TSTF-09-24, Technical Specification Task Force Recommended Changes to Be Incorporated in Revision 4 of the Standard Technical Specifications, NUREG-1430 Through 1434

Technical Specification Task Force Recommended Changes to Be Incorporated in Revision 4 of the Standard Technical Specifications, NUREG-1430 Through 1434

ML093350037
Person / Time
Site:	Technical Specifications Task Force
Issue date:	11/30/2009
From:	Croft W, Joseph Messina, Raidy T, Schrader K BWR Owners Group, PWR Owners Group, Technical Specifications Task Force
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, NUREG-1434, TSTF-09-24
Download: ML093350037 (49)

Text

TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY November 30, 2009 TSTF-09-24 PROJ0753 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Recommended Changes to be Incorporated in Revision 4 of the Standard Technical Specifications, NUREG-1430 through 1434 As discussed at the November 4 TSTF / NRC public meeting, the NRC is preparing to create Revision 4 of the Standard Technical Specifications (STS). The STS are published as NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, and NUREG-1434.

The attachment lists the TSTF Travelers that the TSTF recommends be incorporated into Revision 4. Eighteen of the Travelers have been previously reviewed and approved by the NRC.

An additional ten Travelers are currently under NRC consideration and are expected to be approved before the end of the first calendar quarter of 2010. There are four "T" Travelers that the NRC has not reviewed, but that the TSTF recommends be incorporated in Revision 4 as administrative corrections. Copies of these four Travelers are enclosed.

The TSTF looks forward to working with the NRC in this important endeavor.

Should you have any questions, please do not hesitate to contact us.

Kenneth J. Schrader (PWROG/W) John Messina (BWROG)

Thomas W. Raidy (PWROG/CE) Wendy E. Croft (PWROG/B&W)

Attachment Enclosures cc: Robert Elliott, Technical Specifications Branch, NRC Michelle Honcharik, Special Projects Branch, NRC 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation

TSTF Travelers Recommended to be Incorporated into Revision 4 of the Improved Standard Technical Specifications Approved Travelers

1. TSTF-412-A, Rev. 3, "Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable."

2. TSTF-425-A, Rev. 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b."

3. TSTF-427-A, Rev. 2, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY."

4. TSTF-448-A, Rev. 3, "Control Room Habitability."

5. TSTF-454-A, Rev. 1, "Extend PCIV Completion Times (NEDC-33046) ."

6. TSTF-471-A, Rev. 1, "Eliminate use of term CORE ALTERATIONS in ACTIONS and Notes."

7. TSTF-475-A, Rev. 1, "Control Rod Notch Testing Frequency and SRM Insert Control Rod Action."

8. TSTF-476-A, Rev. 1, "Improved BPWS Control Rod Insertion Process (NEDO-33091)."

9. TSTF-477-A, Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems."

10. TSTF-478-A, Rev. 2, "BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control."

11. TSTF-484-A, Rev. 0, "Use of TS 3.10.1 for Scram Time Testing Activities."

12. TSTF-486-A, Rev. 2, ."Revise MTC Surveillance for Startup Test Activity Reduction (STAR) Program (WCAP-16011)."

13. TSTF-487-A, Rev. 1, "Relocate DNB Parameters to the COLR."

14. TSTF-490-A, Rev. 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec" Note: The TSTF acknowledges that there are currently questions on TSTF-490 which may affect its incorporation in Revision 4.

15. TSTF-491-A, Rev. 2, "Removal of Main Steam and Main Feedwater Valve Isolation Times From Technical Specifications."

16. TSTF-497-A, Rev. 0, "Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less."

Page 1

TSTF Travelers Recommended to be Incorporated into Revision 4 of the Improved Standard Technical Specifications

17. TSTF-498-A, Rev. 1, "Risk-Informed Containment Isolation Valve Completion Times (BAW-2461)."

18. TSTF-511-A, Rev. 0, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26."

Travelers Anticipated to be Approved by the First Quarter of 2010

1. TSTF-422, Rev. 2, "Change in Technical Specifications End States (CE NPSD-1186)."

2. TSTF-423, Rev. 1, "Technical Specifications End States, NEDC-32988-A."

3. TSTF-431, Rev. 3, "Change in Technical Specifications End States (BAW-2441)."

4. TSTF-446, Rev. 3, "Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP-15791)."

5. TSTF-493, Rev. 4, "Clarify Application of Setpoint Methodology for LSSS Functions."

Note: The TSTF and NRC are working to determine the appropriate method to incorporate TSTF-493 into the ISTS.

