Text

Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2
	ML17275A520
Person / Time
Site:	FitzPatrick
Issue date:	10/02/2017
From:	Jim Barstow; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	JAFP-17-0093, TSTF-542, Rev 2
	Download: ML17275A520 (142)
	v • d • e

200 Exelon Way Exelon Generation Kennett Square. PA 19348 www.exeloncorp.com JAFP-17-0093 October 2, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant, Unit 1 Renewed Facility Operating License Nos. DPR-59 NRG Docket Nos. 50-333 10 CFR 50.90

Subject:

Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2 Pursuant to 1 O CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGG) is submitting a request for an amendment to the Technical Specifications (TS) for James A. FitzPatrick Nuclear Power Plant (JAF), Unit 1. The proposed changes replace existing Technical Specifications (TS) requirements related to "operations with a potential for draining the reactor vessel" (OPDRVs) with new requirements on Reactor Pressure Vessel Water Inventory Control (RPV WIG) to protect Safety Limit 2.1.1.3. Safety Limit 2.1.1.3 requires reactor vessel water level to be greater than the top of active irradiated fuel. EGG has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 1 O CFR 50.92. The proposed changes have been reviewed by the JAF On-Site Safety Review Committee in accordance with the requirements of the JAF Quality Assurance Program. This amendment request contains no regulatory commitments.

Attachment 1 provides a description and assessment of the proposed changes. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides the existing Bases pages marked up to show the proposed changes (information only).

U.S. Nuclear Regulatory Commission Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-333 October 2, 2017 Page 2 EGC requests approval of the proposed amendment by August 16, 2018, in support of the Fall 2018 refueling outage. Once approved, the amendment shall be implemented prior to the next refueling outage. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), EGC is notifying the State of New York of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Christian Williams at (61 O) 765-5729.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of October 2017. Respectfully, Director -Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Evaluation of Proposed Changes 2. Markup of Technical Specifications Pages 3. Markup of Technical Specifications Bases Pages (For Information Only) cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, JAF USNRC Project Manager, JAF w/ attachments II ATTACHMENT 1 Description and Assessment of Proposed Changes James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License Nos. DPR-59 Docket Nos. 50-333

Subject:

Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2

1.0 DESCRIPTION

2.0 ASSESSMENT

2.1 Applicability

of Published Safety Evaluation

2.2 Variations

3.0 REGULATORY

ANALYSIS 3.1 NO SIGNIFICANT HAZARDS CONSIDERATION

4.0 ENVIRONMENTAL

CONSIDERATION

5.0 REFERENCES

Description and Assessment of Proposed Changes Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-333

1.0 DESCRIPTION

Attachment 1 Page 1 of 7 Exelon Generation Company, LLC (EGC), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-59 James A. FitzPatrick Nuclear Power Plant (JAF). The proposed changes replace existing TS requirements related to "operations with a potential for draining the reactor vessel" (OPDRVs) with new requirements on Reactor Pressure Vessel (RPV) Water Inventory Control to protect Safety Limit 2.1.1.3. Safety Limit 2.1.1.3 requires reactor vessel water level to be greater than the top of active irradiated fuel. 2.0 ASSESSMENT

2.1 Applicability

of Published Safety Evaluation EGC has reviewed the safety evaluation provided to the Technical Specifications Task Force on December 20, 2016 (Reference 1 ), as well as the information provided in TSTF-542 (Reference 2). EGC has concluded that the justifications presented in TSTF-542 and the safety evaluation prepared by the Nuclear Regulatory Commission (NRC) staff are applicable to JAF and justify this amendment for the incorporation of the changes to the JAF TS. The following JAF TS reference or are related to OPDRVs and are affected by the proposed changes: 3.3.5.1 3.3.6.1 3.3.6.2 3.3.7.1 3.5.2 3.6.1.3 3.6.4.1 3.6.4.2 3.6.4.3 3.7.3 3.7.4 3.8.2 3.8.5 3.8.8 Emergency Core Cooling System (ECCS) Instrumentation Primary Containment Isolation Instrumentation Secondary Containment Isolation Instrumentation Control Room Emergency Ventilation Air Supply (CREVAS) System Instrumentation ECCS -Shutdown Primary Containment Isolation Valves (PCIVs) Secondary Containment Secondary Containment Isolation Valves (SCIVs) Standby Gas Treatment (SGT) System Control Room Emergency Ventilation Air Supply (CREVAS) System Control Room AC System AC Sources -Shutdown DC Sources -Shutdown Distribution Systems -Shutdown 2.2 Variations EGC is proposing the following variations from the TS changes described in TSTF-542.

These variations do not affect the applicability of TSTF-542 or the NRC staff's safety evaluation to the proposed license amendment.

2.2.1 The JAF TS utilize different numbering and titles than the Standard Technical Specifications (STS) on which TSTF-542 was based. The differences are administrative and do not affect the applicability of TSTF-542 to the JAF TS.

Description and Assessl')1ent of Proposed Changes Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-333 Attachment 1 Page 2 of 7

STS Table 3.3.5.1-1 Function 1.c, 2.c, and 2.d, in part, are titled "Reactor Steam Dome Pressure -Low. In JAF TS, Function 1.c, 2.c, and 2.d, in part, are titled "Reactor Pressure -Low.

STS Section 3.3.7.1 is titled "Main Control Room Environmental Control System Instrumentation".

The equivalent section in JAF TS is titled "Control Room Emergency Ventilation Air Supply (CREVAS) System Instrumentation".

STS Section 3.7.4 is titled "Main Control Room Environmental Control System". The equivalent section in JAF TS is titled "Control Room Emergency Ventilation Air Supply (CREVAS) System".

The STS TS LCO 3.8.8, "Inverters

-Shutdown", does not exist in the JAF TS. JAF TS LCO 3.8.8, "Distribution Systems -Shutdown" will be revised consistent with STS LCO 3.8.10 "Distribution Systems -Shutdown".

This variation is editorial in nature.

The STS Section 3.8.1 O is titled "Distribution Systems -Shutdown".

The equivalent JAF TS section is numbered 3.8.8. 2.2.2 The JAF TS contain a Surveillance Frequency Control Program. Therefore, the Surveillance Requirements (SR) Frequencies for Specifications 3.3.5.2 and 3.5.2 are "In accordance with the Surveillance Frequency Control Program".

This variation is editorial in nature. 2.2.3 The JAF TS contain NOTES in SR 3.5.1.2 and SR 3.5.2.4 regarding alignment of the Low Pressure Coolant Injection mode that are the same as the NOTES in STS LCOs 3.5.1 and 3.5.2. JAF will relocate these NOTES from the SRs to the LCO section. This has no effect on the adoption of the TSTF-542 and increases consistency between the JAF TS and STS. This variation is editorial in nature. 2.2.4 The JAF TS Table 3.3.5.1-1 contains notes (a) thru (d). The STS Table 3.3.5.1-1 contains notes (a) thru (f). The deletion of note (a) from the STS and JAF TS will result in renaming the remaining notes (a) thru (c) for JAF as opposed to (a) thru (e) for the STS. This variation is editorial in nature. 2.2.5 The JAF TS 3.3.7.1 APPLICABILITY includes "During operations with a potential for draining the reactor vessel." This applicability is captured in the STS as note (a) in Table 3.3.7.1-1.

As this applicability is being removed, this variation is editorial in nature. 2.2.6 There are STS requirements on which TSTF-542 is based, related to "manual initiation," that do not appear in the JAF TS. STS Table 3.3.5.1-1 contains Functions 1.e and 2.h, Manual Initiation, for CS and LPCI, respectfully.

The "manual initiation" logic does not exist in the JAF design. These functions, as well as the related TSTF-542 surveillance requirements, SR 3.3.5.2.3 and SR 3.5.2.8, do not apply to JAF. As an alternative, EGC proposes that TS 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control," include an SR 3.5.2.8 to verify that the JAF required ECCS injection/spray subsystem can be manually operated through the manipulation of subsystem components from the Main Control Room. The manual operation of the required ECCS injection/spray subsystem for the control of reactor cavity or RPV inventory is a relatively simple evolution and involves the Description and Assessment of Proposed Changes Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-333 Attachment 1 Page 3 of 7 manipulation of a small number of components.

These subsystem alignments can be performed by licensed operators from the Main Control Room. This alternative is justified by the fact that a draining event is a slow evolution when compared to a design basis loss of coolant accident, which is assumed to occur at full power, and thus, there is adequate time to take manual actions (i.e., hours versus minutes).

Adequate time to take action is assured since the proposed TS 3.5.2, Condition E, prohibits plant conditions that result in drain times that are less than one hour. Therefore, there is sufficient time for the licensed operators to take manual action to stop an unanticipated draining event, and to manually start an ECCS injection/spray subsystem or the additional method of water injection.

Since the ECCS injection/spray subsystem can be placed in service using manual means in a short period of time (i.e., within the time frames assumed in the development of TSTF-542), using controls and indications that are readily available in the Main Control Room, manual operation of the required subsystem would be an equivalent alternative to system initiation via manual initiation logic. Current SR 3.5.1.6 and SR 3.5.2.4 manually operate the ECCS injection/spray pumps to verify each required ECCS injection/spray pump develops the specified flow rate against a system head corresponding to the specified reactor pressure at a frequency specified by the lnservice Testing (IST} Program. The IST Program requires the ECCS injection/spray subsystems motor operated injection valves, minimum flow valves and test flow path valves (with the exception of the CS test flow path valves) be cycled to demonstrate operability and compliance with IST stroke time requirements at a frequency specified by the IST Program. The CS test flow path valves are part of the IST Program but do not have stroke time requirements.

The CS valves are cycled for position indication verification only. The manual operation of the ECCS injection/spray subsystem to demonstrate operability required by the proposed SR 3.5.2.7 is equivalent to the testing that is presently required to be performed on the ECCS injection/spray subsystems.

This variation is technical in nature due to plant design differences and similar to variations described in the license amendment requests submitted for Dresden Nuclear Power Station, Edwin I. Hatch Nuclear Plant, and Cooper Nuclear Power Station. 2.2.7 The JAF TS contain requirements that differ from the STS on which TSTF-542 was based, but are encompassed in the TSTF-542 justification.

The JAF TS 3.3.6.1 Primary Containment Isolation Instrumentation Function 5e, Reactor Water Cleanup (RWCU) System Isolation, occurs at Reactor Water Vessel Level-Low, Level 3. The STS isolation signal occurs at Reactor Water Vessel Level -Low Low, Level 2. The intent of the TSTF is to change the applicability of this function, but does not change the setpoint or allowable value. This variation is technical however is consistent with the intent of TSTF 542.

JAF TS Table 3.3.5.1-1 contains Function 1.d, "Core Spray Pump Start -Time Delay Relay", that does not appear in the STS table. The Function is required to be operable in Modes 1, 2, 3, 4 and 5. Modes 4 and 5 are Description and Assessment of Proposed Changes Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-333 Attachment 1 Page 4 of 7 being deleted from this Function as this is related to automatic ECCS initiation.

This is the same justification that is provided in the TSTF for STS Table 3.3.5.1-1, Function 2.f, "Low Pressure Coolant Injection Pump Start -Time Delay Relay". This variation is technical in nature and is justified by the discussion in Section 3.4.1 of the TSTF-542 justification.

JAF TS Table 3.3.5.1-1 contains Function 1.f, "Core Spray Pump Discharge Pressure -High (Bypass)", that does not appear in the STS table. The Function is required to be operable in Modes 1, 2, 3, 4 and 5. The Function is required for protection of the low pressure ECCS pump from overheating when the associated injection valve is not fully open, similar to STS Function 1.d and 2.g, "Core Spray and Low Pressure Coolant Injection Pump Discharge Flow-Low (Bypass)".

Modes 4 and 5 of JAF TS Function 1.f are being moved to the new TS 3.3.5.2 as Function 1.c. Justification for this move is consistent with the justification provided in TSTF-542 Section 3.4.2 for STS Functions 1.d and 2.g from Table 3.3.5.1-1.

2.2.8 JAF TS 3.6.1.3, PCIVs, Condition G applies to Modes 4 and 5. In the STS the corresponding applicable condition is Condition H, therefore the required action to Initiate Action to suspend OPDRVs applies to G.1 for JAF as opposed to H.1 for the STS. This variation is administrative in nature. 2.2.9 TSTF-542 Rev 2 Eliminated Required Action (RA) J.2 from TS 3.3.6.1. Due to editorial errors which occurred between Rev O and Rev 1, the associated BASES pages and justification for this deletion were removed from the TSTF. They have been included in this submittal as a variation from Rev 2 of TSTF-542 with the following justification:

JAF TS 3.3.6.1 RA J.2 is triggered by Function 6.b from Table 3.3.6.1 (Shutdown Cooling System Isolation:

Reactor Vessel Water Level -Low, Level 3). The direction to initiate action to close the Residual Heat Removal (RHR) Shutdown Cooling (SOC) isolation valves in Mode 3 is in direct conflict with TS 3.4.7 (RHR Shutdown Cooling System -Hot Shutdown) which requires two RHR SOC subsystems to be operable, and if not, to take immediate action to restore an RHR SOC subsystem to operable status (RA A.1 ). Therefore, Required Action J.2 is being deleted. Removing Required Action J.2 is also appropriate to protect plant safety. As discussed in the Bases to Function 6.b, the Reactor Vessel Level -Low, Level 3 Function associated with the RHR SOC System is not directly assumed in the safety analyses because a break of the RHR Shutdown Cooling System is bounded by breaks of the reactor recirculation system and main steam lines. Specifically, for the RHR SOC isolation valves to be open in Mode 3, reactor steam dome pressure would need to be below the RHR cut-in permissive pressure.

Should a LOCA occur inside Primary Containment, TS 3.5.1 explicitly credits the manual closing of the RHR SOC isolation valves and alignment of RHR in the LPCI mode. Similarly, if the break is on the RHR SOC system outside Primary Containment, credit can still be given for manual closing of the RHR SOC isolation valves and alignment of an intact LPCI loop. In either case, core uncovery would not result and Description and Assessment of Proposed Changes Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-333 radiological consequences are bounded by the LOCA and MSLB accidents.

Attachment 1 Page 5 of 7 For these reasons, it is not critical to immediately initiate action to close the AHR SOC isolation valves (RA J.2) if Function 6.b. 2.2.10 TSTF-542 Rev 2 Enclosure 7, page 3.8.2-3 (SR 3.8.2-1 NOTE 2), contains an editorial error which is a reference to LCO 3.5.2, "ECCS -Shutdown".

