shall 24 also be included in the application, but shall not become part of the technical specifications. 25 26 In its Final Policy Statement on Technical Specifications Improvements for Nuclear Power 27 Reactors, the Commission presented its policy on the scope and purpose of the Technical 28 Specifications. The Commission explained how implementation of the policy statement through 29 implementation of the improved STS is expected to produce an improvement in the safety of 30 nuclear power plants through the use of more operator-oriented TS, improved TS Bases, 31 reduced action-statement-induced plant transients, and more efficient use of NRC and industry 32 resources. 33 34 The Final Policy Statement provides the following description of the scope and the purpose of 35 the Technical Specification Bases: 36 37 Appropriate Surveillance Requirements and Actions should be 38 retained for each LCO which remains or is included in the 39 Technical Specifications. Each LCO, Action, and Surveillance 40 Requirement should have supporting Bases. The Bases should at 41 a minimum address the following questions and cite references to 42 appropriate licensing documentation (e.g., FSAR, Topical Report) 43 to support the Bases. 44 ATTACHMENT

1 1. What is the justification for the Technical Specification, i.e., which 2 Policy Statement criterion requires it to be in the Technical 3 Specifications? 4 5 2. What are the Bases for each LCO, i.e., why was it determined to 6 be the lowest functional capability or performance level for the 7 system or component in question necessary for safe operation of 8 the facility and, what are the reasons for the Applicability of the 9 LCO? 10 11 3. What are the Bases for each Action, i.e., why should this remedial 12 action be taken if the associated LCO cannot be met; how does 13 this Action relate to other Actions associated with the LCO; and 14 what justifies continued operation of the system or component at 15 the reduced state from the state specified in the LCO for the 16 allowed time period? 17 18 4. What are the Bases for each Safety Limit? 19 20 5. What are the Bases for each Surveillance Requirement and 21 Surveillance Frequency; i.e., what specific functional requirement 22 is the surveillance designed to verify? Why is this surveillance 23 necessary at the specified frequency to assure that the system or 24 component function is maintained, that facility operation will be 25 within the Safety Limits, and that the LCO will be met? 26 27 Note: In answering these questions the Bases for each number 28 (e.g., Allowable Value, Response Time, Completion Time, 29 Surveillance Frequency), state, condition, and definition (e.g., 30 operability) should be clearly specified. As an example, a number 31 might be based on engineering judgment, past experience, or 32 PSA insights; but this should be clearly stated. 33 34 The NRC staff used the guidance contained in the Final Policy Statement during its review of 35 the proposed changes to the Bases. 36 37 2.2 Description of Changes 38 39 Volume 2 NUREGs-1433 and -1434 contain the Bases for each Safety Limit and each LCO 40 contained in Volume 1. The Bases for each LCO is organized into sections: 41 42 Background

1 Applicable Safety Analyses, LCO, and Applicability 2 Actions 3 Surveillance Requirements 4 References 5 6 The Bases for LCOs 3.3.5.2 (A and B) and 3.5.2 were rewritten in their entirety to reflect the 7 changes in the associated LCOs. The Bases for the remainder of the affected LCOs were 8 modified to reflect the deletion of OPDRVs. 9 10 In the following sections, the discussion is applicable to both NUREG 1433 (for BWR/4 plants) 11 and NUREG 1434 (for BWR/6 plants) unless otherwise noted. The discussion provides a 12 summary of the revised Bases, followed by the NRC staffs evaluation of the revised Bases. 13 14

3.0 TECHNICAL EVALUATION

15 16 3.1 Evaluation of B 3.3.5.2 (A) and B 3.3.5.2 (B) 17 18 B 3.3.5.2(A) is applicable in the absence of a Setpoint Control Program, and B 3.3.5.2(B) is 19 applicable if a Setpoint Control Program is used. For simplicity in presentation, the description 20 provided below applies to both the (A) and (B) versions, unless otherwise stated. 21 22 The Background section provides: 23 24

a description of the reactor pressure vessel (RPV) design, which includes penetrations 25 below the top of active fuel.