6. TSTF-500, Rev. 2, "DC Electrical Rewrite - Update to TSTF-360."

7. TSTF-501, Rev. 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control."

8. TSTF-508, Rev. 1, "Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation."

9. TSTF-513, Rev. 2, "Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation."

10. TSTF-514, Rev. 1, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation."

Travelers Correcting Errors to be Incorporated as Administrative Actions

1. TSTF-494-T, Rev. 0, "Correct Bases Discussion of Figure B3.0-1."

2. TSTF-516-T, Rev. 0, "Remove Incorrect Sentence in ATWS-RPT Bases."

3. TSTF-518-T, Rev. 0, "Correct Specification 3.1.5, Control Rod Scram Accumulators, Applicability Bases."

4. TSTF-519-T, Rev. 0, "Increase Standardization in Condition and Required Action Notes."

Page 2

BWROG-106, Rev. 0 TSTF-494-T, Rev. 0 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Correct Bases Discussion of Figure B3.0-1 NUREGs Affected: 1430 1431 1432 1433 1434 Note: This "T" Traveler has been reviewed and approved by the Technical Specification Task Force and is made available as a template for plant-specific license amendments. This Traveler has not been reviewed and approved by the Nuclear Regulatory Commission. Any plant submitting a license amendment request to adopt this change should inform the industry contact listed below and copy the Technical Specification Task Force on their submittal letter.

Classification 2) Bases Only Change Recommended for CLIIP?: No Correction or Improvement: Correction NRC Fee Status:

Benefit: Improves Bases Industry

Contact:

John Messina, (330) 384-5878, jmessina@firstenergycorp.com 1.0 Description This Traveler revises the Examples that discuss Figure B 3.0-1 in the Bases of LCO 3.0.6 to more accurately describe a loss of safety function and to be internally consistent.

2.0 Proposed Change The Bases of LCO 3.0.6 are revised. Example B 3.0.6-1 and Example B 3.0.6-2 are changed to be more clear and be internally consistent.

3.0 Background

Figure B 3.0-1 and the accompanying discussion, including Examples B 3.0.6-1, B 3.0.6-2, and B 3.0.6-3, were added by TSTF-71, Revision 2 and approved by the NRC on 10/27/1998. The purpose of the figure and the examples is to clarify the discussions of a loss of safety function and cross train checks.

Examples B 3.0.6-1, B 3.0.6-2, and B 3.0.6-3 are not consistent.

Example B 3.0.6-1 describes a situation in which there is a loss of safety function for one system (System

5) but it does not mention the loss of safety function in systems supported by System 5 (Systems 10 and 11). However, Example B 3.0.6-3 presents a similar situation and describes all of the affected systems.

Example B 3.0.6-2 describes a situation in which there is a loss of safety function for a supported system (System 11) and goes on to discuss an OPERABLE supporting system (System 5). This is inconsistent with Examples B 3.0.6-1 and B 3.0.6-3 which do not discuss OPERABLE supporting systems.

These inconsistencies are confusing and should be corrected in order for the Bases to be a useful tool in understanding the Technical Specifications.

30-Nov-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-106, Rev. 0 TSTF-494-T, Rev. 0 4.0 Technical Analysis Example B 3.0.6-1 is changed from:

If System 2 of Train A is inoperable and System 5 of Train B is inoperable, a loss of safety function exists in supported System 5.

to If System 2 of Train A is inoperable and System 5 of Train B is inoperable, a loss of safety function exists in Systems 5, 10, and 11.

Examining Figure B 3.0-1, it is clear that if there is a loss of safety function in System 5, there is also a loss of safety function in the systems supported by System 5, Systems 10 and 11. This relationship is explicitly listed in Example B 3.0.6-3 and to not do so here is inconsistent and confusing as it leads the reader to believe that Systems 10 and 11 do not have a loss of safety function.

Example B 3.0.6-2 is changed from:

If System 2 of Train A is inoperable, and System 11 of Train B is inoperable, a loss of safety function exists in System 11 which is in turn supported by System 5.

to If System 2 of Train A is inoperable, and System 11 of Train B is inoperable, a loss of safety function exists in System 11.

The phrase "which in turn is supported by System 5" is confusing. System 5 is not inoperable and does not lead to the loss of safety function. Examples B 3.0.6-1 and B 3.0.6-3 do not discuss OPERABLE support systems. This phrase is adds no value and leads the reader to believe there is some special relationship with System 5 which does not exist.

5.0 Regulatory Analysis This section is not required for a Bases-only change.

6.0 Environmental Consideration This section is not required for a Bases-only change.

7.0 References None.

Revision History OG Revision 0 Revision Status: Active 30-Nov-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-106, Rev. 0 TSTF-494-T, Rev. 0 OG Revision 0 Revision Status: Active Revision Proposed by: TSICC Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 26-Oct-05 Owners Group Comments (No Comments)

Owners Group Resolution: Date:

TSTF Review Information TSTF Received Date: 04-May-06 Date Distributed for Review 04-May-06 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

Revised example 1 to delete the word "supported."