This is being revised in the JAF NOTE 2 of SR 3.8.2-1 to reference LCO 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control." This variation is consistent with the intent of the TSTF and is administrative in nature. 3.0 REGULATORY ANALYSIS 3.1 No Significant Hazards Determination Exelon Generation Company, LLC (EGC), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-59 for the James A. FitzPatrick Nuclear Power Station. EGC requests adoption of TSTF-542 "Reactor Pressure Vessel Water Inventory Control," which is an approved change to the Standard Technical Specifications (STS), into the JAF TS. The proposed amendment replaces the existing requirements in the TS related to "operations with a potential for draining the reactor vessel" (OPDRVs) with new requirements on Reactor Pressure Vessel (RPV) Water Inventory Control (WIC) to protect Safety Limit 2.1.1.3. Safety Limit 2.1.1.3 requires reactor vessel water level to be greater than the top of active irradiated fuel. EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 1 O CFR 50.92, "Issuance of amendment," as discussed below: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No. The proposed changes replace existing TS requirements related to OPDRVs with new requirements on RPV WIC that will protect Safety Limit 2.1.1.3. Draining of RPV water inventory in Mode 4 (i.e., cold shutdown) and Mode 5 (i.e., refueling) is not an accident previously evaluated, and therefore replacing the existing TS controls to prevent or mitigate such an event with a new set of controls has no effect on any accident previously evaluated.

RPV water inventory control in Mode 4 or Mode 5 is not an initiator of any accident previously evaluated.

The existing OPDRV controls or the proposed RPV WIC controls are not mitigating actions assumed in any accident previously evaluated.

The proposed changes reduce the probability of an unexpected draining event (which is not a previously evaluated accident) by imposing new requirements on the limiting time in which an unexpected draining event could result in the reactor vessel water level dropping to the top of the active fuel (TAF). These controls require cognizance of the plant configuration and control of configurations with unacceptably short drain times.

Description and Assessment of Proposed Changes Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-333 Attachment 1 Page 6 of 7 These requirements reduce the probability of an unexpected draining event. The current TS requirements are only mitigating actions and impose no requirements that reduce the probability of an unexpected draining event. The proposed changes reduce the consequences of an unexpected draining event (which is not a previously evaluated accident) by requiring an Emergency Core Cooling System (ECCS) subsystem to be operable at all times in Modes 4 and 5. The current TS requirements do not require any water injection systems, ECCS or otherwise, to be Operable in certain conditions in Mode 5. The change in requirement from two ECCS subsystems to one ECCS subsystem in Modes 4 and 5 does not significantly affect the consequences of an unexpected draining event because the proposed Actions ensure equipment is available within the limiting drain time that is as capable of mitigating the event as the current requirements.

The proposed controls provide escalating compensatory measures to be established as calculated drain times decrease, such as verification of a second method of water injection and additional confirmations that containment and/or filtration would be available if needed. The proposed changes reduce or eliminate some requirements that were determined to be unnecessary to manage the consequences of an unexpected draining event, such as automatic initiation of an ECCS subsystem and control room ventilation.

These changes do not affect the consequences of any accident previously evaluated since a draining event in Modes 4 and 5 is not a previously evaluated accident and the requirements are not needed to adequately respond to a draining event. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response:

No. The proposed changes replace existing TS requirements related to OPDRVs with new requirements on RPV WIC that will protect Safety Limit 2.1.1.3. The proposed changes will not alter the design function of the equipment involved.

Under the proposed changes, some systems that are currently required to be operable during OPDRVs would be required to be available within the limiting drain time or to be in service depending on the limiting drain time. Should those systems be unable to be placed into service, the consequences are no different than if those systems were unable to perform their function under the current TS requirements.

The event of concern under the current requirements and the proposed changes are an unexpected draining event. The proposed changes do not create new failure mechanisms, malfunctions, or accident initiators that would cause a draining event or a new or different kind of accident not previously evaluated or included in the design and licensing bases. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Description and Assessment of Proposed Changes Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-333 Response:

No. Attachment 1 Page 7 of 7 The proposed changes replace existing TS requirements related to OPDRVs with new requirements on RPV WIC. The current requirements do not have a stated safety basis and no margin of safety is established in the licensing basis. The safety basis for the new requirements is to protect Safety Limit 2.1.1.3. New requirements are added to determine the limiting time in which the RPV water inventory could drain to the top of the fuel in the reactor vessel should an unexpected draining event occur. Plant configurations that could result in lowering the RPV water level to the T AF within one hour are now prohibited.

New escalating compensatory measures based on the limiting drain time replace the current controls.

The proposed TS establish a safety margin by providing defense-in-depth to ensure that the Safety Limit is protected and to protect the public health and safety. While some less restrictive requirements are proposed for plant configurations with long calculated drain times, the overall effect of the change is to improve plant safety and to add safety margin. Therefore, the proposed changes do not involve a significant reduction in a margin of safety. Based on the above, EGC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 1 O CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL

CONSIDERATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 1 O CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 1 O CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

5.0 REFERENCES

1. TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," dated December 29, 2016. 2. Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" (TAC No. MF3487) ADAMS Accession No. ML 163438065 ii 1.1-2a* 3.3.5.1-1 3.3.5.1-2 3.3.5.1-4 3.3.5.1-8 3.3.5.1-9 3.3.5.1-10 3.3.5.1-11 3.3.5.1-12 3.3.5.2-1

3.3.5.2-2*

3.3.5.2-3*

3.3.5.3-1*

3.3.5.3-2*

New TS Page ATTACHMENT2 Markup of Technical Specifications Pages James A. FitzPatrick Nuclear Power Station Renewed Facility Operating License Nos. DPR-59 Docket Nos. 50-333 Revised Technical Specifications Pages Unit 1 TS Pages 3.3.5.3-3*

3.3.5.3-4*

3.3.6.1-3 3.3.6.1-10 3.3.6.2-4 3.3.7.1-1 3.5.1-1 3.5.1-4 3.5.2-1 3.5.2-2 3.5.2-3 3.5.2-4 3.5.2-5 3.5.3-1 3.6.1.3-6

3.6.4.1-1 3.6.4.1-2 3.6.4.2-1 3.6.4.2-3 3.6.4.3-1 3.6.4.3-2 3.7.3-1 3.7.3-2 3.7.3-3 3.7.4-1 3.7.4-2 3.8.2-2 3.8.2-3 3.8.2-4 3.8.5-2 3.8.8-2

TABLE OF CONTENTS

ECCS Instrumentation 3.3.5.1 JAFNPP 3.3.5.1-1 Amendment 274XXX 3.3 INSTRUMENTATION 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation LCO 3.3.5.1 The ECCS instrumentation for each Function in Table 3.3.5.1

-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.1

-1. ACTIONS - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - Separate Condition entry is allowed for each channel.

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - CONDITION REQUIRED ACTION COMPLETION TIME A.One or more channels inoperable

. A.1 Enter the Condition referenced in Table 3.3.5.1

-1 for the channel.

Immediately B.As required by Required Action A.1 and referenced in Table 3.3.5.1

-1. B.1 - - - - - -NOTE S- - - - -- 1. Only applicable in MODES 1, 2, and 3. 2. Only applicable for Functions 1.a, 1.b, 2.a, and 2.b. - - - - - - - - - - - - - - - - Declare supported feature(s) inoperable when its redundant feature ECCS initiation capability is inoperable.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of initiation capability for feature(s) in both divisions.

AND (continued)

ECCS Instrumentation 3.3.5.1 JAFNPP 3.3.5.1-2 Amendment 274XXX ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. (continued)

B.2 - - - - - -NOTE - - - - - - Only applicable for Functions 3.a and 3.b. - - - - - - - - - - - - - - - - - Declare High Pressure Coolant Injection (HPCI) System inoperable.

AND B.3 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of HPCI initiation capability 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months C.As required by Required Action A.1 and referenced in Table 3.3.5.1

-1. C.1 - - - - - -NOTE S- - - - - - 1. Only applicable in MODES 1, 2, and 3. 2. Only applicable for Functions 1.c, 1.d, 2.c, 2.d, and 2.f.

- - - - - - - - - - - - - - - - Declare supported feature(s) inoperable when its redundant feature ECCS initiation capability is inoperable.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of initiation capability for feature(s) in both divisions.

AND C.2 Restore channel to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ECCS Instrumentation 3.3.5.1 JAFNPP 3.3.5.1-4 Amendment 274XXX ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.As required by Required Action A.1 and referenced in Table 3.3.5.1

-1. E.1 - - - - - -NOTE S- - - - - - 1. Only Applicable in MODES 1, 2, and 3. 2. Only applicable for Functions 1.e, 1.f, and 2.g. - - - - - - - - - - - - - - - - - Declare supported feature(s) inoperable when its redundant feature ECCS Initiation capability Is inoperable AND E.2 Restore channel to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of initiation capability for subsystems in both divisions.

7 days (continued)

ECCS Instrumentation 3.3.5.1 JAFNPP 3.3.5.1-8 Amendment 274XXX

ECCS Instrumentation 3.3.5.1 JAFNPP 3.3.5.1-9 Amendment 274XXX

ECCS Instrumentation 3.3.5.1 JAFNPP 3.3.5.1-10 Amendment 274XXX

ECCS Instrumentation 3.3.5.1 JAFNPP 3.3.5.1-11 Amendment 274XXX

ECCS Instrumentation 3.3.5.1 JAFNPP 3.3.5.1-12 Amendment 274XXX

ACTIONS (continued)

Primary Containment Isolation Instrumentation 3.3.6.1 JAFNPP 3.3.6.1-10 Amendment 298 XXX Table 3.3.6.1-1 (page 5 of 6) Primary Containment Isolation Instrumentation

FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER TRIP SYSTEM CONDITIONS REFERENCED FROM REQUIRED ACTION C.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 5. Reactor Water Cleanup (RWCU) System Isolation

a. RWCU Suction Line Penetration Area Temperature

-High

1,2,3

1

F

SR 3.3.6.1.3

SR 3.3.6.1.7

144F b. RWCU Pump Area Temperature

-High 1,2,3

1 per room F

SR 3.3.6.1.3 SR 3.3.6.1.7

165F for Pump Room A and 175F for Pump Room B c. RWCU Heat Exchanger Room Area Temperature

-High 1,2,3 1 F SR 3.3.6.1.3 SR 3.3.6.1.7 155 F d. SLC System Initiation 1,2 2(d) I SR 3.3.6.1.7 NA e. Reactor Vessel Water Level

-Low (Level

3) 1,2,3 2 F SR 3.3.6.1.1 SR 3.3.6.1.2

SR 3.3.6.1.4

SR 3.3.6.1.5 SR 3.3.6.1.7 177 inches

f. Drywell Pressure

-High 1,2,3 2 F SR 3.3.6.1.1 SR 3.3.6.1.2

SR 3.3.6.1.4

SR 3.3.6.1.5 SR 3.3.6.1.7 2.7 psig 6. Shutdown Cooling System Isolation

a. Reactor Pressure

-High 1,2,3 1

F SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.7

74 psig b. Reactor Vessel Water Level

-Low (Level 3) 3,4,5 2(e) J

SR 3.3.6.1.7 177 inches

(continued)

(d) SLC System Initiation only inputs into one of the two trip systems and only isolates one valve in the RWCU suction and return line.

(e) Only one trip system required in MODES 4 and 5 when RHR Shutdown Cooling System integrity maintained.

ECCS - Operating 3.5.1

JAFNPP 3.7.4-1 Amendment 290 XXX

ii 8 3.3.4.1-4 8 3.3.5.1-8 8 3.3.5.1-10 8 3.3.5.1-12 8 3.3.5.1-14 8 3.3.5.1-26 8 3.3.5.1-28 8 3.3.5.1-31 8 3.3.5.2-1*

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New TS Page ATTACHMENT 3 Markup of Technical Specification Bases Pages James A. FitzPatrick Nuclear Power Station Renewed Facility Operating License Nos. DPR-59 Docket Nos. 50-333 Revised Technical Specification Bases Pages Unit 1 TS Bases Pages 8 3.3.5.3-9 8 3.3.5.3-10 8 3.3.5.3-11 8 3.3.5.3-12 8 3.3.6.1-7 8 3.3.6.1-22 8 3.3.6.1-23 8 3.3.6.1-29 8 3.3.6.2-4 8 3.3.7.1-3 8 3.5.1-1 8 3.5.1-6 8 3.5.2-1* 8 3.5.2-2* 8 3.5.2-3* 8 3.5.2-4* 8 3.5.2-5* 83.5.2-6*

8 3.5.2-7* 8 3.5.2-8* 8 3.5.2-9* 8 3.5.2-10*

8 3.5.3-1 8 3.5.3-2 8 3.6.1.3-4 8 3.6.1.3-10 8 3.6.2.2-2 8 3.6.4.1-2 8 3.6.4.1-3 8 3.6.4.2-2 8 3.6.4.2-5 8 3.6.4.3-3 8 3.6.4.3-4 8 3.6.4.3-5 8 3.7.3-3 8 3.7.3-5 8 3.7.3-6 8 3.7.4-2 8 3.7.4-3 8 3.7.4-4 8 3.7.4-5 8 3.8.2-1 8 3.8.2-3 8 3.8.2-4 8 3.8.2-5 8 3.8.2-6 8 3.8.5-1 8 3.8.5-2 8 3.8.5-3 8 3.8.5-4 8 3.8.8-1 8 3.8.8-2 8 3.8.8-3 8 3.10.1-2

TABLE OF CONTENTS

JAFNPP B 3.3.4.1-4 Revision 0XX ATWS RPT Instrumentation B 3.3.4.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY a.Reactor Vessel Water Level - Low Low (Level 2) (continued)

Four channels of Reactor Vessel Water Level - Low Low (Level 2), with two channels in each trip system, are available and required to be OPERABLE to ensure that no single instrument failure can preclude an ATWS-RPT from this Function on a valid signal. The Reactor Vessel Water Level - Low Low (Level 2) Allowable Value is chosen so that the system will not be initiated after a Level 3 scram with feedwater still available, and also provides an opportunity for the high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) systems to recover water level if feedwater is not available. The Allowable Value is referenced from a level of water 352.56 inches above the lowest point in the inside bottom of the RPV and also corresponds to the top of a 144 inch fuel column (Ref. 3).

The HPCI, RCIC and ATWS-RPT initiation functions (as described in Table 3.3.5.1-1, Function 3.a; Table 3.3.5.23-1. Function 1; and LCO 3.3.4.1.a including SR 3.3.4.1.4. respectively) describe the reactor vessel water level initiation function as "Low Low (Level 2)." The Allowable Values associated with the HPCI and RCIC initiation function is different from the Allowable Value associated with the ATWS-RPT initiation function as the ATWS function has a separate analog trip unit. Nevertheless, consistent with the nomenclature typically used in design documents, the "Low Low (Level 2)" designation is retained in describing each of these three initiation functions.

b.Reactor Pressure - High

Excessively high RPV pressure may rupture the RCPB. An increase in the RPV pressure during reactor operation compresses the steam voids and results in a positive reactivity insertion. This increases neutron flux and THERMAL POWER, which could potentially result in fuel failure and overpressurization. The Reactor Pressure-High Function initiates an RPT for transients that result in a pressure increase, counteracting the pressure increase by rapidly reducing core power generation. For the overpressurization event, the RPT (continued)

JAFNPP B 3.3.5.1-8 Revision 0XX ECCS Instrumentation B 3.3.5.1 BASES BACKGROUND Emergency Diesel Generators (continued) associated ECCS initiation logic. Upon receipt of an ECCS initiation signal, each EDG is automatically started, is ready to load in approximately 10 seconds, and will run in standby conditions (rated voltage and speed, with the EDG output breaker open). The EDGs will only energize their respective emergency buses if a loss of preferred power occurs. (Refer to Bases for LCO 3.3.8.1.)

APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY The actions of the ECCS are explicitly assumed in the safety analyses of References 1, 2, 3, and 4. The ECCS is initiated to preserve the integrity of the fuel cladding by limiting the post LOCA peak cladding temperature to less than the 10 CFR 50.46 limits.

ECCS instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 5). Certain instrumentation Functions are retained for other reasons and are described below in the individual Functions discussion.

The OPERABILITY of the ECCS instrumentation is dependent upon the OPERABILITY of the individual instrumentation channel Functions specified in Table 3.3.5.1-1. Each Function must have a required number of OPERABLE channels, with their setpoints within the specified Allowable Values, where appropriate. The actual setpoint is calibrated consistent with applicable setpoint methodology assumptions.

Table 3.3.5.1-1 is modified by two a footnotes which. Footnote (a) is added to clarify that the associated functions are required to be OPERABLE in MODES 4 and 5 only when their supported ECCS are required to be OPERABLE per LCO 3.5.2, "ECCS-Shutdown." Footnote (b) is added to show that certain ECCS instrumentation Functions also perform EDG initiation.

Allowable Values are specified for each ECCS Function specified in the table. Nominal trip setpoints are specified in the setpoint calculations. The nominal setpoints are selected to ensure that the setpoints do not exceed the Allowable Value between CHANNEL CALIBRATIONS.

Operation with a trip setpoint less conservative than the nominal trip setpoint, but within its Allowable Value, is acceptable. A channel is inoperable if its actual trip setpoint is not within its required Allowable Value. Trip setpoints are those predetermined values of output at which an action should take place. The setpoints are compared to the actual process parameter (e.g., reactor vessel water (continued)

JAFNPP B 3.3.5.1-10 Revision 0XX ECCS Instrumentation B 3.3.5.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY 1.a, 2.a. Reactor Vessel Water Level - Low Low Low (Level 1)

(continued) cooling function of the ECCS, along with the scram action of the Reactor Protection System (RPS), ensures that the fuel peak cladding temperature remains below the limits of 10 CFR 50.46.

Reactor Vessel Water Level - Low Low Low (Level 1) signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.

The Reactor Vessel Water Level - Low Low Low (Level 1) Allowable Value is chosen to allow time for the low pressure core flooding systems to activate and provide adequate cooling. The Allowable Value is referenced from a level of water 352.56 inches above the lowest point in the inside bottom of the RPV and also corresponds to the top of a 144 inch fuel column (Ref. 6).

Thus, four channels of the CS and LPCI Reactor Vessel Water Level - Low Low Low (Level 1) Function are only required to be OPERABLE when the ECCS are required to be OPERABLE to ensure that no single instrument failure can preclude ECCS initiation. Per Footnote (a) to Table 3.3.5.1-1, this ECCS Function is only required to be OPERABLE in MODES 4 and 5 whenever the associated ECCS is required to be OPERABLE per LCO 3.5.2. Refer to LCO 3.5.1 and LCO 3.5.2 for Applicability Bases for the low pressure ECCS subsystems; LCO 3.8.1 and LCO 3.8.2, "AC Sources-Shutdown," for Applicability Bases for the EDGs.

1.b, 2.b. Drywell Pressure - High

High pressure in the drywell could indicate a break in the reactor coolant pressure boundary (RCPB). The low pressure ECCS and associated EDGs are initiated upon receipt of the Drywell Pressure - High Function in order to minimize the possibility of fuel damage. The EDGs are initiated from Function 1.b and 2.b. The Drywell Pressure - High Function, along with the Reactor Water Level - Low Low Low (Level 1) Function, is directly assumed in the analysis of the recirculation line break (Refs. 1, 2, and 4). The core cooling function of the ECCS, along with the scram action of the RPS, ensures that the fuel peak cladding temperature remains below the limits of 10 CFR 50.46.

(continued)

JAFNPP B 3.3.5.1-12 Revision 0XX ECCS Instrumentation B 3.3.5.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY 1.c, 2.c. Reactor Pressure - Low (Injection Permissive) (continued)

Four channels of Reactor Pressure - Low Function are only required to be OPERABLE when the ECCS is required to be OPERABLE to ensure that no single instrument failure can preclude ECCS initiation. Per Footnote (a) to Table 3.3.5.1-1, this ECCS Function is only required to be OPERABLE in MODES 4 and 5 whenever the associated ECCS is required to be OPERABLE per LCO 3.5.2. Refer to LCO 3.5.1 and LCO 3.5.2 for Applicability Bases for the low pressure ECCS subsystems.

1.d, 2.f. Core Spray and Low Pressure Coolant Injection Pump Start-Time Delay Relay The purpose of these time delay relays is to stagger the start of the CS and LPCI pumps to enable sequential loading of the appropriate AC source. The CS and LPCI Pump Start-Time Delay Relays are assumed to be OPERABLE in the accident analyses requiring ECCS initiation. That is, the analyses assumes that the pumps will initiate when required and no excess loading of the power sources will occur.

There are two CS and four LPCI Pump Start-Time Delay Relays, one in each of the CS and LPCI pump start circuits. While each time delay relay is dedicated to a single pump start circuit, a single failure of a CS or LPCI Pump Start-Time Delay Relay could result in the failure of a CS pump and both the LPCI pumps powered from the same emergency bus to perform their intended function within the assumed ECCS response time (e.g., as in the case where one inoperable time delay relay results in more than one pump starting at nearly the same time). In the worst case this would still leave the other three low pressure ECCS pumps OPERABLE; thus, the single failure of one instrument does not preclude ECCS initiation. The Allowable Values for the CS and LPCI Pump Start-Time Delay Relays are chosen to be short enough so that ECCS operation is within the time period assumed in the accident analyses.

Each CS and LPCI Pump Start-Time Delay Relay Function is required to be OPERABLE only when the associated CS and LPCI subsystem is required to be OPERABLE. Per Footnote (a) to Table 3.3.5.1-1, this ECCS Function is only required to be OPERABLE in MODES 4 and 5 whenever the associated ECCS is required to be OPERABLE per LCO 3.5.2. Refer to LCO 3.5.1 and LCO 3.5.2 for Applicability Bases for the CS and LPCI subsystems.

(continued)

JAFNPP B 3.3.5.1-14 Revision 0XX ECCS Instrumentation B 3.3.5.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY 1.e, 2.g, 1.f. Core Spray and Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass), Core Spray Pump Discharge Pressure - High (Bypass) (continued) condition that results in a discharge pressure permissive when the CS pump is aligned for injection and the pump is not running.

Each channel of Pump Discharge Flow-Low Function (two CS channels and four LPCI channels) and each channel of Core Spray Pump Discharge Pressure-High (Bypass) are only required to be OPERABLE when the associated ECCS is required to be OPERABLE to ensure that no single instrument failure can preclude the ECCS function. Per Footnote (a) to Table 3.3.5.1-1, this ECCS Function is only required to be OPERABLE in MODES 4 and 5 whenever the associated ECCS is required to be OPERABLE per LCO 3.5.2. Refer to LCO 3.5.1 and LCO 3.5.2 for Applicability Bases for the low pressure ECCS subsystems.

2.d. Reactor Pressure - Low (Recirculation Discharge Valve Permissive)

Low reactor pressure signals are used as permissives for recirculation discharge valve closure. This ensures that the LPCI subsystems inject into the proper RPV location assumed in the safety analysis. The Reactor Pressure - Low is one of the Functions assumed to be OPERABLE and capable of closing the valve during the transients analyzed in Reference 3. The core cooling function of the ECCS, along with the scram action of the RPS, ensures that the fuel peak cladding temperature remains below the limits of 10 CFR 50.46. The Reactor Pressure - Low Function is directly assumed in the analysis of the recirculation line break (Refs. 1, 2 and 4).

The Reactor Pressure - Low signals are initiated from four pressure transmitters that sense the reactor dome pressure.

The Allowable Value is chosen to ensure that the valves close prior to commencement of LPCI injection flow into the core, as assumed in the safety analysis.

Four channels of the Reactor Pressure-Low Function are only required to be OPERABLE in MODES 1, 2, and 3 with the associated recirculation pump discharge valve open. With the valve(s) closed, the function of the instrumentation has been performed; thus, the Function is not required. In (continued)

JAFNPP B 3.3.5.1-26 Revision 0XX ECCS Instrumentation B 3.3.5.1 BASES ACTIONS B.1, B.2, and B.3 (continued) more Function 2.a channels are inoperable and untripped such that both trip systems lose initiation capability, (c) two or more Function 1.b channels are inoperable and untripped such that both trip systems lose initiation capability, or (d) two or more Function 2.b channels are inoperable and untripped such that both trip systems lose initiation capability. For low pressure ECCS, since each inoperable channel would have Required Action B.1 applied separately (refer to ACTIONS Note), each inoperable channel would only require the affected portion of the associated system of low pressure ECCS and EDGs to be declared inoperable. However, since channels in both associated low pressure ECCS subsystems (e.g., both CS subsystems) are inoperable and untripped, and the Completion Times started concurrently for the channels in both subsystems, this results in the affected portions in the associated low pressure ECCS and EDGs being concurrently declared inoperable.

For Required Action B.2, redundant automatic HPCI initiation capability is lost if two or more Function 3.a or two or more Function 3.b channels are inoperable and untripped such that trip capability is lost. In this situation (loss of redundant automatic initiation capability), the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowance of Required Action B.3 is not appropriate and the HPCI System must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . As noted (Note 1 to Required Action B.1), Required Action B.1 is only applicable in MODES 1, 2, and 3. In MODES 4 and 5, the specific initiation time of the low pressure ECCS is not assumed and the probability of a LOCA is lower. Thus, a total loss of initiation capability for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (as allowed by Required Action B.3) is allowed during MODES 4 and 5. There is no similar Note provided for Required Action B.2 since HPCI instrumentation is not required in MODES 4 and 5; thus, a Note is not necessary.

Notes are also provided (the Note 2 to Required Action B.1 and the Note to Required Action B.2) to delineate which Required Action is applicable for each Function that requires entry into Condition B if an associated channel is inoperable. This ensures that the proper loss of initiation capability check is performed. Required Action B.1 (the Required Action for certain inoperable channels in the low pressure ECCS subsystems) is not applicable to Functions 2.e and 2.h, since these Functions provide backup to administrative controls ensuring that operators do not divert LPCI flow from injecting into the core when needed, and do not spray the containment unless needed. Thus, a total loss of (continued)

JAFNPP B 3.3.5.1-28 Revision 0XX ECCS Instrumentation B 3.3.5.1 BASES ACTIONS C.1 and C.2 (continued)

ECCS). Redundant automatic initiation capability is lost if either (a) two or more Function 1.c channels are inoperable such that both trip systems lose initiation capability, (b) two Function 1.d channels are inoperable, (c) two or more Function 2.c channels are inoperable such that both trip systems lose initiation capability, (d) two or more Function 2.d channels are inoperable such that both trip systems lose initiation capability, or (e) three Function 2.f channels are inoperable. In this situation (loss of redundant automatic initiation capability), the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowance of Required Action C.2 is not appropriate and the feature(s) associated with the inoperable channels must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Since each inoperable channel would have Required Action C.1 applied separately (refer to ACTIONS Note), each inoperable channel would only require the affected portion of the associated system to be declared inoperable. However, since channels for both low pressure ECCS subsystems are inoperable (e.g.,

both CS subsystems), and the Completion Times started concurrently for the channels in both subsystems, this results in the affected portions in both subsystems being concurrently declared inoperable. For Functions 1.c, 1.d, 2.c, 2.d, and 2.f, the affected portions are the associated low pressure ECCS pumps. As noted (Note 1), Required Action C.1 is only applicable in MODES 1, 2, and 3. In MODES 4 and 5, the specific initiation time of the ECCS is not assumed and the probability of a LOCA is lower. Thus, a total loss of automatic initiation capability for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (as allowed by Required Action C.2) is allowed during MODES 4 and 5.

The Note 2 states that Required Action C.1 is only applicable for Functions 1.c, 1.d, 2.c, 2.d, and 2.f.

Required Action C.1 is not applicable to Function 3.c (which also requires entry into this Condition if a channel in this Function is inoperable), since the loss of one channel results in a loss of the Function (two out of two logic).

This loss was considered during the development of Reference 7 and considered acceptable for the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed by Required Action C.2.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

For Required Action C.1, the Completion Time only begins upon discovery that the same feature in both subsystems (continued)

JAFNPP B 3.3.5.1-31 Revision 0XX ECCS Instrumentation B 3.3.5.1 BASES ACTIONS E.1 and E.2 (continued) concurrently for the channels of the low pressure ECCS pumps, this results in the affected low pressure ECCS pumps being concurrently declared inoperable.

In this situation (loss of redundant automatic initiation capability), the 7 day allowance of Required Action E.2 is not appropriate and the subsystem associated with each inoperable channel must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . As noted (Note 1 to Required Action E.1), Required Action E.1 is only applicable in MODES 1. 2. and 3. In MODES 4 and 5, the specific initiation time of the ECCS is not assumed and the probability of a LOCA is lower. Thus, a total loss of initiation capability for 7 days (as allowed by Required Action E.2) is allowed during MODES 4 and 5. A Note is also provided (the Note 2 to Required Action E.1) to delineate that Required Action E.1 is only applicable to low pressure ECCS Functions. Required Action E.1 is not applicable to HPCI Functions 3.f and 3.g since the loss of one channel results in a loss of the Function (one-out-of-one logic). This loss was considered during the development of Reference 7 and considered acceptable for the 7 days allowed by Required Action E.2.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

For Required Action E.1, the Completion Time only begins upon discovery that a redundant feature in the same system (e.g., both CS subsystems) cannot be automatically initiated due to inoperable channels within the same Function as described in the paragraph above. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration of channels.

If the instrumentation that controls the pump minimum flow valve is inoperable, such that the valve will not automatically open, extended pump operation with no injection path available could lead to pump overheating and failure. If there were a failure of the instrumentation. such that the valve would not automatically close, a portion of the pump flow could be diverted from the reactor vessel injection path, causing insufficient core cooling. These consequences can be averted by the operator's manual control of the valve, which would be adequate to maintain ECCS pump (continued)

JAFNPP B 3.3.5.2-1 Revision XX RPV Water Inventory Control Instrumentation B 3.3.5.2 B 3.3 INSTRUMENTATION B 3.3.5.2 REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL INSTRUMENTATION BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSS) for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The actual settings for the automatic isolation channels are the same as those established for the same functions in MODES 1, 2, and 3 in LCO 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," or LCO 3.3.6.1, "Primary Containment Isolation instrumentation".

With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur. Under the definition of DRAIN TIME, some penetration flow paths may be excluded from the DRAIN TIME calculation if they will be isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation.