26

a description of Safety Limit 2.1.1.3, which requires the RPV water level to be above the 27 top of active fuel.

28

an explanation of the purpose of the RPV water Inventory Control Instrumentation, which 29 is to support the requirements of LCO 3.5.2, Reactor Pressure Vessel Water Inventory 30 Control by ensuring that the functions required for manual initiation of required 31 Emergency Core Cooling System (ECCS) injection/spray subsystem are available and 32 that other functions supporting isolation of flowpath(s) on low RPV level are available.

33 34 The Applicable Safety Analyses, LCO and Applicability section provides: 35 36

a statement that indicates that water inventory control is required in Modes 4 and 5 to 37 protect Safety Limit 2.1.1.3 and a discussion that due to the reduced Reactor Coolant 38 System (RCS) pressure in the shutdown condition, a very large break in the RCS is not 39 postulated in the shutdown condition.

40

an explanation that this LCO is applicable in Modes 4 and 5 to support operability of 41 subsystems required to be operable in Modes 4 and 5 as specified in LCO 3.5.2.

1

a description of why the LCO meets Criterion 4 specified in 10 CFR 50.36(c)(2(ii) as a 2 structure, system or component which operating experience has shown to be significant 3 to public health and safety.

4

a detailed discussion regarding each function contained in LCO 3.3.5.2.

5 6 o Core Spray and Low Pressure Coolant Injection Systems: 7 Function 1.a, 2.a Reactor Steam Dome Pressure - Low (Injection 8 Permissive) is required to be Operable to ensure the capability of initiating 9 ECCS when pressure is below the injection subsystems design pressure. 10 The actuation logic is one out of two taken twice, four channels are 11 required to be operable. 12 For BWR/4s, Function 1.b, 2.b Core Spray and Low Pressure Coolant 13 Injection Pump Discharge Flow - Low (Bypass) is required to be operable 14 to ensure minimum flow line is available to protect the associated low 15 pressure ECCS pump from overheating on low discharge and to ensure 16 closure of the minimum flow valve is initiated at the proper point to ensure 17 full injection flow when required. One channel per required pump is 18 required to be operable. 19 For BWR/6s, Function 1.b, 1.c, 2.b Low Pressure Coolant Injection and 20 Low Pressure Core Spray pump Discharge Flow - Low (Bypass) is 21 required to be operable to ensure minimum flow line is available to protect 22 the associated low pressure ECCS pump from overheating on low 23 discharge and to ensure closure of the minimum flow valve is initiated at 24 the proper point to ensure full injection flow when required. One channel 25 per required pump is required to be operable. 26 Function 1.c (for BWR/4), 1.d (for BWR/6) 2.c, Manual Initiation, is 27 required to be operable to provide manual initiation capability. One 28 channel (pushbutton) per required subsystem is required to be operable 29 per ECCS subsystem required to be operable. 30 31 o For BWR/6, High Pressure Core Spray System: 32 Function 3.a, Reactor Vessel Water Level - High, Level 8 is used to close 33 the HPCS injection valve to prevent overflow into the main steam lines. 34 One channel associated with the HPCS system required by LCO 3.5.2 is 35 required to be operable. The allowable value is chosen to ensure no 36 overflow into the main steam lines. 37 Function 3.b, Condensate Storage Tank (CST) Level, Low indicates low 38 supply of makeup water from this source. HPCS is normally aligned to 39 take suction on the CST. On low CST level, the HPCS pump suction 40 valves from the suppression pool open and then the suction valves from 41 the CST close. One channel is required to be operable when HPCS is