TSTF Resolution: Approved for Use Date: 18-May-06 Affected Technical Specifications LCO 3.0.6 Bases LCO Applicability 30-Nov-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-494, Rev. 0 LCO APPLICABILITY B 3.0 BASES LCO 3.0.6 (continued)

However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.

This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, when a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

Specification 5.5.15, "Safety Function Determination Program (SFDP),"

ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross train checks to identify a loss of safety function for those support systems that support multiple and redundant safety systems are required.

The cross train check verifies that the supported systems of the remaining OPERABLE support systems are OPERABLE, thereby ensuring safety function is retained. [ A loss of safety function may exist when a support system is inoperable, and:

a. A required system redundant to system(s) supported by the inoperable support system is also inoperable (EXAMPLE B 3.0.6-1),

b. A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable (EXAMPLE B 3.0.6-2), or

c. A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable (EXAMPLE B 3.0.6-3).

EXAMPLE B 3.0.6-1 If System 2 of Train A is inoperable and System 5 of Train B is inoperable, a loss of safety function exists in supported Systems 5, 10, and 11.

BWOG STS B 3.0-9 Rev. 3.0, 03/31/04

TSTF-494, Rev. 0 LCO APPLICABILITY B 3.0 BASES LCO 3.0.6 (continued)

EXAMPLE B 3.0.6-2 If System 2 of Train A is inoperable, and System 11 of Train B is inoperable, a loss of safety function exists in System 11 which is in turn supported by System 5.

EXAMPLE B 3.0.6-3 If System 2 of Train A is inoperable, and System 1 of Train B is inoperable, a loss of safety function exists in Systems 2, 4, 5, 8, 9, 10 and

11. ]

If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

[ Figure B 3.0-1 Configuration of Trains and Systems ]

BWOG STS B 3.0-10 Rev. 3.0, 03/31/04

TSTF-494, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)

However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.

This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, when a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

Specification 5.5.15, "Safety Function Determination Program (SFDP),"

ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross train checks to identify a loss of safety function for those support systems that support multiple and redundant safety systems are required.

The cross train check verifies that the supported systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained. [ A loss of safety function may exist when a support system is inoperable, and:

a. A required system redundant to system(s) supported by the inoperable support system is also inoperable (EXAMPLE B 3.0.6-1),

b. A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable (EXAMPLE B 3.0.6-2), or

c. A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable (EXAMPLE B 3.0.6-3).

EXAMPLE B 3.0.6-1 If System 2 of Train A is inoperable and System 5 of Train B is inoperable, a loss of safety function exists in supported Systems 5, 10, and 11.

WOG STS B 3.0-9 Rev. 3.0, 03/31/04

TSTF-494, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)

EXAMPLE B 3.0.6-2 If System 2 of Train A is inoperable, and System 11 of Train B is inoperable, a loss of safety function exists in System 11 which is in turn supported by System 5.

EXAMPLE B 3.0.6-3 If System 2 of Train A is inoperable, and System 1 of Train B is inoperable, a loss of safety function exists in Systems 2, 4, 5, 8, 9, 10 and

11. ]

If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

[ Figure B 3.0-1 Configuration of Trains and Systems ]

This loss of safety function does not require the assumption of additional single failures or loss of offsite power. Since operations is being restricted in accordance with the ACTIONS of the support system, any resulting temporary loss of redundancy or single failure protection is taken WOG STS B 3.0-10 Rev. 3.0, 03/31/04

TSTF-494, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued) some other Required Action. Regardless of whether it is immediate or after some delay, when a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

Specification 5.5.15, "Safety Function Determination Program (SFDP),"

ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross train checks to identify a loss of safety function for those support systems that support multiple and redundant safety systems are required.

The cross train check verifies that the supported systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained. [ A loss of safety function may exist when a support system is inoperable, and:

a. A required system redundant to system(s) supported by the inoperable support system is also inoperable (EXAMPLE B 3.0.6-1),

b. A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable (EXAMPLE B 3.0.6-2), or

c. A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable (EXAMPLE B 3.0.6-3).

EXAMPLE B 3.0.6-1 If System 2 of Train A is inoperable and System 5 of Train B is inoperable, a loss of safety function exists in supported Systems 5, 10, and 11.

EXAMPLE B 3.0.6-2 If System 2 of Train A is inoperable, and System 11 of Train B is inoperable, a loss of safety function exists in System 11 which is in turn supported by System 5.

CEOG STS B 3.0-9 Rev. 3.0, 03/31/04

TSTF-494, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)

Specification 5.5.12, "Safety Function Determination Program (SFDP),"

ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross division checks to identify a loss of safety function for those support systems that support safety systems are required. The cross division check verifies that the supported systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained. [ A loss of safety function may exist when a support system is inoperable, and:

a. A required system redundant to system(s) supported by the inoperable support system is also inoperable (EXAMPLE B 3.0.6-1),

b. A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable (EXAMPLE B 3.0.6-2), or

c. A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable (EXAMPLE B 3.0.6-3).