(continued)

JAFNPP B 3.3.5.2-2 Revision XX RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES BACKGROUND (continued)

The purpose of the RPV Water Inventory Control Instrumentation is to support the requirements of LCO 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control," and the definition of DRAIN TIME. There are functions that are required for manual initiation or operation of the ECCS injection/spray subsystem required to be OPERABLE by LCO 3.5.2 and other functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

The RPV Water Inventory Control Instrumentation supports operation of core spray (CS) and low pressure coolant injection (LPCI). The equipment involved with each of these systems is described in the Bases for LCO 3.5.2 APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses. RPV, LCO, water inventory control is required in MODES 4 and 5 to protect and Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulated in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is postulated in which a single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety. Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy.

(continued)

JAFNPP B 3.3.5.2-3 Revision XX RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

Core Spray and Low Pressure Coolant Injection Systems 1.a, 2.a. Reactor Pressure - Low (Injection Permissive)

Low reactor pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions. This function ensures that, prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems' maximum design pressure. While it is assured during MODES 4 and 5 that the reactor pressure will be below the ECCS maximum design pressure, the Reactor Pressure - Low signals are assumed to be OPERABLE and capable of permitting initiation of the ECCS. The Reactor Pressure - Low signals are initiated from four pressure transmitters that sense the reactor dome pressure. The Allowable Value is low enough to prevent overpressuring the equipment in the low pressure ECCS.

The four channels of Reactor Pressure - Low Function are required to be OPERABLE in MODES 4 and 5 when ECCS manual initiation is required to be OPERABLE by LCO 3.5.2.

1.b, 2.b, and 1.c. Core Spray and Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass), Core Spray Pump Discharge Pressure - High (Bypass) (continued)

The minimum flow instruments are provided to protect the associated low pressure ECCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump.

One differential pressure indicating switch per CS pump and one differential pressure indicating switch per LPCI subsystem are used to detect the associated subsystems' flow rates. In addition, one pressure switch per CS pump is used to detect the associated pumps discharge pressure. The logic is arranged such that each differential pressure indicating switch causes its associated minimum flow valve to open. For CS both the differential pressure indicating switch and the pressure switch must actuate to cause the valve to open. The logic will close the minimum flow valve once the closure setpoint of the associated differential pressure indicating switch is exceeded. The LPCI minimum flow valves are time delayed such that the valves will not open for 10 seconds after the switches detect low flow. The time delay is provided to limit reactor vessel inventory loss during the startup of the Residual Heat Removal (RHR) shutdown cooling mode. (continued)

JAFNPP B 3.3.5.2-4 Revision XX RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

The Pump Discharge Flow - Low Allowable Values are high enough to ensure that the pump flow rate is sufficient to protect the pump, yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core. The Core Spray Pump Discharge Pressure-High (Bypass) Allowable Value is less than the pump discharge pressure when the pump is operating in a full flow mode and high enough to avoid any condition that results in a discharge pressure permissive when the CS pump is aligned for injection and the pump is not running.

One channel of the Pump Discharge Flow - Low Function and one channel of Core Spray Pump Discharge Pressure - High (Bypass) is required to be OPERABLE in MODES 4 and 5 when the associated Core Spray or LPCI pump is required to be OPERABLE by LCO 3.5.2 to ensure the pumps are capable of injecting into the Reactor Pressure Vessel when manually initiated.

RHR System Isolation 3.a - Reactor Vessel Water Level - Low, Level 3 The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low, Level 3 Function associated with RHR System isolation may be credited for automatic isolation of penetration flow paths associated with the RHR System.

Reactor Vessel Water Level - Low, Level 3 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low, Level 3 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

(continued)

JAFNPP B 3.3.5.2-5 Revision XX RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

The Reactor Vessel Water Level - Low, Level 3 Allowable Value was chosen to be the same as the Primary Containment Isolation Instrumentation Reactor Vessel Water Level - Low, Level 3 Allowable Value (LCO 3.3.6.1), since the capability to cool the fuel may be threatened.

The Reactor Vessel Water Level - Low, Level 3 Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. This Function isolates the Group 11 valves.

Reactor Water Cleanup (RWCU) System Isolation 4.a - Reactor Vessel Water level - Low, Level 3 The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low (Level 3) Function associated with RWCU System isolation may be credited for automatic isolation of penetration flow paths associated with the RWCU System.

Reactor Vessel Water Level - Low, (Level 3) signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low (Level 3) Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low (Level 3) Allowable Value was chosen to be the same as the RPS Reactor Vessel Water Level - Low (Level 3) Allowable Value (LCO 3.3.1.1), since the capability to cool the fuel may be threatened. The allowable value is referenced from a level of water 352.56 inches above thr lowest point in the inside bottom of the RPV and also corresponds to the top of a 144 inch fuel column (Ref 6).

The Reactor Vessel Water Level - Low (Level 3) Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. This Function isolates the Group 5 valves.

(continued)

JAFNPP B 3.3.5.2-6 Revision XX RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES ACTIONS A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control instrumentation channels.

Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control instrumentation channel.

A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.2-1. The applicable Condition referenced in the Table is Function dependent. Each time a channel is discovered inoperable, Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition.

B.1 and B.2 RHR System Isolation, Reactor Vessel Water Level - Low Level 3, and Reactor Water Cleanup System, Reactor Vessel Water Level - Low Low, Level 2 functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating Drain Time. If the instrumentation is inoperable, Required Action B.1 directs an immediate declaration that the associated penetration flow path(s) are incapable of automatic isolation. Required Action B.2 directs calculation of DRAIN TIME. The calculation cannot credit automatic isolation of the affected penetration flow paths.

(continued)

JAFNPP B 3.3.5.2-7 Revision XX RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES ACTIONS (continued)

C.1 Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions. If the permissive is inoperable, manual initiation of ECCS is prohibited. Therefore, the permissive must be placed in the trip condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . With the permissive in the trip condition, manual initiation may be performed. Prior to placing the permissive in the tripped condition, the operator can take manual control of the pump and the injection valve to inject water into the RPV.

The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in trip.

D.1 If a Core Spray or Low Pressure Coolant Injection Pump Discharge Flow - Low bypass function is inoperable, there is a risk that the associated low pressure ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the pump and the injection valve to ensure the pump does not overheat. If a manual initiation function is inoperable, the ECCS subsystem pumps can be started manually and the valves can be opened manually, but this is not the preferred condition.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The Completion Time is appropriate given the ability to manually start the ECCS pumps and open the injection valves and to manually ensure the pump does not overheat.

E.1 With the Required Action and associated Completion Time of Condition C or D not met, the associated low pressure ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

(continued)

JAFNPP B 3.3.5.2-8 Revision XX RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES SURVEILLANCE REQUIREMENTS As noted in the beginning of the SRs, the SRs for each RPV Water Inventory Control instrument Function are found in the SRs column of Table 3.3.5.2-1. SR 3.3.5.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK guarantees that undetected outright channel failure is limited; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL FUNCTIONAL TEST.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO. (continued)

JAFNPP B 3.3.5.2-9 Revision XX RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.5.2.2

A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.2.3

The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO

3.5.2 overlaps

this Surveillance to complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.Information Notice 84

-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984.

2.Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986. 3.Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(F), " August 1992.

4.NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993. 5.Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.

6.Drawing 11825-5.01-150. Rev. D. Reactor Assembly Nuclear Boiler. (GE Drawing 9190690BO).

JAFNPP B 3.3.5.23-1 Revision 0XX RCIC System Instrumentation 3.3.5.2 3 B 3.3 INSTRUMENTATION Reactor Core Isolation Cooling (RCIC) System Instrumentation BASES BACKGROUND The purpose of the RCIC System instrumentation is to initiate actions to ensure adequate core cooling when the reactor vessel is isolated from its primary heat sink (the main condenser) and normal coolant makeup flow from the Reactor Feedwater System is insufficient or unavailable, such that RCIC System initiation occurs and maintains sufficient reactor water level such that an initiation of the low pressure Emergency Core Cooling Systems (ECCS) pumps does not occur. A more complete discussion of RCIC System operation is provided in the Bases of LCD 3.5.3, "RCIC System."

The RCIC System may be initiated by either automatic or manual means. Automatic initiation occurs for conditions of Reactor Vessel Water Level - Low Low (Level 2). The variable is monitored by four transmitters that are connected to four trip units. The outputs of the trip units are connected to relays whose contacts are arranged in a one-out-of-two taken twice logic arrangement. Once initiated, the RCIC logic seals in and can be reset by the operator only when the reactor vessel water level signals have cleared.

The normally closed RCIC test line isolation valve is closed on a RCIC initiation signal to allow full system flow.

The RCIC System also monitors the water level in each condensate storage tank (CST) since this is the initial source of water for RCIC operation. Reactor grade water in the CSTs is the normal source. The CST suction source consists of two CSTs connected in parallel to the RCIC pump suction. Upon receipt of a RCIC initiation signal, the CSTs suction valve is automatically signaled to open (it is normally in the open position) unless the pump suction from the suppression pool valves are open. If the water level in both CSTs fall below a preselected level, first the suppression pool suction valves automatically open, and then the CST suction valve automatically closes. Two level switches are used to detect low water level in each CST. A level switch associated with each CST must actuate to cause the suppression pool suction valves to open and the CSTs suction valve to close. The channels are arranged in a one out-of-two taken twice logic. To prevent losing suction to the pump when automatically transferring suction from the (continued)

JAFNPP B 3.3.5.23-2 Revision 0XX RCIC System Instrumentation B 3.3.5.2 3 BASES BACKGROUND (continued)

CSTs to the suppression pool on low CST level. the suction valves are interlocked so that the suppression pool suction path must be open before the CST suction path automatically closes.

The RCIC System provides makeup water to the reactor until the reactor vessel water level reaches the high water level (Level 8) trip (two-out-of-two logic), at which time the RCIC steam inlet valve closes. The RCIC System restarts if vessel level again drops to the low level initiation point (Level 2).

APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY The function of the RCIC System is to respond to transient events by providing makeup coolant to the reactor. The RCIC System is not an Engineered Safeguard System and no credit is taken in the safety analyses for RCIC System operation. The RCIC System instrumentation satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii) (Ref. 1). Certain instrumentation Functions are retained for other reasons and are described below in the individual Functions discussion.

The OPERABILITY of the RCIC System instrumentation is dependent upon the OPERABILITY of the individual instrumentation channel Functions specified in Table 3.3.5.23-1. Each Function must have a required number of OPERABLE channels with their setpoints within the specified Allowable Values, where appropriate. The actual setpoint is calibrated consistent with applicable setpoint methodology assumptions.

Allowable Values are specified for each RCIC System instrumentation Function specified in the Table. Nominal trip setpoints are specified in the setpoint calculations.

The nominal setpoints are selected to ensure that the setpoints do not exceed the Allowable Value between CHANNEL CALIBRATIONS. Operation with a trip setpoint less conservative than the nominal trip setpoint, but within its Allowable Value is acceptable. A channel is inoperable if its actual trip setpoint is not within its required Allowable Value. Trip setpoints are those predetermined values of output at which an action should take place. The setpoints are compared to the actual process parameter (e.g., reactor vessel water level), and when the measured output value of the process parameter exceeds the setpoint, the associated device (e.g., trip unit) changes state. The analytic limits are derived from the limiting values of the process parameters obtained from the safety analysis or (continued)

JAFNPP B 3.3.5.23-3 Revision 0XX RCIC System Instrumentation B 3.3.5.2 3 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) other appropriate documents. The trip setpoints are derived from the analytical limits and account for all worst case instrumentation uncertainties as appropriate (e.g., drift, process effects, calibration uncertainties, and severe environmental errors (for channels that must function in harsh environments as defined by 10 CFR 50.49)). The trip setpoints derived in this manner provide adequate protection because all expected uncertainties are accounted for. The Allowable Values are then derived from the trip setpoints by accounting for normal effects that would be seen during periodic surveillance or calibration. These effects are instrumentation uncertainties observed during normal operation (e.g., drift and calibration uncertainties).

The individual Functions are required to be OPERABLE in MODE 1, and in MODES 2 and 3 with reactor steam dome pressure > 150 psig since this is when RCIC is required to be OPERABLE. (Refer to LCO 3.5.3 for Applicability Bases for the RCIC System.)

The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.

1. Reactor Vessel Water Level - Low Low (Level 2)

Low reactor pressure vessel (RPV) water level indicates that normal feedwater flow is insufficient to maintain reactor vessel water level and that the capability to cool the fuel may be threatened. Should RPV water level decrease too far, fuel damage could result. Therefore, the RCIC System is initiated at Level 2 to assist in maintaining water level above the top of the active fuel.

Reactor Vessel Water Level - Low Low (Level 2) signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.

The Reactor Vessel Water Level - Low Low (Level 2) Allowable Value is set high enough such that for complete loss of feedwater flow, the RCIC System flow with high pressure coolant injection assumed to fail will be sufficient to avoid initiation of low pressure ECCS at Level 1. The (continued)

JAFNPP B 3.3.5.23-4 Revision XXX 0 RCIC System Instrumentation B 3.3.5.2 3 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY

1. Reactor Vessel Water Level - Low Low (Level 2)

(continued)

Allowable Value is referenced from a level of water 352.56 inches above the lowest point in the inside bottom of the RPV and also corresponds to the top of a 144 inch fuel column (Ref. 2).

The HPCI. RCIC and ATWS-RPT initiation functions (as described in Table 3.3.5.1-1. Function 3.a; Table 3.3.5.23-1. Function 1; and LCO 3.3.4.1.a including SR 3.3.4.1.4, respectively) describe the reactor vessel water level initiation function as "Low Low (Level 2)." The Allowable Values associated with the HPCI and RCIC initiation function is different from the Allowable Value associated with the ATWS*RPT initiation function as the ATWS function has a separate analog trip unit. Nevertheless, consistent with the nomenclature typically used in design documents, the "Low Low (Level 2)" is retained in describing each of these three initiation functions.

Four channels of Reactor Vessel Water Level - Low Low (Level 2) Function are available and are required to be OPERABLE when RCIC is required to be OPERABLE to ensure that no single instrument failure can preclude RCIC initiation. Refer to LCO 3.5.3 for RCTC Applicability Bases.

2. Reactor Vessel Water Level-High (Level 8)

High RPV water level indicates that sufficient cooling water inventory exists in the reactor vessel such that there is no danger to the fuel. Therefore, the Level 8 signal is used to close the RCIC steam inlet valve to prevent overflow into the main steam lines (MSLs).

Reactor Vessel Water Level - High (Level 8) signals for RCIC are initiated from two level transmitters from the narrow range water level measurement instrumentation, which sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. Both Level 8 signals are required in order to close the RCIC steam inlet valve.

The Reactor Vessel Water Level - High (Level 8) Allowable Value is high enough to preclude isolating the steam inlet valve during normal operation, yet low enough to prevent water overflowing into the MSLs. The Allowable Value is (continued)

JAFNPP B 3.3.5.23-5 Revision 0XX RCIC System Instrumentation B 3.3.5.2 3 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY

2. Reactor Vessel Water Level - High (Level 8) (continued) referenced from a level of water 352.56 inches above the lowest point in the inside bottom of the RPV and also corresponds to the top of a 144 inch fuel column (Ref. 2).