1 required per LCO 3.5.2 and the HPCS is aligned to the CST. The 2 allowable value is selected to ensure adequate pump suction head. 3 Function 3.c., 3.d HPCS Pump Discharge Pressure - High (Bypass) and 4 HPCS System Flow Rate - Low (Bypass) is required to be operable to 5 ensure minimum flow line is available to protect the associated HPCS 6 pump from overheating on low discharge. The allowable value is set to 7 ensure the flow is sufficient to protect the pump, but closes when a 8 minimum flow is reached to ensure full injection flow into the core. One 9 channel is required when HPCS is required to be operable per LOC 3.5.2. 10 Function 3.e, Manual Initiation, is required to be operable to ensure 11 manual initiation capability. One channel is required when the associated 12 ECCS subsystem is required by LCO 3.5.2. 13 14 o RHR System Isolation: 15 Function 3.a (for BWR/4) and 4.a (for BWR/6), Reactor Vessel Water 16 Level - Low Level 3 may be credited for automatic isolation of penetration 17 flow paths associated with the RHR system. The function is required to 18 be operable when automatic isolation of the associated penetration flow 19 path is assumed in the calculated Drain Time. Two channels in the same 20 trip system are required to be operable. 21 22 o Reactor Water Cleanup (RWCU) System Isolation: 23 Function 4.a (for BWR/4) and 5.a (for BWR/6), Reactor Vessel Water 24 level - Low Low, Level 2 may be credited for automatic isolation of 25 penetration flow paths associated with the RWCU System. This function 26 is required to be operable when automatic isolation of the associated 27 penetration flow path is assumed in the calculated Drain Time. Two 28 channels in the same trip system are required to be operable. 29 The Allowable Value selected is the same as the Allowable Value during 30 Power Operation. 31 32

an explanation of each Required Action and Completion Time contained in the Actions 33 Table.

34 35 o For BWR/4s: 36 Condition A is entered when a channel is declared inoperable and 37 Required Action A.1 directs entry into the Appropriate Condition. 38 Condition B is entered when Functions 1.a, 2.a, 1.b or 2.b are inoperable. 39 The Required Action is to declare the associated penetration flow path 40 incapable of automatic isolation and to recalculate the Drain Time without 41 taking credit for the automatic isolation of the affect pathway.

1 Condition C is entered when the steam dome pressure signal permissive 2 is inoperable. Inoperability of the permissive means that the injection 3 function cannot be manually initiated. The Required Action is to place the 4 permissive in the tripped condition within one hour. This enables manual 5 initiation of the injection function. The one hour allowance provides 6 sufficient time for the operator to place the channel in trip. 7 Condition D is entered when the Core Spray or Low Pressure Coolant 8 Injection Pump Discharge Flow - Low bypass functions are unavailable. 9 In this condition, the Required Action is to restore the channel to operable 10 status within 24 hours. The 24 hour is judged to be appropriate because 11 manual operation of the pumps and the minimum flow valves is still 12 available, but this is not the preferred condition. 13 Condition E is entered when the Required Action and associated 14 Completion Time for Condition C or D is not met. In this case, the 15 associated ECCS subsystem may not be capable of performing its 16 intended function, and is declared inoperable immediately. 17 18 o For BWR/6s: 19 Condition A is entered when a channel is declared inoperable and 20 Required Action A.1 directs entry into the Appropriate Condition. 21 Condition B is entered when the RHR System Isolation or RWCU System 22 Isolation functions are inoperable. The Required Action is to declare the 23 associated penetration flow path incapable of automatic isolation and to 24 recalculate the Drain Time without taking credit for the automatic isolation 25 of the affect pathway. 26 Condition C is entered when the Steam Dome Low Pressure Signal 27 (Injection Permissive) is inoperable. Inoperability of the permissive 28 means that the injection function cannot be manually initiated. The 29 Required Action is to place the permissive in the tripped condition within 30 one hour. This enables manual initiation of the injection function. The 31 one hour allowance provides sufficient time for the operator to place the 32 channel in trip. 33 Condition D is entered when the CST Level - Low function is inoperable. 34 The Required Action is to declare HPCS system inoperable and to align 35 the HPCS pump suction to the suppression pool within 1 hour. 36 Condition E is entered when the Reactor Vessel Water Level - High - 37 Level 8 function is inoperable. The Required Action is to declare HPCS 38 system inoperable within 1 hour and to restore the channel to operable 39 status within 24 hours. 40 Condition F is entered when the LPCS Pump Discharge Flow - Low 41 (Bypass), LPCI Pump A Discharge Flow - Low (Bypass), LPCI Pump B 42 and LPCI pump C Discharge Flow - Low (Bypass), HPCS Pump