EXAMPLE B 3.0.6-1 If System 2 of Train A is inoperable and System 5 of Train B is inoperable, a loss of safety function exists in supported Systems 5, 10, and 11.

EXAMPLE B 3.0.6-2 If System 2 of Train A is inoperable, and System 11 of Train B is inoperable, a loss of safety function exists in System 11 which is in turn supported by System 5.

EXAMPLE B 3.0.6-3 If System 2 of Train A is inoperable, and System 1 of Train B is inoperable, a loss of safety function exists in Systems 2, 4, 5, 8, 9, 10 and

11. ]

BWR/4 STS B 3.0-9 Rev. 3.0, 03/31/04

TSTF-494, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)

Specification 5.5.12, "Safety Function Determination Program (SFDP),"

ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross division checks to identify a loss of safety function for those support systems that support safety systems are required. The cross division check verifies that the supported systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained. [ A loss of safety function may exist when a support system is inoperable, and:

a. A required system redundant to system(s) supported by the inoperable support system is also inoperable (EXAMPLE B 3.0.6-1),

b. A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable (EXAMPLE B 3.0.6-2), or

c. A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable (EXAMPLE B 3.0.6-3).

EXAMPLE B 3.0.6-1 If System 2 of Train A is inoperable and System 5 of Train B is inoperable, a loss of safety function exists in supported Systems 5, 10, and 11.

EXAMPLE B 3.0.6-2 If System 2 of Train A is inoperable, and System 11 of Train B is inoperable, a loss of safety function exists in System 11 which is in turn supported by System 5.

EXAMPLE B 3.0.6-3 If System 2 of Train A is inoperable, and System 1 of Train B is inoperable, a loss of safety function exists in Systems 2, 4, 5, 8, 9, 10 and

11. ]

BWR/6 STS B 3.0-9 Rev. 3.0, 03/31/04

BWROG-113, Rev. 0 TSTF-516-T, Rev. 0 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Remove Incorrect Sentence in ATWS-RPT Bases NUREGs Affected: 1430 1431 1432 1433 1434 Note: This "T" Traveler has been reviewed and approved by the Technical Specification Task Force and is made available as a template for plant-specific license amendments. This Traveler has not been reviewed and approved by the Nuclear Regulatory Commission. Any plant submitting a license amendment request to adopt this change should inform the industry contact listed below and copy the Technical Specification Task Force on their submittal letter.

Classification 2) Bases Only Change Recommended for CLIIP?: No Correction or Improvement: Correction NRC Fee Status:

Benefit: Improves Bases Industry

Contact:

John Messina, (330) 384-5878, jmessina@firstenergycorp.com 1.0 - Description The Bases for Specification 3.3.4.2, "ATWS-RPT Instrumentation," states that ATWS-RPT is not assumed in the safety analysis. It has been determined that it is common practice for the domestic BWR fuel vendors to model the ATWS-RPT function in their plant transient models, for plants that have the function installed. Therefore, this sentence is not accurate.

The proposed change revises the Specification 3.3.4.2 Bases to remove the incorrect statement.

2.0 - Proposed Change The proposed change eliminates the first sentence in the Specification 3.3.4.2, "ATWS-RPT Instrumentation," the "Applicable Safety Analysis, LCO, and Applicability" section of the Bases, which states, "The ATWS-RPT is not assumed in the safety analysis."

3.0 - Background Some plants BASES state that the ATWS-RPT is credited in the ASME overpressurization safety analysis. Other plants (Duane Arnold, Monticello, Brunswick, and Cooper for example) have modified the standard ITS wording. Duane Arnolds TS BASES states "The ATWS-RPT is not assumed to function during or after a design basis accident." Monticellos TS BASES reads "The ATWS-RPT is not assumed to mitigate any accident or transient in the original design or licensing basis in the safety analysis." The Brunswick TS BASES now states "The ATWS-RPT is not assumed to mitigate any accident or transient in the safety analysis." Similarly, the Cooper TS BASES states "The ATWS-RPT is not assumed in the safety analysis to mitigate any accident or transient."

However, these statements may not adequately correct the standard Bases. A clearer change is to eliminate the sentence entirely.