Two channels of Reactor Vessel Water Level - High (Level 8) Function are available and are required to be OPERABLE when RCIC is required to be OPERABLE to ensure that no single instrument failure can preclude RCIC initiation. Refer to LCO 3.5.3 for RCIC Applicability Bases.

3. Condensate Storage Tank (CST) Level - Low

Low level in the CSTs indicates the unavailability of an adequate supply of makeup water from this normal source. Normally, the suction valve between the RCIC pump and the CSTs is open and, upon receiving a RCIC initiation signal, water for RCIC injection would be taken from the CSTs.

However, if the water level in both CSTs falls below a preselected level, first the suppression pool suction valves automatically open, and then the CSTs suction valve automatically closes. This ensures that an adequate supply of makeup water is available to the RCIC pump. To prevent losing suction to the pump, the suction valves are interlocked so that the suppression pool suction valves must be open before the CSTs suction valve automatically closes.

Two level switches are used to detect low water level in each CST. The Condensate Storage Tank Level-Low Function Allowable Value is set high enough (15,600 gallons of water is available in each CST) to ensure adequate pump suction head while water is being taken from the CST.

Four channels of Condensate Storage Tank Level-Low Function are available and are required to be OPERABLE when RCIC is required to be OPERABLE to ensure that no single instrument failure can preclude RCIC automatic suction source alignment to suppression pool source. Refer to LCO 3.5.3 for RCIC Applicability Bases.

4. Manual Initiation The Manual Initiation push button switch introduces a signal into the RCIC System initiation logic that is redundant to the automatic protective instrumentation and provides manual initiation capability. There is one push button for the RCIC System.

(continued)

JAFNPP B 3.3.5.23-6 Revision XXX 0 RCIC System Instrumentation B 3.3.5.2 3 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY

4. Manual Initiation (continued)

The Manual Initiation Function is not assumed in any accident or transient analyses in the UFSAR. However, the Function is retained for overall redundancy and diversity of the RCIC function as required by the NRC in the plant licensing basis. There is no Allowable Value for this Function since the channel is mechanically actuated based solely on the position of the push button. One channel of Manual Initiation is required to be OPERABLE when RCIC is required to be OPERABLE.

ACTIONS A Note has been provided to modify the ACTIONS related to RCIC System instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RCIC System instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable RCIC System instrumentation channel. A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.23-1. The applicable Condition referenced in the Table is Function dependent.

Each time a channel is discovered to be inoperable, Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition.

B.1 and B.2 Required Action B.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same Function result in a complete loss of automatic initiation capability for the RCIC System. In (continued)

JAFNPP B 3.3.5.23-7 Revision 0XX RCIC System Instrumentation B 3.3.5.2 3 BASES ACTIONS B.1 and B.2 (continued) this case, automatic initiation capability is lost if two Function 1 channels in the same trip system are inoperable and untripped. In this situation (loss of automatic initiation capability), the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowance of Required Action B.2 is not appropriate, and the RCIC System must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after discovery of loss of RCIC initiation capability.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action B.1, the Completion Time only begins upon discovery that the RCIC System cannot be automatically initiated due to two inoperable, untripped Reactor Vessel Water Level - Low Low (Level 2) channels in the same trip system. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the redundancy of sensors available to provide initiation signals and the fact that the RCIC System is not assumed in any accident or transient analysis, an allowable out of service time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months has been shown to be acceptable (Ref. 3) to permit restoration of any inoperable channel to OPERABLE status. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action B.2. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue.

Alternately, if it is not desired to place the channel in trip (e.g., as in the case where placing the inoperable channel in trip would result in an initiation), Condition E must be entered and its Required Action taken.

C.1 A risk based analysis was performed and determined that an allowable out of service time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Ref. 3) is acceptable to permit restoration of any inoperable channel to OPERABLE status (Required Action C.1). A Required Action (similar to Required Action B.1) limiting the allowable out (continued)

JAFNPP B 3.3.5.23-8 Revision 0XX RCIC System Instrumentation B 3.3.5.2 3 BASES ACTIONS C.1 (continued) of service time, if a loss of automatic RCIC initiation capability exists, is not required. This Condition applies to the Reactor Vessel Water Level - High (Level 8) Function whose logic is arranged such that any inoperable channel will result in a loss of automatic RCIC initiation capability due to closure of the RCIC steam inlet valve. As stated above, this loss of automatic RCIC initiation capability was analyzed and determined to be acceptable.

This Condition also applies to the Manual Initiation Function. Since this Function is not assumed in any accident or transient analysis, a total loss of manual initiation capability (Required Action C.1) for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed. The Required Action does not allow placing a channel in trip since this action would not necessarily result in a safe state for the channel in all events.

D.1, D.2.1, and D.2.2 Required Action D.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same Function result in automatic component initiation capability being lost for the feature(s). For Required Action D.1, the RCIC System is the only associated feature. In this case, automatic initiation capability (automatic suction source alignment) is lost if two Function 3 channels associated with the same CST are inoperable and untripped. In this situation (loss of automatic suction source alignment), the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowance of Required Actions D.2.1 and D.2.2 is not appropriate, and the RCIC System must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of RCIC initiation capability. As noted, Required Action D.1 is only applicable if the RCIC pump suction is not aligned to the suppression pool since, if aligned, the Function is already performed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

For Required Action D.1, the Completion Time only begins upon discovery that the RCIC System suction source cannot be automatically aligned to the suppression pool due to two inoperable, untripped channels in the same Function. The (continued)

JAFNPP B 3.3.5.23-9 Revision 0XX RCIC System Instrumentation B 3.3.5.2 3 BASES ACTIONS D.1, D.2.1, and D.2.2 (continued) 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time from discovery of loss of initiation capability (automatic suction source alignment) is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the redundancy of sensors available to provide initiation signals and the fact that the RCIC System is not assumed in any accident or transient analysis, an allowable out of service time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months has been shown to be acceptable (Ref. 3) to permit restoration of any inoperable channel to OPERABLE status. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action D.2.1, which performs the intended function of the channel (shifting the suction source to the suppression pool). Alternatively, Required Action D.2.2 allows the manual alignment of the RCIC suction to the suppression pool, which also performs the intended function. If Required Action D.2.1 or D.2.2 is performed, measures should be taken to ensure that the RCIC System piping remains filled with water. If it is not desired to perform Required Actions D.2.1 and D.2.2 (e.g., as in the case where shifting the suction source could drain down the RCIC suction piping), Condition E must be entered and its Required Action taken.

E.1 With any Required Action and associated Completion Time not met, the RCIC System may be incapable of performing the intended function, and the RCIC System must be declared inoperable immediately.

SURVEILLANCE REQUIREMENTS As noted in the beginning of the SRs, the SRs for each RCIC System instrumentation Function are found in the SRs column of Table 3.3.5.23-1. The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed 'as follows:

(a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 2 and 4; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1 and 3, provided the associated Function maintains trip capability. Upon completion of the (continued)

JAFNPP B 3.3.6.1-7 Revision 0XX Primary Containment Isolation Instrumentation B 3.3.6.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) associated with these signals are addressed in LCO 3.3.5.1, "Emergency Core Cooling Systems (ECCS) Instrumentation," and LCO 3.3.5.23, "Reactor Core Isolation Cooling (RCIC) System Instrumentation," and are not included in this LCO.

In general, the individual Functions are required to be OPERABLE in MODES 1, 2, and 3 consistent with the Applicability for LCO 3.6.1.1, "Primary Containment." Functions that have different Applicabilities are discussed below in the individual Functions discussion.

The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.

Main Steam Line Isolation 1.a. Reactor Vessel Water Level - Low Low Low (Level 1)

Low reactor pressure vessel (RPV) water level indicates that the capability to cool the fuel may be threatened. Should RPV water level decrease too far, fuel damage could result. Therefore, isolation of the MSIVs and other interfaces with the reactor vessel occurs to prevent offsite dose limits from being exceeded. The Reactor Vessel Water Level - Low Low Low (Level 1) Function is one of the many Functions assumed to be OPERABLE and capable of providing isolation signa1s. The Reactor Vessel Water Level - Low Low Low (Level 1) Function associated with isolation is assumed in the analysis of the recirculation line break (Ref. 2). The isolation of the MSLs on Level 1 supports actions to ensure that offsite dose limits are not exceeded for a DBA.

Reactor vessel water level signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. Four channels of Reactor Vessel Water Level - Low Low Low (Level 1) Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function.

The Reactor Vessel Water Level - Low Low Low (Level 1) Allowable Value is chosen to ensure that the MSLs isolate on a potential loss of coolant accident (LOCA) to prevent offsite doses from exceeding 10 CFR 100 limits. In addition, the setting is low enough to allow the removal of heat from the reactor for a predetermined time following a (continued)

JAFNPP B 3.3.6.1-23 Revision XXX 3 Primary Containment Isolation Instrumentation B 3.3.6.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY 6.b. Reactor Vessel Water Level - Low (Level 3) (continued) be OPERABLE in MODES 4 and 5, provided the RHR Shutdown Cooling System integrity is maintained. System integrity is maintained provided the piping is intact and no maintenance or other activity is being performed that has the potential for draining the reactor vessel through the system.

The Reactor Vessel Water Level - Low (Level 3) Allowable Value was chosen to be the same as the RPS Reactor Vessel Water Level-Low (Level 3) Allowable Value (LCO 3.3.1.1), since the capability to cool the fuel may be threatened.

The Allowable Value is referenced from a level of water 352.56 inches above the lowest point in the inside bottom of the RPV and also corresponds to the top of a 144 inch fuel column (Ref. 13).

The Reactor Vessel Water Level - Low (Level 3) Function is only required to be OPERABLE in MODE S 3, 4, and 5 to prevent this potential flow path from lowering the reactor vessel level to the top of the fuel. In MODES 1 and 2, another isolation (i.e., Reactor Pressure - High) and administrative controls ensure that this flow path remains isolated to prevent unexpected loss of inventory via this flow path.

This Function isolates both RHR shutdown cooling pump suction valves and the inboard LPCI injection valves.

Traversing Incore Probe System Isolation 7.a. Reactor Vessel Water Level-Low (Level 3)

Low RPV water level indicates that the capability to cool the fuel may be threatened. The valves whose penetrations communicate with the primary containment are isolated to limit the release of fission products. The isolation of the primary containment on Level 3 supports actions to ensure that offsite dose limits of 10 CFR 100 are not exceeded.

The Reactor Vessel Water Level-Low (Level 3) Function associated with isolation is implicitly assumed in the UFSAR analysis as these leakage paths are assumed to be isolated post LOCA.

Reactor Vessel Water Level - Low (Level 3) signals are initiated from level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. Two channels of Reactor (continued)

JAFNPP B 3.3.6.1-29 Revision 3XX Primary Containment Isolation Instrumentation B 3.3.6.1 BASES ACTIONS (continued)

H.1 and H.2 If the channel is not restored to OPERABLE status or placed in trip within the allowed Completion Time, or any Required Action of Condition F or G is not met and the associated Completion Time has expired, the plant must be placed in a MODE or other specified condition in which the LCO does not apply. This is done by placing the plant in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

I.1 and I.2 If the channel is not restored to OPERABLE status within the allowed Completion Time, the associated SLC subsystem is declared inoperable or the RWCU System is isolated. Since this Function is required to ensure that the SLC System performs its intended function, sufficient remedial measures are provided by declaring the associated SLC subsystems inoperable or isolating the RWCU System.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing sufficient time for personnel to isolate the RWCU System.

J.1 and J.2 If the channel is not restored to OPERABLE status or placed in trip within the allowed Completion Time, the associated penetration flow path should be closed. However, if the shutdown cooling function is needed to provide core cooling, these Required Actions allow the penetration flow path to remain unisolated provided action is immediately initiated to restore the channel to OPERABLE status or to isolate the RHR Shutdown Cooling System (i.e., provide alternate decay heat removal capabilities so the penetration flow path can be isolated). Actions must continue until the channel is restored to OPERABLE status or the RHR Shutdown Cooling System is isolated. SURVEILLANCE REQUIREMENTS As noted (Note 1) at the beginning of the SRs, the SRs for each Primary Containment Isolation instrumentation Function are found in the SRs column of Table 3.3.6.1-1. (continued)

JAFNPP B 3.3.6.2-4 Revision 0XX Secondary Containment Isolation Instrumentation B 3.3.6.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY

1. Reactor Vessel Water Level - Low (Level 3) (continued)

The Reactor Vessel Water Level - Low (Level 3) Allowable Value was chosen to be the same as the RPS level scram Allowable Value (LCO 3.3.1.1, "Reactor Protection System Instrumentation"), since this could indicate that the capability to cool the fuel is being threatened. The Allowable Value is referenced from a level of water 352.56 inches above the lowest point in the inside bottom of the RPV and also corresponds to the top of a 144 inch fuel column (Ref. 8).

The Reactor Vessel Water Level - Low (Level 3) Function is required to be OPERABLE in MODES 1, 2, and 3 where considerable energy exists in the Reactor Coolant System (RCS); thus, there is a probability of pipe breaks resulting in significant releases of radioactive steam and gas. In MODES 4 and 5, the probability and consequences of these events are low due to the RCS pressure and temperature limitations of these MODES; thus, this Function is not required. In addition, the Function is also required to be OPERABLE during operations with a potential for draining the reactor vessel (OPDRVs) because the capability of isolating potential sources of leakage must be provided to ensure that offsite and control room dose limits are not exceeded if core damage occurs.

2. Drywell Pressure-High High drywell pressure can indicate a break in the reactor coolant pressure boundary (RCPB). An isolation of the secondary containment and actuation of the SGT System are initiated in order to minimize the potential of an offsite and control room release. The Drywell Pressure - High Function is one of the Functions assumed to be OPERABLE and capable of providing isolation and initiating signals. The isolation and initiation systems on high drywell pressure supports actions to ensure that any offsite and control room releases are within the limits calculated in the safety analysis (Ref. 4).

High drywell pressure signals are initiated from pressure transmitters that sense the pressure in the drywell. Four channels of Drywell Pressure - High Functions are available and are required to be OPERABLE to ensure that no single instrument failure can preclude performance of the isolation function.

(continued)

JAFNPP B 3.3.7.1-3 Revision 2XX CREVAS System Instrumentation B 3.3.7.1 BASES LCO personnel; thus, an alarm is provided in the control room so that the CREVAS System can be placed in the isolate mode of operation. (continued)

APPLICABILITY The Control Room Air Inlet Radiation - High Function is required to be OPERABLE in MODES 1, 2, and 3 and during OPDRVs and movement of recently irradiated fuel assemblies in the secondary containment, to ensure that control room personnel are protected during a LOCA, or fuel handling event, or vessel draindown event. During MODES 4 and 5, when these specified conditions are not in progress (e.g.,OPDRVs), the probability of a LOCA is low: thus, the Function is not required. Also due to radioactive decay, the Function is only required to provide an alarm to alert the operator of the need to initiate the CREVAS System during fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ).