1 Discharge Pressure - High (Bypass), HPCS System Flow rate - Low 2 (Bypass) or any of the required Manual functions are inoperable. The 3 Required Action is to restore the channel to operable status within 24 4 hours. The 24 hour is judged to be appropriate because manual 5 operation of the pumps and the minimum flow valves is still available, but 6 this is not the preferred condition. 7 Condition G is entered when the Required Action and associated 8 Completion Time for Condition C, D, E or F is not met. In this case, the 9 associated ECCS subsystem may not be capable of performing its 10 intended function, and is declared inoperable immediately. 11 12 The Surveillance Requirements section provides: 13 14

a description of the purpose of each Surveillance Requirement and the basis for the 15 surveillance frequency selected. For each function.

16 o A channel check is performed to verify that a gross failure of an instrument 17 channel has not occurred. Agreement criteria is established based on channel 18 instrument uncertainties and readability. The surveillance is performed once per 19 12 hours or in accordance with the Surveillance Frequency Control Program. 20 The frequency was selected based on operating experience that indicates 21 channel failure is rare. 22 o A channel functional test is performed to verify the channel is capable of 23 performing its intended function. The surveillance is performed once per 92 days 24 or in accordance with the Surveillance Frequency Control Program. The 25 frequency was selected based on operating experience that indicates channel 26 failure is rare. 27 o A logic system functional test is performed to verify proper functioning of the 28 required initiation logic for a channel. The surveillance is performed once per 18 29 months or in accordance with the Surveillance Frequency Control Program. The 30 frequency was selected because of the preference to perform the surveillance 31 under shutdown conditions. 32 33 The References section provides lists Regulatory Guide 1.105, Setpoints for Safety-Related 34 Instrumentation, and NEDE-770-06-2, Addendum to Bases for Changes to Surveillance Test 35 Intervals and Allowed Out-of-Service Times for Selected instrumentation Technical 36 Specifications. 37 38 The staff reviewed the revised bases to ensure the applicable criteria from 10 CFR 50.36 is 39 identified and justified. The revised bases state that the proposed LCO meets the Criterion 4 40 specified in 10 CFR 50.36(c)(2(ii) and provides a discussion of why this Criterion applies. The 41 reasons for the selection of each instrument function and required number of channels in the 42 LCO is described and the reason for the applicable modes is stated. Each instrument function

1 is necessary to support operability of the equipment required by LCO 3.5.2, and the applicable 2 modes are consistent with those in LCO 3.5.2. The purpose of each required action is 3 described. The purpose of each instrument surveillance and the basis for the performance 4 frequency is addressed, and appropriate references are cited. The staff concluded that each of 5 the elements of the Final Policy Statement were satisfactorily addressed. Therefore, the staff 6 determined that the revised Bases adhere to the guidance provided in the Final Policy 7 Statement. 8 9 3.2 EVALUATION OF B 3.5.2 10 11 The Background section provides: 12 13

a description of the reactor pressure vessel (RPV) design, which includes penetrations 14 below the top of active fuel.

15

a description of Safety Limit 2.1.1.3, which requires the RPV water level to be above the 16 top of active fuel.

17 18 The Applicable Safety Analyses, LCO and Applicability section provides: 19 20

a statement that indicates that water inventory control is required in Modes 4 and 5 to 21 protect Safety Limit 2.1.1.3 and a discussion that due to the reduced RCS pressure in 22 the shutdown condition, a very large break in the RCS is not postulated in the shutdown 23 condition.