11-Feb-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-113, Rev. 0 TSTF-516-T, Rev. 0 4.0 - Technical Analysis In the case of the Load Rejection event, the ATWS-RPT trip does not occur until after the minimum Critical Power Ratio (CPR) has occurred. Therefore the trip does not have any effect on the delta CPR severity of the transient event. For the ASME overpressure MSIV Isolation event, the ATWS-RPT does have an effect on the peak pressure for the event, however it is not a large effect (typically less than 10 psi) and it can actually either increase or decrease the peak pressure, depending on the plant. For some plants, the reduction in core flow from the ATWS-RPT can come too late in the event to affect the power, but the reduction in flow can cause an increase in the steam rate, leading to higher calculated dome pressures than would be calculated without the trip. Thus, it does not appear that the ATWS-RPT necessarily acts to mitigate the transient events, nor does it appear that the function plays an important role in determining the results of the reload licensing transient being analyzed. Therefore, the trip function could be removed from the vendors transient analysis models with little or no consequences to the customer. However, given that the system exists and has an effect on the analysis results, the appropriate course of action is to retain the ATWS-RPT in the safety analysis and remove the incorrect sentence in the Bases.

An example 10 CFR 50.59 screen for removing the sentence is attached.

5.0 - Regulatory Analysis No regulatory analysis is requried for a Bases-only Traveler.

6.0 - Environmental Consideration No environmental consideration is requried for a Bases-only Traveler.

7.0 - References None Revision History OG Revision 0 Revision Status: Active Revision Proposed by: BWROG Revision

Description:

Original Issue 11-Feb-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-113, Rev. 0 TSTF-516-T, Rev. 0 OG Revision 0 Revision Status: Active Owners Group Review Information Date Originated by OG: 09-Dec-08 Owners Group Comments (No Comments)

Owners Group Resolution: Approved Date: 09-Dec-08 TSTF Review Information TSTF Received Date: 20-Jan-09 Date Distributed for Review 20-Jan-09 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved for Use Date: 11-Feb-09 Affected Technical Specifications S/A 3.3.4.2 Bases ATWS-RPT Instrumentation 11-Feb-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-516-T, Rev. 0 50.59 SCREEN 50.59 Screen No. - Rev. No. Page 1 of 3 I Activity/Document Number: BWROG-113 and Revision Number: 0

Title:

Revise TS Bases B 3.3.4.2, "ATWS-RPT Instrumentation," to remove statement indicating that ATWS-RPT is not assumed in the safety analysis.

Brief Description of activity (what is being changed and why):

It has been determined that it is common practice for the domestic BWR fuel vendors to model the ATWS-RPT function in their plant transient models, for plants that have the function installed. Therefore, the statement is inaccurate.

Continued II Applicability Determination:

Other applicable process identified during the applicability determination:

None Continued III Document Review:

1. List the documents (UFSAR, Technical Specifications, and other documents) reviewed where relevant information was found, including section numbers.

UFSAR 7.7.1.2, Recirc Flow Control System, UFSAR 15.2.2, Generator Load Rejection, UFSAR 15.2.3, Turbine Generator Trip, UFSAR 5.2.2, Overpressurization Protection.

TS 3.3.4.2 and TS Bases B 3.3.4.2, ATWS-RPT Instrumentation. COLR Cycle 13, Rev. 1.

Continued

2. List UFSAR section that will be changed and list the LCR.

None Continued

3. List relevant 50.59 screen number if previously reviewed and approved. (See Section 5.2.3 of MLS Appendix C for additional guidance.)

None Continued IV Identify relevant UFSAR design functions: (See Section 5.2.4 of MLS Appendix C for additional guidance.)

To lessen the effect of an ATWS event, the recirculation pumps are tripped adding negative reactivity from the increase in steam voiding in the core area as core flow decreases. Also credited in Load Rejection Event &

Overpressure Protection analyses Continued DTC: TPMMLS DSN: MLS14002 Rev. 7 P1/3 File: 1703.22 Approved: 7-24-07 Issued: 7-30-07 DTC: VSSCRN DSN: File: 0923.07 IP: I

TSTF-516-T, Rev. 0 50.59 SCREEN 50.59 Screen No. - Rev. No. Page 2 of 3 V 50.59 Screening Questions (Check correct response.) (See Section 5.2.5 of the 50.59 Resource Manual, MLS Appendix C [RM] for additional guidance.)

Yes No 1. Does the proposed activity involve a change to an SSC that adversely affects a UFSAR described design function? (See Section 5.2.5.1 of the RM.)

Yes No 2. Does the proposed activity involve a change to a procedure that adversely affects how UFSAR described SSC design functions are performed or controlled? (See Section 5.2.5.2 of the RM.)

Yes No 3. Does the proposed activity involve revising or replacing a UFSAR described evaluation methodology that is used in establishing the design bases or used in the safety analyses? (See Section 5.2.5.3 of the RM.)

Yes No 4. Does the proposed activity involve a test or experiment not described in the UFSAR, where an SSC is used or controlled in a manner that is outside the reference bounds of the design for that SSC or is inconsistent with the analyses or descriptions in the UFSAR? (See Section 5.2.5.4 of the RM.)