ACTIONS A.1 and A.2

With the Control Room Air Inlet Radiation - High Function inoperable one CREVAS subsystem must be placed in the isolate mode of operation per Required Action A.1 to ensure that control room personnel will be protected in the event of a Design Basis Accident. Alternately, if it is not desired to start a CREVAS subsystem, the CREVAS System must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is intended to allow the operator time to place the CREVAS subsystem in operation. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration of the channel, for placing one CREVAS subsystem in operation, or for entering the applicable Conditions and Required Actions for two inoperable CREVAS subsystems.

SURVEILLANCE REQUIREMENTS The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken. This Note is based on the low (continued)

JAFNPP B 3.5.1-1 Revision 35 XX ECCS - Operating B 3.5.1 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.1 ECCS

- Operating BASES BACKGROUND The ECCS is designed, in conjunction with the primary and secondary containment, to limit the release of radioactive materials to the environment following a loss of coolant accident (LOCA). The ECCS uses two independent methods (flooding and spraying) to cool the core during a LOCA. The ECCS network consists of the High Pressure Coolant Injection (HPCI) System, the Core Spray (CS) System, the low pressure coolant injection (LPCI) mode of the Residual Heat Removal (RHR) System, and the Automatic Depressurization System (ADS). The suppression pool provides the required source of water for the ECCS.

Although no credit is taken in the safety analyses for the condensate storage tanks (CSTs), they are capable of providing a source of water for the HPCI and CS systems.

On receipt of an initiation signal, ECCS pumps automatically start; simultaneously, the system aligns and the pumps inject water, taken either from the CSTs or suppression pool, into the Reactor Coolant System (RCS) as RCS pressure is overcome by the discharge pressure of the ECCS pumps. Although the system is initiated, ADS action is delayed, allowing the operator to interrupt the timed sequence if the system is not needed. The HPCI pump discharge pressure almost immediately exceeds that of the RCS, and the pump injects coolant into the vessel to cool the core. If the break is small, the HPCI System will maintain coolant inventory as well as vessel level while the RCS is still pressurized. If HPCI fails, it is backed up by ADS in combination with LPCI and CS. In this event, if the ADS timed sequence is allowed to time out, the selected safety/relief valves (S/RVs) would open, depressurizing the RCS, thus allowing the LPCI and CS to overcome RCS pressure and inject coolant into the vessel. If the break is large, RCS pressure initially drops rapidly and the LPCI and CS cool the core.

Water from the break returns to the suppression pool where it is used again and again.

Water in the suppression pool is circulated through a heat exchanger cooled by the RHR Service Water System. Depending on the location and size of the break, portions of the (continued)

JAFNPP B 3.5.1-6 Revision 35 XX ECCS - Operating B 3.5.1 BASES LCO (continued) realigned (remote or local) to the LPCI mode and not otherwise inoperable. Alignment and operation for decay heat removal includes when the system is being realigned from or to the RHR shutdown

cooling mode. At these low pressures and decay heat levels, a reduced complement of ECCS subsystems should provide the required core cooling, thereby allowing operation of RHR shutdown cooling when necessary.

The HPCI system is considered OPERABLE when it is aligned to one or both CSTs with power available to support automatic realignment to the suppression pool if required. This is based on the design of the CSTs and the accident analysis which credits the suppression pool for supplying the HPCI System.

APPLICABILITY All ECCS subsystems are required to be OPERABLE during MODES 1, 2, and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure is < 150 psig, ADS and HPCI are not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. ECCS r Requirements for MODES 4 and 5 are specified in LCO 3.5.2, "ECCS - ShutdownRPV Water Inventory Control

." ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCI System. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCI System and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 If any one low pressure ECCS injection/spray subsystem is inoperable or if one LPCI pump in both LPCI subsystems is inoperable, the inoperable subsystem(s) must be restored to OPERABLE status within (continued)

RCIC System B 3.5.3 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.3 RCIC System BASES BACKGROUND The RCIC System is not part of the ECCS; however, the RC IC System is included with the ECCS section because of their similar functions. The RC IC System is designed to operate either automatically or manually following reactor pressure vessel (RPV) isolation accompanied by a loss of coolant flow from the feedwater system to

provide adequate core cooling and control of the RPV water level.

Under these conditions, the High Pressure Coolant Injection (HPCI)

and RC IC systems perform similar functions. The RC IC System design requirements ensure that the criteria of Reference 1 are satisfied.

The RCIC System (Ref. 2) consists of a steam driven turbine pump unit, piping and valves to provide steam to the turbine, as well as piping and valves to transfer water from the suction source to the core via the feedwater system line, where the coolant is distributed within the RPV through the feedwater sparger. Suction piping is provided from the condensate storage tanks (CSTs) and the suppression pool. Pump suction is normally aligned to the CSTs to minimize injection of suppression pool water into the RPV. However, if the CST water supply is low, an automatic transfer to the suppression pool water source ensures a water supply for continuous operation of the RC IC System. The steam supply to the turbine is piped from the "B" main steam line upstream of the associated inboard main steam line isolation valve.

The RC IC System is designed to provide core cooling for a wide range of reactor pressures (150 psig to 1195 psig). Upon receipt of an initiation signal, the RC IC turbine accelerates to a specified speed. As the RC IC flow increases, the turbine control valve is automatically adjusted to maintain design flow. Exhaust steam from the RCIC turbine is discharged to the suppression pool. A full flow test line is provided to route water to the CSTs to allow testing of the RCIC System during normal operation without injecting water into the RPV.

(continued)

RCIC System B 3.5.3 BASES BACKGROUND (continued)

The RC IC pump is provided with a minimum flow bypass line, which discharges to the suppression pool. The valve in this line automatically opens to prevent pump damage due to overheating when other discharge line valves are closed. To ensure rapid delivery of water to the RPV and to minimize water hammer effects, the RC IC System discharge piping is kept full of water. The RC IC System is normally aligned to the CSTs. The height of water in the CSTs is sufficient to maintain the piping full of water up to the first isolation valve. The relative height of the feedwater line connection for RC IC is such that the water in the feedwater lines keeps the remaining portion of the RCIC discharge line full of water.

Therefore, RCIC does not require a "keep full" system.

APPLICABLE SAFETY ANALYSES The function of the RCIC System is to respond to transient events by providing makeup coolant to the reactor. The RCIC System is not an Engineered Safeguard System and no credit is taken in the safety analyses for RCIC System operation. The RCIC System satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii) (Ref. 3).

LCO The OPERABILITY of the RCIC System provides adequate core cooling such that actuation of any of the low pressure ECCS subsystems is not required in the event of RPV isolation accompanied by a loss of feedwater flow. The RCIC System has sufficient capacity for

maintaining RPV inventory during an isolation event.

The RCIC system is considered OPERABLE when it is aligned to one or both CSTs with power available to support automatic realignment to the suppression pool if required. This is based on the design of the CSTs and the RCIC System.

APPLICABILITY The RCIC System is required to be OPERABLE during MODE 1, and MODES 2 and 3 with reactor steam dome pressure > 150 psig, since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized. In MODES 2 and 3 with reactor steam dome pressure

<150 psig, the low pressure ECCS injection/spray subsystem can provide sufficient flow to the RPV. and i In MODES 4 and 5, RCIC is not required to be OPERABLE since RPV water inventory control is required by LCO 3.5.2, "RPV Water Level Inventory Control"

.the low pressure ECCS injection/spray subsystems can provide sufficient flow to the RPV.

(continued)

JAFNPP B 3.6.1.3-4 Revision 0XX PCIVs B 3.6.1.3 BASES LCO (continued) flanges are in place, and closed systems are intact. These passive isolation valves and devices are those listed in Reference 8.

MSIVs, Low Pressure Coolant Injection (LPCI) and Core Spray (CS) System air operated testable check valves must meet additional leakage rate requirements. Other PCIV leakage rates are addressed by LCO 3.6.1.1. "Primary Containment."

as Type B or C testing.

This LCO provides assurance that the PCIVs will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the primary containment boundary during accidents.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, most PCIVs are not required to be OPERABLE and the primary containment vent and purge valves are not required to be normally closed in MODES 4 and 5. Certain valves, however, are required to be OPERABLE when the to prevent inadvertent reactor vessel draindown. These valves are those whose associated instrumentation is required to be OPERABLE per LCO 3.3.6.1. "Primary Containment Isolation Instrumentation." (This does not include the valves that isolate the associated instrumentation.)

ACTIONS The ACTIONS are modified by a Note allowing penetration flow path(s) to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated operator at the controls of the valve. who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

A second Note has been added to provide clarification that. for the purpose of this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable PCIV.

Complying with the Required Actions may allow for continued operation, and subsequent inoperable PCIVs are governed by subsequent Condition entry and application of associated Required Actions.

(continued)

JAFNPP B 3.6.1.3-10 Revision 30XXX PCIVs B 3.6.1.3 BASES ACTIONS G.1 and G.2 (continued) suspend operations with a potential for draining the reactor vessel (OPDRVs) to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended and valve(s) are restored to OPERABLE status. If suspending an OPDRV would result in closing the residual heat removal (RHR) shutdown cooling isolation valves, an alternative Required Action is provided to immediately initiate action to restore the valve(s) to OPERABLE status. This allows RHR shutdown cooling to remain in service while actions are being taken to restore the valve.

SURVEILLANCE REQUIRMENTS SR 3.6.1.3.1 This SR ensures that the primary containment vent and purge valves are closed as required or, if open, open for an allowable reason. If a purge valve is open in violation of this SR, the valve is considered inoperable. The SR is modified by a Note stating that the SR is not required to be met when t he vent and purge valves are open for the stated reasons. The Note states that these valves may be opened for inerting, de

-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open, provided the full

-flow 12 inch line (with valve 27MOV-120) to the SGT System is closed and one or more SGT System reactor building suction valves are open. This will ensure there is no damage to the filters if a LOCA were to occur with the vent and purge valves open since excessive differential pressure is not expected with the full

-flow 12 inch line closed and one or more SGT System reactor building suction valves open. The 20 and 24 inch vent and purge valves are capable of closing against the dynamic effects of a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.1.3.2

This SR ensures that each primary containment isolation manual valve and blind flange that is located outside primary containment and not locked, sealed or otherwise secured and is required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits.

(continued)

JAFNPP B 3.6.2.2-2 Revision 0XXX Suppression Pool Water Level B 3.6.2.2 BASES APPLICABLE SAFETY ANALYSES (continued) loads due to S/RV discharges. Suppression pool water level must be maintained within the limits specified so that the safety analysis of References 1 and 2 remain valid.

Suppression pool water level satisfies Criteria 2 and 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3).

LCO A limit that suppression pool water level be > 13.88 ft and < 14 ft is required to ensure that the primary containment conditions assumed for the safety analyses are met. Either the high or low water level limits were used in the safety analyses, depending upon which is more conservative for a particular calculation.

The LCO is modified by a note which states that the LCO is not required to be met up to four hours during Surveillances that cause suppression pool water level to be outside of limits. These Surveillances include required OPERABILITY testing of the High Pressure Coolant Injection System, the Reactor Core Isolation Cooling System, the suppression chamber-to-drywell vacuum breakers, the Core Spray System and the Residual Heat Removal System. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months allowance is adequate to perform the Surveillances and to restore the suppression pool water level to within limits.

APPLICABILITY In MODES 1, 2, and 3, a DBA would cause significant loads on the primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. The requirement for maintaining suppression pool water level within limits in MODE 4 or 5 is addressed in LCO 3.5.2.

"Reactor Pressure Vessel (RPV) Water Inventory ControlECCS -

Shutdown." ACTIONS A.1 With suppression pool water level outside the limits, the conditions assumed for the safety analyses are not met. If water level is below the minimum level, the pressure suppression function still exists as long as the vent system downcomer lines are covered, HPCI and RCIC turbine exhausts are covered, and S/RV quenchers are covered. If suppression pool water level is above the maximum level, protection against overpressurization still exists due to the margin in the peak containment pressure analysis and the capability of the Residual Heat Removal Containment Spray System.

(continued)

JAFNPP B 3.6.4.1-2 Revision 2XXX Secondary Containment B 3.6.4.1 BASES APPLICABLE SAFETY ANALYSES (continued)

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

LCO An OPERABLE secondary containment provides a control volume into which fission products that leak from primary containment, or are released from the reactor coolant pressure boundary components located in secondary containment, or are released directly to the secondary containment as a result of a refueling accident, can be processed prior to release to the environment. For the secondary containment to be considered OPERABLE, it must have adequate leak tightness to ensure that the required vacuum can be established and maintained.

APPLICABILITY In MODES 1, 2, and 3, a LOCA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, secondary containment OPERABILITY is required during the same operating conditions that require primary containment OPERABILITY.

In MODES 4 and 5, the probability and consequences of the LOCA are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining secondary containment OPERABLE is not required in MODE 4 or 5 to ensure a control volume, except for other situations for which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs) or during movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, secondary containment is only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e.,

fuel that has occupied part of a critical reactor core within the previous 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ).

ACTIONS A.1 If secondary containment is inoperable, it must be restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time provides a period of time to correct the problem that is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.

(continued)

JAFNPP B 3.6.4.1-3 Revision 2XXX Secondary Containment B 3.6.4.1 BASES ACTIONS (continued) B.1 and B.2 If secondary containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

C.1 and C.2 Movement of recently irradiated fuel assemblies in the secondary containment and OPDRVs can be postulated to cause significant fission product release to the secondary containment. In such cases, the secondary containment is the only barrier to release of fission products to the environment. Therefore, movement of recently irradiated fuel assemblies must be immediately suspended if the secondary containment is inoperable.

Suspension of this activity shall not preclude completing an action that involves moving a component to a safe position. Also, action must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

LCO 3.0.3 is not applicable in MODES 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3, Required Action C.1 has been modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODE 4 or 5.

LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

SURVEILLANCE REQUIREMENTS SR 3.6.4.1.1

This SR ensures that the secondary containment boundary is sufficiently leak tight to preclude exfiltration under expected wind conditions. Momentary transients on the (continued)

JAFNPP B 3.6.4.2-2 Revision XXX2 SCIVs B 3.6.4.2 BASES APPLICABLE SAFETY ANALYSES (continued)

Maintaining SCIVs OPERABLE with isolation times within limits ensures that fission products will remain trapped inside secondary containment so that they can be treated by the SGT System prior to discharge to the environment.

SCIVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3). LCO SCIVs form a part of the secondary containment boundary. The SCIV safety function is related to control of offsite radiation releases resulting from DBAs.

The power operated automatic isolation valves are considered OPERABLE when their isolation times are within limits and the valves actuate on an automatic isolation signal. The valves covered by this LCO, along with their associated stroke times, are listed in Reference 4.

The normally closed isolation valves or blind flanges are considered OPERABLE when manual valves are closed or open in accordance with appropriate administrative controls, automatic SCIVs are de-activated and secured in their closed position, and blind flanges are in place. These passive isolation valves or devices are listed in Reference 4.