24

an explanation that one low pressure ECCS injection/spray subsystem can maintain 25 adequate RPV level (explanation retained from previous Bases for LCO 3.5.2).

26

a description of why the LCO meets Criterion 4 specified in 10 CFR 50.36(c)(2(ii) as a 27 structure, system or component which operating experience has shown to be significant 28 to public health and safety.

29

an explanation that a Drain Time of 36 hours was selected for the LCO because this 30 time period is reasonable for the operator to identify and initiate remedial measures.

31

an explanation that the LCO also requires one low pressure ECCS injection/spray 32 subsystem to be operable and capable of being manually started so that it is available 33 should an unexpected drain event occur. The ECCS injection/spray subsystem may be 34 considered operable during alignment for decay heat removal because the restriction on 35 drain time ensures sufficient time is available to initiate LPCI operation to maintain 36 inventory if required.

37

an explanation of each Required Action and Completion Time contained in the Actions 38 Table 39 o Condition A is entered if the required ECCS injection/spray subsystem is 40 inoperable. The Required Action is to restore it to Operable status within 4 41 hours. The 4 hour Completion Time is judged to be appropriate because of the 42 controls on Drain Time and the low probably of a drain event occurring.

1 o Condition B is entered if the Required Action and Completion Time of Condition 2 A is not met. Condition B requires establishing an alternate method of water 3 injection capable of injecting without the use of offsite power, with attendant 4 necessary support equipment, and access to water inventory capable of 5 maintaining the RPV water level above TAF for 36 hours. The Completion Time 6 is immediately. 7 o Condition C is entered if the drain time is less than 36 hours but greater than or 8 equal to 8 hours. The Required Actions associated with this Condition ensure 9 the availability of compensatory actions should an unexpected drain event occur. 10 The Required Actions include actions to ensure the secondary containment 11 boundary can be restored in less than the Drain Time to provide a volume to 12 contain, dilute and process radioactive materials if an unexpected drain event 13 were to occur. The Actions also include verification of the ability to place the 14 Standby Gas Treatment System in service within the Drain Time to provide a 15 means to maintain the secondary containment volume at a negative pressure 16 and to filter the contents prior to release. A Completion Time of 4 hours was 17 selected for these verifications because this ensures that the actions are 18 completed well within the minimum Drain Time of 8 hours. 19 o Condition D is entered if the drain time is less than 8 hours. When the Drain 20 Time is this short, mitigating actions as well as compensatory actions are 21 needed. The Required Actions include an immediate action to establish an 22 additional method of water injection. This method is in addition to the injection 23 method required by the LCO. The Required Actions include the compensatory 24 actions of immediately establishing the secondary containment boundary, 25 verifying secondary containment penetrations can be isolated, and verifying that 26 at least one Standby Gas Treatment subsystem can be placed into operation. 27 These Actions are performed immediately because of the short Drain Time. 28 o Condition E is also applicable when Drain Time is less than 1 hour. The 29 Required Action is to immediately restore the Drain Time to greater than 36 30 hours. Restoration of the Drain Time to 36 hours is necessary to ensure there is 31 adequate time to perform mitigating actions should an unexpected drain event 32 occur. 33 34 The Surveillance Requirements section provides: 35 36

a description of the purpose of each Surveillance Requirement and the basis for the 37 surveillance frequency selected.

38 o The Drain Time is required to be verified to be 36 hours once per 12 hours or in 39 accordance with the Surveillance Frequency Control Program. This Surveillance 40 verifies the LCO for Drain Time is met. The frequency is selected based on the 41 fact that numerous indications of changes in RPV level are available to the