Yes No 5. Does the proposed activity require a change to the Technical Specifications?

(See Section 5.2.5.5 of the RM.)

VI 50.59 Screening Results (See Section 5.2.6 of MLS Appendix C.)

If all questions are answered NO, then implement the activity per the applicable plant procedure for the type of activity without obtaining a License Amendment.

If screen question 5 is answered YES, then request and receive a License Amendment prior to implementation of the activity.

If screen question 5 is answered NO and question 1, 2, 3, or 4 is answered YES, then a 50.59 Evaluation shall be performed.

If a 50.59 Evaluation is required, enter the 50.59 Evaluation No. for this activity: N/A VII 50.59 Screening Conclusion (See Section 5.2.7 of MLS Appendix C.)

If the conclusion of the screening questions is that a 50.59 evaluation is not required, provide an overall justification for that determination in the Comments Section below.

VIII Screen Approval Screen Preparer:

Print Sign Date Screen Reviewer:

Print Sign Date Screen Reviewer shall forward the completed Screen to the Engineering First Team.

Comments The ATWS-RPT System initiates an RPT, adding negative reactivity, following events in which a scram does not (but should) occur, to lessen the effects of an ATWS event. Tripping the recirculation pumps adds negative reactivity from the increase in steam voiding in the core area as core flow decreases. When Reactor Vessel Water Level - Low Low, Level 2 or Reactor Steam Dome Pressure - High setpoint is reached, the recirculation pump drive motor breakers trip.

Continued DTC: TPMMLS DSN: MLS14002 Rev. 7 P2/3 File: 1703.22

TSTF-516-T, Rev. 0 50.59 SCREEN Continuation Page 50.59 Screen No. - Rev. No. Page 3 of 3 Since the recirculation pump trip occurs based on reactor water level or reactor pressure parameters, the trip was assumed to occur in the analyses of the Load Rejection Transient and ASME Overpressure Protection. The Core Operating Limits Report (COLR) for the current cycle and the UFSAR indicate that ATWS-RPT is assumed in these analyses.

In the case of the Load Rejection event, the ATWS-RPT trip does not occur until after the minimum CPR has occurred. Therefore the trip does not have any effect on the delta CPR severity of the transient event.

For the ASME Overpressure MSIV Isolation event, the ATWS-RPT does have an affect on the peak pressure for the event, however it is not a large effect (typically less than 10 psi) and it can actually either increase or decrease the peak pressure, depending on the plant. For some plants, the reduction in core flow from the ATWS-RPT can come too late in the event to affect the power, but the reduction in flow can cause an increase in the steam rate, leading to higher calculated dome pressures than would be calculated without the trip. Thus, it does not appear that the ATWS-RPT necessairly acts to mitigate the transient events, nor does it appear that the function plays an important role in determining the results of the reload licensing transient being analyzed. Therefore, the trip function could be removed from the vendors transient analysis models with little or no consequences to the customer. However, given that the system exists and has an effect on the analysis results, the appropriate course of action is to retain the ATWS-RPT in the safety analysis and remove the incorrect sentenece in the Bases.

There is no change to the SSC that affects UFSAR design functions. The UFSAR described function of RPT to mitigate an ATWS condition is not altered. The UFSAR already assumes the recirculation pump trip in the other described transient analyses. There is also no procedure change that affects UFSAR functions. The ATWS-RPT is originally designed for ATWS conditions but is credited in other transient analyses since it reflects actual plant design. The TS Bases has an incorrect statement indicating that ATWS-RPT was not assumed in the transient analyses. The UFSAR properly describes crediting the trip in transient analyses. Therefore, the discrepent statement in the TS Bases is being removed.

Although the effect of crediting the trip is insignificant on taransient analyses, the statement in the TS Bases is removed to more accurately reflect the analyses by the fuel vendor.

No change is required to the Technical Specifications. Removing the TS Bases statement does not alter the UFSAR described evaluation for analyzing transients associated with Load Rejection and RPV Overpressurization Protection.

DTC: TPMMLS DSN: MLS14002 Rev. 7 P3/3 File: 1703.22

TSTF-516-T, Rev. 0 ATWS-RPT Instrumentation B 3.3.4.2 B 3.3 INSTRUMENTATION B 3.3.4.2 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT)

Instrumentation BASES BACKGROUND The ATWS-RPT System initiates an RPT, adding negative reactivity, following events in which a scram does not (but should) occur, to lessen the effects of an ATWS event. Tripping the recirculation pumps adds negative reactivity from the increase in steam voiding in the core area as core flow decreases. When Reactor Vessel Water Level - Low Low, Level 2 or Reactor Steam Dome Pressure - High setpoint is reached, the recirculation pump drive motor breakers trip.