APPLICABILITY In MODES 1, 2, and 3, a DBA could lead to a fission product release to the primary containment that leaks to the secondary containment. Therefore, the OPERABILITY of SCIVs is required.

In MODES 4 and 5, the probability and consequences of these events are reduced due to pressure and temperature limitations in these MODES. Therefore, maintaining SCIVs OPERABLE is not required in MODE 4 or 5, except for situations under which significant radioactive releases can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs) or during movement of recently irradiated fuel assemblies in the secondary containment. Moving recently irradiated fuel assemblies in the secondary containment may also occur in MODES 1, 2, and 3. Due to radioactivitveradioactive decay, SCIVs are only requriedrequired to be OPERABLE during fuel handling involving recently irradiated fuel (i.e ., fuel that has occupied part of a critical reactor core within the previous 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ).

(continued)

JAFNPP B 3.6.4.2-5 Revision XXX2 SCIVs B 3.6.4.2 BASES ACTIONS (continued) C.1 and C.2 If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

D.1 and D.2 If any Required Action and associated Completion Time are not met, the plant must be placed in a condition in which the LCO does not apply. If applicable, the movement of recently irradiated fuel assemblies in the secondary containment must be immediately suspended. Suspension of this activity shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be immediately initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3, Required Action D.1 has been modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving fuel while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

SURVEILLANCE REQUIREMENTS SR 3.6.4.2.1 This SR verifies that each secondary containment manual isolation valve and blind flange that is not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the secondary containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification that those (continued)

JAFNPP B 3.6.4.3-3 Revision 2XXX SGT System B 3.6.4.3 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, a DBA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, SGT System OPERABILITY is required during these MODES.

In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining the SGT System in OPERABLE status is not required in MODE 4 or 5, except for other situations under which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs) or during movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, the SGT system is only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ).

ACTIONS A.1 With one SGT subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status in 7 days. In this Condition, the remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function. However, the overall system reliability is reduced because a single failure in the OPERABLE subsystem could result in the radioactivity release control function not being adequately performed. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant SGT subsystem and the low probability of a DBA occurring during this period.

B.1 and B.2

If the SGT subsystem cannot be restored to OPERABLE status within the required Completion Time in MODE 1, 2, or 3, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable. based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

JAFNPP B 3.6.4.3-4 Revision 2XXX SGT System B 3.6.4.3 BASES ACTIONS (continued) C.1, and C.2.1, and C.2.2 During movement of recently irradiated fuel assemblies, in the secondary containment or during OPDRVs, when Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE SGT subsystem should immediately be placed in operation. This action ensures that the remaining subsystem is OPERABLE, that no failures that could prevent automatic actuation have occurred, and that any other failure would be readily detected.

An alternative to Required Action C.1 is to immediately suspend activities that represent a potential for releasing a significant amount of radioactive material to the secondary containment, thus placing the plant in a condition that minimizes risk. If applicable, movement of recently irradiated fuel assemblies must immediately be suspended. Suspension of this activity must not preclude completion of movement of a component to a safe position. Also, if applicable, actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

LCO 3.0.3 is not applicable in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the Required Actions of Condition C have been modified by a Note stating that LCO 3.0.3 is not applicable.

If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

D.1 If both SGT subsystems are inoperable in MODE 1, 2, or 3, the SGT System may not be capable of supporting the required radioactivity release control function. Therefore, action is required to enter LCO 3.0.3 immediately.

(continued)

JAFNPP B 3.6.4.3-5 Revision 30XXX SGT System B 3.6.4.3 BASES ACTIONS (continued)

E.1 and E.2 When two SGT subsystems are inoperable, if applicable, movement of recently irradiated fuel assemblies in secondary containment must immediately be suspended. Suspension of this activity shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

LCO 3.0.3 is not applicable in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3, Required Action E.1 has been modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 Operating each SGT subsystem fan for > 10 continuous hours ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation with the heaters on for > 10 continuous hours periodically eliminates moisture on the adsorbers and HEPA filters. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.4.3.2 This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

(continued)

JAFNPP B 3.7.3-3 Revision 20 XXX CREVAS System B 3.7.3 BASES LCO (continued) b.A prefilter, two HEPA filters and charcoal adsorbers are not excessively restricting flow and are capable of performing their filtration functions; and c.Ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In order for the CREVAS subsystems to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

The LCO is modified by a Note allowing the CRE boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors the administrative control of the opening is performed by the person{s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated.

APPLICABILITY In MODES 1, 2, and 3, the CREVAS System must be OPERABLE to ensure that the CRE will remain habitable during and following a DBA, since the DBA could lead to a fission product release.

In MODES 4 and 5, the probability and consequences of a DBA are reduced because of the pressure and temperature limitations in these MODES. Therefore, maintaining the CREVAS System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:

a.During operations with a potential for draining the reactor vessel (OPDRVs);and b.Dduring movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, the CREVAS system is only requriedrequired to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor within the previous 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ).

(continued)

JAFNPP B 3.7.3-5 Revision 20 XXX CREVAS System B 3.7.3 BASES ACTIONS (continued)

C.1 and C.2 In MODE 1, 2, or 3, if the inoperable CREVAS subsystem or CRE boundary cannot be restored to OPERABLE status within the required Completion Time, the plant must be placed in a MODE that minimizes accident risk. To achieve this status, the plant must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. D.1. D.2.1. and D.2.2 LCO 3.0.3 is not applicable when in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply.

If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, if the inoperable CREVAS subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREVAS subsystem may be placed in the isolate mode. This action ensures that the remaining subsystem is OPERABLE, and that any active failure will be readily detected. An alternative to Required Action D.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the CRE. This places the plant in a condition that minimizes the accident risk.

If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of this activity shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Action must continue until the OPDRVs are suspended.

(continued)

JAFNPP B 3.7.3-6 Revision 30XXX CREAVS System B 3.7.3 BASES ACTIONS (continued)

E.1 If both CREVAS subsystems are inoperable in MODE 1, 2, or 3 for reasons other than an inoperable CRE boundary (i.e., Condition B), the CREVAS System may not be capable of performing the intended function and the plant is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

F.1 and F.2 LCO 3.0.3 is not applicable when in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODES 1, 2, or 3, the Required Actions of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, with two CREVAS subsystems inoperable or with one or more CREVAS subsystems inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the control room.

This places the plant in a condition that minimizes the accident risk.

If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of this activity shall not preclude completion of movement of a component to a safe position.

If applicable, action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended. SURVEILLANCE REQUIREMENTS SR 3.7.3.1 This SR verifies that a subsystem in a standby mode starts on demand and continues to operate. These subsystems should be checked periodically to ensure that they start and function properly.

As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every three months provides an adequate check on this system. Since the CREVAS System does not contain heaters, it need only be operated for

> 15 minutes to demonstrate the function of the system. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

JAFNPP B 3.7.4-2 Revision 20 XXX Control Room AC System B 3.7.4 BASES APPLICABLE SAFETY ANALYSES (continued) component failure of a component of the Control Room AC System, assuming a loss of offsite power, does not impair the ability of the system to perform its design function. Redundant detectors and controls are provided for control room temperature control. The Control Room AC System is designed in accordance with Seismic Category I requirements. The Control Room AC System is capable of removing sensible and latent heat loads from the control room, including consideration of equipment heat loads and personnel occupancy requirements to ensure equipment OPERABILITY.

The Control Room AC System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 2).

LCO Two redundant subsystems of the Control Room AC System are required to be OPERABLE to ensure that at least one is available, assuming a single active component failure disables the other subsystem. Total system failure could result in the equipment operating temperature exceeding limits.

The Control Room AC System is considered OPERABLE when the individual components necessary to maintain the control room temperature are OPERABLE in both subsystems.

These components include the air handling units, recirculation exhaust fans, air handling unit fans, ductwork, dampers, and associated Instrumentation and controls. The cooling calls of the air handling units may be cooled by the control room chillers, but to satisfy this LCO the Emergency Service Water System must be capable of alignment to provide cooling water directly to the cooling coils.

APPLICABILITY In MODE 1, 2, or 3, the Control Room AC System must be OPERABLE to ensure that the control room temperature will not exceed equipment OPERABILITY limits following control room isolation.

In MODES 4 and 5, the probability and consequences of a Design Basis Accident are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining the Control Room AC System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:

a.During operations with a potential for draining the reactor vessel (OPDRVs); and b.Dduring movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, the Control Room AC system is only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ).

(continued)

JAFNPP B 3.7.4-3 Revision 20 Control Room AC System B 3.7.4 BASES (continues)

ACTIONS A.1 With one contro l r oom AC subsystem inoperable, the inoperable control room AC subsystem must be restored to OPERABLE status within 30 days. With the plant in this condition, the remaining OPERABLE control room AC subsystem is adequate to perf orm the control room air conditioning function. However, the overall reliability is reduced because a single active component failure in the OPERABLE subsystem Could result in loss of the control room air conditioning function. The 30 day Completion Time is based on the low probability of an event occurring requiring control room isolation, the consideration that the remaining subsystem can provide the required protection, and the availability of alternate safety and nonsafely cooling methods. B.1. and B.2 If both control room AC subsystems are inoperable, the Control Room AC System may not be capable of performing its intended function. Therefore, the control room area temperature is required to be monitored to ensure that temperature is being maintained low enough that equipment in the control room is not adversely affected. With the control room temperature being maintained within the temperature limit, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore a control room AC subsystem to OPERABLE status. This Completion Time is reasonable considering that the control room temperature is being maintained within limits and the low probability of an event occurring requiring control room isolation. C.1 and C.2 In MODE 1, 2, or 3, if the inoperable control r oom AC subsystem cann ot be rest ored to OPERABLE status within the associated Completion Time, the plant must be placed In a MODE that minimizes risk. To achieve this status, the plant must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant c onditi ons fr om full p ower c onditi ons in an orderly manner and without challenging plant systems.

D.1 , D.2.1 and D.2.2 LCO 3.0.3 is not applicable while in MODE 4 and 5. However, since recently irradiated fuel assembly movement can occur in MODES 1, 2, or 3 the Required Actions of condition D are modified by a Note indicating that LCO 3.0.3 does not apply. (continued)

JAFNPP B 3.7.4-4 Revision 20 XXX Control Room AC System B 3.7.4 BASES ACTIONS D.1 , D.2.1 and D.2.2 (continued)

If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, if Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE control room AC subsystem may be placed immediately in operation. This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent actuation will occur, and that any active failure will be readily detected. An alternative to Required Action D.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room. This places the plant in a condition that minimizes risk.

If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of this activity shall not preclude completion of movement of a component to a safe position. Also, If applicable, action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission produ ct release. Action must continue until the OPDRVs are suspended.

E.1 and E.2 LCO 3.0.3 is not applicable when in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3 the Required Actions of Condition E are modified by a Note indicating that LCO 3.0.3 does not apply.

If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not a sufficient reason to require a reactor shutdown.

During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, if Required Actions B.1 and B.2 cannot be met within the required Completion Times, action must be taken to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room. This places the plant in a condition that minimizes risk.

(continued)

JAFNPP B 3.7.4-5 Revision 30 Control Room AC System B 3.7.4 BASES ACTIONS E.1 and E.2 (continued)

If applicable, handling of recently irradiated fuel in the secondary

containment must be suspended immediately. Suspension of this activity shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended.

SURVEILLANCE REQUIREMENTS SR 3.7.4.1 This SR verifies that the heat removal capability of the system is sufficient to remove the control room heat load assumed in the safety analyses with ESW providing water to the cooling coils of the air handling units. Heat transfer testing is not performed on the Control Room (CR) and Relay Room (RR) Air Handlin Units (AHUs) as these coolers are closed loop, glycol based systems which are not prone to fouling. To verify the system has the capability to remove the assumed heat, the ESW supply function (safety related) is required to be operable and the following surveillance requirements met: 1) the manual valves needed to initiate ESW flow to these coolers are cycled to verify operability; 2) the ESW supply piping to the AHUs is flushed during check valve testing; and 3) flow rates are measured against target flow rates. Therefore, any degradation would be detected and corrected through the corrective action program. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program JAF calculations verify maximum Allowable Tube Plugging Limit for CR and RR AHUs if maintenance is required on the AHUs. The level of allowed plugging provides a margin in the CR and RR equipment heat load and still maintains the CR and RR below 104° F under accident conditions using ESW at 85° F. In addition, JAF calculations state the potential for plugged tubes is low crediting use of a closed loop cooling water system using glycol/demineralized water (not service water) as the cooling medium.

REFERECES 1.UFSAR, Section 9.9.3.11.

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

3.SEP-SW-001 Rev.0, NRC Generic Letter 89

-13 Service Water Program AC Sources - Shutdown B 3.8.2 JAFNPP B 3.8.2-1 Revision 7 XX B 3.8 ELECT R ICAL POWER SYSTEMS B 3.8.2 AC Sources

- Shutdown BASES BACKROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources

-Operating." In addition to the reserve AC sources described in LCO 3.8.1, during plant shutdown with the main generator off line, the plant emergency buses may be supplied using the 345 kV (backfeed)

AC source. The 345 kV backfeed requires removing the main generator disconnect links that tie the main generator to the 24 kV bus, and providing power from the 345 kV transmission network to energize the main transformers (T1A and T1B), 24 kV bus, normal station service transformer (NSST) 71T-4, and subsequent 4.16 kV distribution and emergency buses. The 345 kV offsite backfeed AC source as well as the two (2) 115 kV offsite circuits are the qualified offsite circuits during outages.

APPLICABLE SAFETY ANALYSES The OPERABILITY of the minimum AC sources during MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the secondary containment ensures that:

a.The facility can be maintained in the shutdown or refueling condition for extended periods: b.Sufficient instrumentation and control capability is available for monitoring and maintaining the plant status: and c.Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as an inadvertent draindown of the vessel or a fuel handling accident involving handling recently irradiated fuel.

Due to radioactive decay, AC electrical power is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ).

In general, when the plant is shutdown the Technical Specifications requirements ensure that the plant has the capability to mitigate the consequences of postulated accidents. However, assuming a single active component failure and concurrent loss of all offsite or loss of all onsite power is not required. The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, and 3 have no specific (continued)

AC Sources - Shutdown B 3.8.2 JAFNPP B 3.8.2-3 Revision XXX 2 BASES (continued)

LCO One qualified offsite circuit capable of supplying one division of the plant Class IE AC power distribution subsystem(s) of LCO 3.8.8, "Distribution Systems

-Shutdown," and one qualified offsite circuit, which may be the same circuit required above, capable of supplying the other division of the plant Class IE AC power distribution subsystem(s) when a second division is required by LCO 3.8.8, ensures that all required loads are powered from offsite power. An OPERABLE EDG subsystem, associated with a 4.16 kV emergency bus required OPERABLE by LCO 3.8.8, ensures that a diverse power source is available for providing electrical power support assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit and EDG subsystem ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the conse quences of postulated events during shutdown (e.g., fuel handling accidents involving handling recently irradiated fuel and reactor vessel draindown). Automatic initiation of the required EDG during shutdown conditions is s pecified in LCO 3.3.5.1, "ECCS Instrumentation," and LCO 3.3.8.1, "LOP Instrumentation."