1 operator. Changes in RPV level would necessitate recalculation of the Drain 2 Time. 3 o The suppression pool water level for a required LPCI subsystem, or suppression 4 pool water level or Condensate Storage Tank level for a required core spray 5 subsystem is required to be verified to ensure net positive suction head is 6 available for the ECCS injection/spray subsystem required to be operable by the 7 LCO. This Surveillance is required to be performed once per 12 hours or in 8 accordance with the Surveillance Frequency Control Program. The frequency 9 was chosen based on the availability of other indications available in the Control 10 Room regarding suppression pool water level and Condensate Storage Tank 11 level. 12 o The surveillance requirements to verify the piping is full of water and to verify 13 correct valve alignment was retained from the existing TS 3.5.2. 14 o The required ECCS injection/spray subsystem is required to be operated through 15 its recirculation line for 10 minutes every 92 days or in accordance with the 16 Surveillance Frequency Control Program. This demonstrates that the subsystem 17 is capable for operation. The time limit is based on engineering judgement. The 18 frequency is consistent with other at-power testing. 19 o Verification that valves credited for automatically isolating a penetration flow path 20 actuate to a simulated actuation signal is required every 18 months or 21 accordance with the Surveillance Frequency Control Program. The frequency 22 was selected because it is desirable to perform the surveillance during shutdown 23 conditions to avoid operational transients. 24 o Verification that the required ECCS injection/spray subsystem actuate on a 25 manual actuation signal is required every 18 months or accordance with the 26 Surveillance Frequency Control Program. The frequency was selected because 27 it is desirable to perform the surveillance during shutdown conditions to avoid 28 operational transients. 29 30 The References section cites the applicable operating generic correspondence describing 31 operating experience related to inventory control during shutdown conditions. It lists Information 32 Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors 33 During Shutdown and Startup," November 1984; Information Notice 86-74, "Reduction of 34 Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986; Generic 35 Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation 36 in BWRs Pursuant to 10 CFR 50.54(F), " August 1992; NRC Bulletin 93-03, "Resolution of 37 Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993; 38 Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at 39 Millstone 1," July 1994; and General Electric Service Information Letter No. 388, "RHR Valve 40 Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6," February 1983. 41

1 The revised Bases (Volume 2 of NUREG 1434) for TS 3.5.2 for the BWR/6 differ from the 2 revised Bases for the BWR/4 TS. The major difference is that the LCO requires one ECCS 3 injection/spray subsystem to be operable. The ECCS injection/spray subsystem is either one of 4 the three Low Pressure Coolant Injection subsystems, one Low Pressure Core Spray System, 5 or one High Pressure Core Spray System. This difference is reflected throughout the Bases for 6 TS 3.5.2 in NUREG 1434, Volume 2. 7 8 The staff reviewed the revised bases to ensure the applicable criterion from 10 CFR 50.36 is 9 identified and justified, the reasons for the selection of each instrument function and required 10 number of channels in the LCO is described, the reason for the applicable modes is stated, the 11 purpose of each required action is described, and the purpose of each surveillance and the 12 basis for the performance frequency is addressed, and appropriate references are cited. The 13 staff concluded that each of the elements of the Final Policy Statement were satisfactorily 14 addressed. Therefore, the staff determined that the revised Bases adheres to the guidance 15 provided in the Final Policy Statement. 16 17 3.3 EVALUATION OF ADDITIONAL BASES CHANGES 18 19 3.3.1 B 3.3.5.1, ECCS Instrumentation 20 21 The Bases for several instrument functions related to automatic ECCS initiation were revised to 22 reflect a revised Applicability. The functions would no longer be required during Modes 4 and 5 23 because of the relatively slow transient of unexpected drain events. It is judged that sufficient 24 time is permitted for operators to mitigate such a transient. The instrumentation affected for 25 BWR/4s are Reactor Vessel Water Level - Low Low Low, Level 1; Low Pressure Coolant 26 Injection (LPCI) System Reactor Vessel Water Level - Low Low Low, Level 1; and Low 27 Pressure Coolant Injection Pump Start - Time Delay Relay. For BWR/6s, the affected 28 functions are LPCI A and LPCS: Reactor Vessel Water Level - Low Low Low, Level 1; LPCI 29 Pump A Start - Time Delay Relay; LPCI B and C: Reactor Vessel Water Level - Low Low Low, 30 Level 1; LPCI Pump B Start - Time Delay Relay; and HPCS Reactor Vessel Water Level Lo 31 Low, Level 2. 32 33 The remainder of the changes to the Bases for this LCO reflect the relocation of instrumentation 34 function requirements to the LCO 3.3.5.2. 35 36 3.3.2 B 3.3.6.1, Primary Containment Isolation Instrumentation 37 38 The Bases for the Shutdown Cooling Isolation, Reactor Vessel Water Level - Low, Level 3 were 39 revised to reflect the relocation of this requirement to LCO 3.3.5.2. 40 41 For BWR/6s, the function for Primary Containment Isolation, Containment and Drywell 42 Ventilation Exhaust Radiation - High is revised to reflect the deletion of this requirement.