The ATWS-RPT System (Ref. 1) includes sensors, relays, bypass capability circuit breakers, and switches that are necessary to cause initiation of an RPT. The channels include electronic equipment (e.g., trip units) that compares measured input signals with pre-established setpoints. When the setpoint is exceeded, the channel output relay actuates, which then outputs an ATWS-RPT signal to the trip logic.

The ATWS-RPT consists of two independent trip systems, with two channels of Reactor Steam Dome Pressure - High and two channels of Reactor Vessel Water Level - Low Low, Level 2 in each trip system.

Each ATWS-RPT trip system is a two-out-of-two logic for each Function.

Thus, either two Reactor Water Level - Low Low, Level 2 or two Reactor Pressure - High signals are needed to trip a trip system. The outputs of the channels in a trip system are combined in a logic so that either trip system will trip both recirculation pumps (by tripping the respective drive motor breakers).

There is one drive motor breaker provided for each of the two recirculation pumps for a total of two breakers. The output of each trip system is provided to both recirculation pump breakers.

APPLICABLE The ATWS-RPT is not assumed in the safety analysis. The ATWS-RPT SAFETY initiates an RPT to aid in preserving the integrity of the fuel cladding ANALYSES, LCO, following events in which a scram does not, but should, occur. ATWS-and APPLICABILITY RPT instrumentation satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

The OPERABILITY of the ATWS-RPT is dependent on the OPERABILITY of the individual instrumentation channel Functions. Each Function must have a required number of OPERABLE channels in each trip system, with their setpoints within the specified Allowable Value of SR 3.3.4.2.4. The actual setpoint is calibrated consistent with applicable setpoint methodology assumptions. Channel OPERABILITY also BWR/4 STS B 3.3.4.2-1 Rev. 3.0, 03/31/04

TSTF-516-T, Rev. 0 ATWS-RPT Instrumentation B 3.3.4.2 B 3.3 INSTRUMENTATION B 3.3.4.2 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation BASES BACKGROUND The ATWS-RPT System initiates a recirculation pump trip, adding negative reactivity, following events in which a scram does not (but should) occur, to lessen the effects of an ATWS event. Tripping the recirculation pumps adds negative reactivity from the increase in steam voiding in the core area as core flow decreases. When Reactor Vessel Water Level - Low Low, Level 2 or Reactor Steam Dome Pressure - High setpoint is reached, the recirculation pump motor breakers trip.

The ATWS-RPT System (Ref. 1) includes sensors, relays, bypass capability, circuit breakers, and switches that are necessary to cause initiation of a recirculation pump trip. The channels include electronic equipment (e.g., trip units) that compares measured input signals with pre-established setpoints. When the setpoint is exceeded, the channel output relay actuates, which then outputs an ATWS-RPT signal to the trip logic.

The ATWS-RPT consists of two independent trip systems, with two channels of Reactor Steam Dome Pressure - High and two channels of Reactor Vessel Water Level - Low Low, Level 2, in each trip system.

Each ATWS-RPT trip system is a two-out-of-two logic for each Function.

Thus, either two Reactor Water Level - Low Low, Level 2 or two Reactor Pressure - High signals are needed to trip a trip system. The outputs of the channels in a trip system are combined in a logic so that either trip system will trip both recirculation pumps (by tripping the respective fast speed and low frequency motor generator (LFMG) motor breakers).

There is one fast speed motor breaker and one LFMG breaker provided for each of the two recirculation pumps for a total of four breakers. The output of each trip system is provided to all four breakers.

APPLICABLE The ATWS-RPT is not assumed in the safety analysis. The ATWS-RPT SAFETY initiates an RPT to aid in preserving the integrity of the fuel cladding ANALYSES, LCO, following events in which scram does not, but should, occur. ATWS-RPT and APPLICABILITY instrumentation satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

The OPERABILITY of the ATWS-RPT is dependent on the OPERABILITY of the individual instrumentation channel Functions. Each Function must have a required number of OPERABLE channels in each trip system, with their setpoints within the specified Allowable Value of SR 3.3.4.2.4. The actual setpoint is calibrated consistent with applicable setpoint methodology assumptions. Channel OPERABILITY also BWR/6 STS B 3.3.4.2-1 Rev. 3.0, 03/31/04

BWROG-119, Rev. 0 TSTF-518-T, Rev. 0 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Correct Specification 3.1.5, Control Rod Scram Accumulators, Applicability Bases NUREGs Affected: 1430 1431 1432 1433 1434 Note: This "T" Traveler has been reviewed and approved by the Technical Specification Task Force and is made available as a template for plant-specific license amendments. This Traveler has not been reviewed and approved by the Nuclear Regulatory Commission. Any plant submitting a license amendment request to adopt this change should inform the industry contact listed below and copy the Technical Specification Task Force on their submittal letter.