The qualified offsite circuit(s) must be capable of maintaining rated frequency and voltage while connected to its respective 4.16 kV emergency bus(es), and of accepting required loads during an accident. Qualified offsite circuits are those that are described in LCO 3.8.1 Bases and

the UFSAR and are part of the licensing basis for the plant.

However, since the plant is shutdown, when two offsite circuits are required, they may share one of the incoming switchyard breakers provided the North and South bus disconnect is closed. Also, while in this condition, the automatic opening feature of the disconnect is not required to be OPERABLE. This is allowed since the two offsite circuits are not required to be independent while shutdown.

The required EDG subsystem must be capable of starting, accelerating to rated speed and voltage, force paralleling, and connecting to its respective emergency bus on detection of bus undervoltage. This sequence must be accomplished within 11 seconds. The required EDG subsystem must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the emergency buses.

These capabilities are required to be met with the EDG subsystem in standby condition.

(continued)

AC Sources - Shutdown B 3.8.2 JAFNPP B 3.8.2-4 Revision XXX 2 BASES (continued)

LCO (continued)

Proper sequencing of loads. including tripping of nonessential loads. is a required function for EDG subsystem OPERABILITY. The necessary portions of the Emergency Service Water System and Ultimate Heat Sink are also required to provide appropriate cooling to the required EDG subsystem. In addition. proper sequence operation is an integral part of offsite circuit OPERABILITY since its inoperability impacts the ability to start and maintain energized loads required OPERABLE by LCO 3.8.8.

No automatic transfer capability is required for offsite circuits to be considered OPERABLE.

APPLICABILITY The AC sour ces are required to be OPERABLE in MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the secondary containment to provide assurance that:

a.Systems that provide core cooling providing adequate coolant inventory makeup are available for the irradiated fuel assemblies in a.the core in case of an inadvertent draindown of the reactor vessel

b.Systems needed to mitigate a fuel handling accident involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ) are available; c.Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and d.Instrumentation and control capability is available for monitoring and maintaining the plant in a cold shutdown condition or refueling condition.

AC power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.1.

ACTIONS LCO 3.0.3 is not applicable while in MODE 4 or 5. However.

since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODE 4 or 5.

LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Entering LCO 3.0.3. while in MODE 1. 2. or 3 would require the unit to be shutdown unnecessarily.

(continued)

AC Sources - Shutdown B 3.8.2 JAFNPP B 3.8.2-4 Revision XXX 2 AC Sources - Shutdown B 3.8.2 JAFNPP B 3.8.2-5 Revision XXX 14 BASES ACTIONS (continued)

A.1 An offsite circuit is considered inoperable if it is not available to one required 4.16 kV emergency bus. If two 4.16 kV emergency buses are required per LCO 3.8.8, one division with offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, and recently irradiated fuel movement, and operations with a potential for draining the reactor vessel. By the allowance of the option to declare required features inoperable with no offsite power, appropriate restrictions can be implemented in accordance with the affected required feature(s) LCOs' ACTIONS. These required features are those that are assumed in the safety analysis to function to mitigate events postulated during shutdown, such as an inadvertent draindown of the reactor vessel or a fuel handling accident involving recently irradiated fuel. These required features do not include monitoring requirements.

A.2.1, A.2.2, A.2.3, A.2.4, B.1, B.2, and B.3, and B.4 With an offsite circuit not available to all required 4.16 kV emergency buses, the option still exists to declare all required features inoperable per Required Action A.1. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required EDG subsystem inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS and, movement of recently irradiated fuel assemblies in the secondary containment., and activities that could result in inadvertent draining of the reactor vessel.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de

-energization.

Therefore, the Required Actions of Condition A have been modified by a Note to indicate that when Condition A is entered with no AC power to any (continued)

AC Sources - Shutdown B 3.8.2 JAFNPP B 3.8.2-6 Revision 14 XX BASES ACTIONS A.2.1, A.2.2, A.2.3, A.2.4, B.1, B.2, and B.3 , and B.4 (continued) required 4.16 kV emergency bus, ACTIONS for LCO 3.8.8 must be immediately entered. This Note allows Condition A to provide requirements for the loss of an offsite circuit whether or not a division is de-energized. LCO 3.8.8 provides the appropriate restrictions for the situation involving a de

-energized division.

SURVEILLANCE REQUIREMENTS SR 3.8.2.1 SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.7 is not required to be met since the main generator is not used to provide AC power while shutdown. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

This SR is modified by two Notes. The reason for Note 1 is to preclude requiring the OPERABLE EDG subsystem from being paralleled with the reserve power network or otherwise rendered inoperable during the performance of SRs, and to preclude de

-energizing a required 4.16 kV emergency bus or disconnecting a required reserve circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required reserve circuit and EDG subsystem. It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the EDG subsystem and reserve circuit is req uired to be OPERABLE.

Note 2 states that SRs 3.8.1.10 and 3.8.1.12 are not required to be met when its associated ECCS subsystem(s) are not required to be OPERABLE.

These SRs demonstrate the EDG response to an ECCS signal (either alone or in conjunction with a loss of power signal). This is consistent with the ECCS instrumentation requirements that do not require the ECCS signal when the ECCS System is not required to be OPERABLE per LCO 3.5.2, "ECCS-Shutdown." REFERENCES

1. 10 CFR 50.36(c)(2)(ii).

DC Sources - Shutdown B 3.8.5 JAFNPP B 3.8.5-1 Revision 2XXX B 3.8 ELECT R ICAL POWER SYSTEMS B 3.8.5 DC Sources

- Shutdown BASES BACKROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating." APPLICABLE SAFETY ANALYSES The initial conditions of Design Basis Accident and transient analyses in the UFSAR, Chapter 6 (Ref. 1) and Chapter 14 (Ref. 2), assume that Engineered Safeguards systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the emergency diesel generators (EDGs), emergency auxiliaries, and control and switching during all MODES of operation and during movement of recently irradiated fuel assemblies in the secondary containment.

The OPERABILITY of the DC subsystems is consistent with the

initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the secondary containment ensures that:

a.The facility can be maintained in the shutdown or refueling condition for extended periods: b.Sufficient instrumentation and control capability is available for monitoring and maintaining the plant status: and c.Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as an inadvertent draindown of the vessel or a refueling accident involving handling recently irradiated fuel.

Due to radioactive decay, DC electrical power is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ).

In general, when the unit is shutdown, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and (continued)

DC Sources - Shutdown B 3.8.5 JAFNPP B 3.8.5-2 Revision 2XXX BASES APPLICABLE SAFETY ANALYSES (continued) concurrent loss of all offsite or all onsite power is not required. The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, and 3 have no specific analyses in MODES 4 and 5. Worst case bounding events are deemed not credible in MODES 4 and 5 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems. The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents.

Worst case Design Basis Accidents which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES.

More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result , in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91

-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii)

(Ref. 3). LCO One 125 VDC electrical power subsystem consisting of one 125 V battery, one battery charger, and the corresponding control equipment and interconnecting cabling supplying power to the associated bus is required to be OPERABLE to support one DC distribution subsystem required OPERABLE by LCO 3.8.8, "Distribution Systems - Shutdown." This requirement ensures the availability of sufficient DC electrical power sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., refueling accidents involving handling recently irradiated fuel and inadvertent reactor vessel draindown

). (continued)

DC Sources - Shutdown B 3.8.5 JAFNPP B 3.8.5-3 Revision 14XXX BASES APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the secondary containment provide assurance that:

a.Required features to provide core cooling adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core in case of an inadvertent draindown of the reactor vessel; b.Required features needed to mitigate a fuel handling accident involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ) are available;

c.Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and d.Instrumentation and control capability is available for monitoring and maintaining the plant in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.4.

ACTIONS LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1, 2 or 3, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, or 3 would require the unit to be shutdown unnecessarily.

A.1, A.2.1, A.2.2, and A.2.3, and A.2.4 By allowance of the option to declare req uired features inoperable with the associated DC electrical power subsystem inoperable, appropriate restrictions are implemented in accordance with the affected system LCOs' ACTIONS. These required features are those that are assumed in the safety analysis to function to mitigate events postulated during shutdown, such a s an inadvertent draindown of the reactor vessel or a fuel handling accident involving recently irradiated fuel. These required features do not include monitoring requirements.

However, in many instances this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of recently irradiated fuel assemblies in the (continued)

DC Sources - Shutdown B 3.8.5 JAFNPP B 3.8.5-4 Revision 14XXX BASES ACTIONS A.1, A.2.1

, A.2.2 , and A.2.3 and A.2.4 (continued) secondary containment, and any activities that could result in inadvertent draining of the reactor vessel). Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystem and to continue this action until restoration is accomplished in order to provide the necessary DC ele ctrical power to the plant safety systems. The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power. SURVEILLANCE REQUIREMENTS SR 3.8.5.1 SR 3.8.5.1 requires performance of all Surveillances required by SR 3.8.4.1 through SR 3.8.4.4. Therefore, see the corresponding Bases for LCO 3.8.4 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DC electrical power subsystem from being discharged below their capability to provide the required power supply or otherwise rendered inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not required.

REFERENCES 1.UFSAR, Chapter 6.

2.UFSAR, Chapter 14.

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

Distribution Systems - Shutdown B 3.8.8 JAFNPP B 3.8.8-1 Revision 2XXX B 3.8 ELECT R ICAL POWER SYSTEMS B 3.8.8 Distribution Systems

- Shutdown BASES BACKROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating." APPLICABLE SAFETY ANALYSES The initial conditions of Design Basis Accident and transient analyses in the UFSAR. Chapter 6 (Ref. 1) and Chapter 14 (Ref. 2), assume Engineered Safeguards systems are OPERABLE. The AC and 125 VDC electrical power distribution systems are designed to provide sufficient capacity, capability , redundancy , and reliability to ensure the availability of necessary power to Engineered Safeguards systems so that the fuel. Reactor Coolant System. And containment design limits are not exceeded.

The OPERABILITY of the AC and 125 VDC electrical power distribution systems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum AC and 125 VDC electrical power sources and associated power distribution subsystems during MODES 4 and 5. and during movement of recently irradiated fuel assemblies in the secondary containment ensures that:

a.The facility can be maintained in the shutdown or refueling condition for extended periods:

b.Sufficient instrumentation and control capability is available for monitoring and maintaining the plant status: and c.Adequate power is provided to mitigate events postulated during shutdown, such as an inadvertent draindown of the vessel or a refueling accident involving handling recently irradiated fuel. Due to radioactive decay, DC electrical power is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ).

The AC and 125 VDC electrical power distribution systems

satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3).

(continued)

Distribution Systems - Shutdown B 3.8.8 JAFNPP B 3.8.8-2 Revision 2XXX BASES (continued)

LCO Various combinations of subsystems, equipment, and components are required OPERABLE by other LCOs, depending on the specific plant condition. Implicit in those requirements is the required OPERABILITY of necessary support required features. This LCO explicitly requires energization of the portions of the electrical distribution system necessary to support OPERABILITY of Technical Specification required systems, equipment, and components - both specifica lly addressed by their own LCO, and implicitly required by the definition of OPERABILITY.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents involving handling recently irradiated fuel and inadvertent reactor vessel draindown

). APPLICABILITY The AC and 125 VDC electrical power distribution subsystems required to be OPERABLE in MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the secondary containment provide assurance that:

a.Systems that provide core cooling to provide adequate coolant inventory makeup are available for the irradiated fuel in the core in case of an inadvertent draindown of the reactor vessel

b.Systems needed to mitigate a fuel handling accident involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ) are available; c.Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and d.Instrumentation and control capability is available for monitoring and maintaining the plant in a cold shutdown condition or refueling condition.

The AC, and 125 VDC electrical power distribution subsystem requirements for MODES 1, 2, and 3 are covered in LCO 3.8.7.

(continued)

Distribution Systems - Shutdown B 3.8.8 JAFNPP B 3.8.8-3 Revision 14XXX BASES ACTIONS LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, or 3 would require the unit to be shutdown unnecessarily.

A.1, A.2.1, A.2.2, A.2.3, and A.2.4, and A.2.5 Although redundant required features may 'require redundant divisions of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem division may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and, recently irradiated fuel movement., and operations with a potential for draining the reactor vessel.

By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. These required features are those that are assumed in the safety analysis to function to mitigate events postulated during shutdown, such as an inadvertent draindown of the reactor vessel or a fuel handling accident involving recently irradiated fuel. These required features do not include monitoring requirements. In many instances this option may involve undesired administrative efforts.

Therefore, the allowance for sufficiently conservative actions is made, (i.e., to suspend CORE ALTERATIONS and, movement of recently irradiated fuel assemblies in the secondary containment, and any activities that could result in inadvertent draining of the reactor vessel

).

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and 125 VDC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the p lant safety systems.

Not Withstanding performance of the above conservative Required Actions, a required residual heat removal

-shutdown cooling (RHR-SDC) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR

-SDC ACTIONS would not be entered. Therefore, Required Action A.2.5 is provided to direct declaring RHR

-SDC inoperable, which results in taking the appropriate RHR

-SDC ACTIONS.

(continued)

JAFNPP B 3.10.1-2 Revision 0 XXX Inservice Leak and Hydrostatic Test Operation B 3.10.1 BASES APPLICABLE SAFETY ANALYSES (continued) during the performance of hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a recirculation line break (Refs. 2 and 3) will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 4. Therefore , these requirements will conservatively limit radiation releases to the environment.

In the unlikely event of a largeany primary system leak that could result in draining of the RPV , the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The makeup capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LCO 3.5.2. "ECCS - ShutdownReactor Pressure Vessel (RPV) Water Inventory Control." would be more than adequate to keep the RPV water level above the TAF core flooded under this low decay heat load condition. Small system leaks would be detected by leakage inspections before significant inventory loss occurred.

For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to the secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.

As described in LCO 3.0.7. compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) (Ref. 5) apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.

LCO As described in LCO 3.0.7. compliance with this Special Operations LCO is optional. Operation at reactor coolant temperatures> 212°F can be in accordance with Table 1.1-1 for MODE 3 operation without meeting this Special Operations LCO or its ACTIONS. This option may be required due to P/T limits, however, which require testing at temperatures

> 212°F. while performance of inservice leak and hydrostatic testing results in inoperability of subsystems required when

> 212°F. (continued)

v t e Letter Sequence Request
EPID:L-2017-LLA-0311, TSTF-542 (Approved, Closed)
Initiation Request Acceptance... Supplement Administration Questions 23 March 2018 26 March 2018 Answers 19 April 2018 Results Approval Other:
MONTHYEAR2018-03-23 [Table View]

JAFP-17-0093, Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2

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2.2 Variations

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JAFP-17-0093, Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2

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Subject:

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2.0 ASSESSMENT

2.1 Applicability

2.2 Variations

3.0 REGULATORY

4.0 ENVIRONMENTAL

5.0 REFERENCES

1.0 DESCRIPTION

2.1 Applicability

4.0 ENVIRONMENTAL

5.0 REFERENCES

3.5.2 overlaps

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