1 2 3.3.3 B 3.5.3, RCIC System 3 4 The Applicability was revised to state that in Modes 4 and 5, RPV water inventory control is 5 provided by LCO 3.5.2. 6 7 3.3.4 B 3.6.1.3, PCIVs [Primary Containment Isolation Valves] 8 9 The Applicability was changed to replace the statement that certain valves are required to be 10 operable to prevent inadvertent drain down to state that certain valves are required to be 11 operable when the associated instrumentation is required to be operable. 12 13 The description of the Applicability and Actions is revised to delete the discussion of OPDRVs. 14 15 3.3.5 Other Affected Bases 16 17 The description of the Applicability, Actions and Applicable Safety Analyses Sections are 18 revised to delete the discussion of OPDRVs or inadvertent drain down of the vessel for the 19 following LCOs: 20 21

3.3.6.1 Primary Containment Isolation Instrumentation 22
3.5.1 ECCS - Operating 23
3.6.2.2 Suppression Pool Water Level 24
3.6.4.1 [Secondary] Containment 25
3.6.4.2 SCIVs [Secondary Containment Isolation Valves]

26

3.6.4.3 SGT System [Standby Gas Treatment]

27

3.7.4 MCREC [Main Control Room Environmental Control] System 28
3.7.5 Control Room AC [Air Conditioning] System 29
3.8.2 AC Sources - Shutdown 30
3.8.5 DC Sources - Shutdown 31
3.8.8 Inverters - Shutdown 32
3.8.10 Distribution Systems - Shutdown 33
3.10.1 Inservice Leak and Hydrostatic Testing Operation 34 35 The NRC staff reviewed the revised Bases sections and concluded that the revisions accurately 36 reflect the changes contained in the associated LCOs. The Applicability, Actions and 37 Applicable Safety Analyses sections continue to contain information regarding the reasons for 38 each of the LCO requirements. The staff determined that the Bases for the LCOs continue to 39 satisfy the guidance in the Final Policy Statement.

40 41

4.0 CONCLUSION

42

1 The NRC staff determined that TS Bases changes are consistent with the proposed TS changes 2 and provide an explanation and supporting information for each requirement in the specification. 3 Therefore, the staff determined that the revised Bases are consistent with the Commission's 4 Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, 5 dated July 2, 1993 (58 FR 39132). 6}}

v t e Letter Sequence Draft Approval
TAC:MF3487, Reactor Pressure Vessel Water Inventory Control (Approved, Closed)
Initiation Request Acceptance Administration Meeting Questions 8 December 2015 Answers 15 September 2015 14 March 2016 Results Approval, Approval Other:
MONTHYEAR2015-09-15 [Table View]

ML16175A394: Difference between revisions

Revision as of 17:28, 30 October 2019

Text

SUBJECT:

Dear Members of the Technical Specifications Task Force:

Enclosures:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 CONCLUSION

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 CONCLUSION

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ML16175A394: Difference between revisions

Revision as of 17:28, 30 October 2019

Text

SUBJECT:

Dear Members of the Technical Specifications Task Force:

Enclosures:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 CONCLUSION

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 CONCLUSION

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