Classification 2) Bases Only Change Recommended for CLIIP?: No Correction or Improvement: Correction NRC Fee Status:

Benefit: Improves Bases Industry

Contact:

John Messina, (330) 384-5878, jmessina@firstenergycorp.com 1.0 Description The Applicability Bases of Specification 3.1.5, "Control Rod Scram Accumulators," is revised to correct an inaccurate statement. Specifically, the Bases state, "In MODES 3 and 4, control rods are only allowed to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied." Instead of stating "control rods are only allowed to be withdrawn" it should state "control rods are not allowed to be withdrawn."

2.0 Proposed Change The change proposes to revise the Bases of Specification 3.1.5, Applicability section, to revise an incorrect statement.

30-Nov-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-119, Rev. 0 TSTF-518-T, Rev. 0

3.0 Background

In Revision 0 of NUREG-1433 and NUREG-1434 (the BWR/4 and BWR/5 Standard Technical Specifications, respectively), the Specification 3.1.5 Applicability Bases were correct. The Bases stated, "In MODES 1 and 2, the scram function is required for mitigation of DBAs and transients, and therefore the scram accumulators must be OPERABLE to support the scram function. In MODES 3 and 4, control rods are only allowed to be withdrawn under Special Operations LCO 3.10.3, 'Single Control Rod Withdrawal-Hot Shutdown,' and LCO 3.10.4, 'Single Control Rod Withdrawal-Cold Shutdown,' which provide adequate requirements for control rod scram accumulator OPERABILITY during these conditions. Requirements for scram accumulators in MODE 5 are contained in LCO 3.9.5, 'Control Rod OPERABILITY-Refueling'." (emphasis added)

Starting in Revision 1 of the NUREGs, the Applicability Bases state, "In MODES 1 and 2, the scram function is required for mitigation of DBAs and transients, and therefore the scram accumulators must be OPERABLE to support the scram function. In MODES 3 and 4, control rods are only allowed to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied. This provides adequate requirements for control rod scram accumulator OPERABILITY during these conditions.

Requirements for scram accumulators in MODE 5 are contained in LCO 3.9.5, 'Control Rod OPERABILITY - Refueling'." (emphasis added).

Note that in Specification 3.1.3, "Control Rod OPERABILITY," Specification 3.1.4, "Control Rod Scram Times," Specification 3.1.7, "SLC System," and Specification 3.1.8, "SDV Vent and Drain Valves," the Applicability Bases correctly state, "In MODES 3 and 4, control rods are not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied."

A search of the Revision 0 Travelers did not discover the basis for this change and the conclusion is that substitution of "only" instead of "not" was an administrative error.

4.0 Technical Analysis In MODES 3 and 4, with the reactor mode switch in the shutdown position, a control rod block (LCO 3.3.2.1, "Control Rod Block Instrumentation,") ensures all control rods are inserted. Furthermore, in MODES 3 and 4, the reactor mode switch is in the shutdown position (See Specification Table 1.1-1, "MODES"). The control rod blocks from the Reactor Mode Switch - Shutdown Position Function ensure that all control rods remain inserted.

Therefore, the statement in the Specification 3.1.5 Applicability Bases, which states that in Modes 3 and 4, control rods are only allowed to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied, is obviously false. The correct statement, which appears in multiple similar specifications, is that in Modes 3 and 4, control rods are not (vice "only") allowed to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied.

This change is a correction to the Bases with no technical change or implications to the Specifications.

30-Nov-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-119, Rev. 0 TSTF-518-T, Rev. 0 5.0 Regulatory Analysis 5.1 No Significant Hazards Consideration A No Significant Hazards Consideration Determination is not required for a Bases change.

6.0 Environmental Consideration An Environmental Consideration is not required for a Bases change.

7.0 References None Revision History OG Revision 0 Revision Status: Active Revision Proposed by: GE Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 08-May-09 Owners Group Comments (No Comments)

Owners Group Resolution: Approved Date: 22-May-09 TSTF Review Information TSTF Received Date: 26-May-09 Date Distributed for Review 26-May-09 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved for Use Date: 18-Jun-09 Affected Technical Specifications Appl. 3.1.5 Bases Control Rod Scram Accumulators 30-Nov-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-518-T, Rev. 0 Control Rod Scram Accumulators B 3.1.5 BASES APPLICABILITY In MODES 1 and 2, the scram function is required for mitigation of DBAs and transients, and therefore the scram accumulators must be OPERABLE to support the scram function. In MODES 3 and 4, control rods are not only allowed to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied. This provides adequate requirements for control rod scram accumulator OPERABILITY during these conditions. Requirements for scram accumulators in MODE 5 are contained in LCO 3.9.5, "Control Rod OPERABILITY - Refueling."

ACTIONS The ACTIONS table is modified by a Note indicating that a separate Condition entry is allowed for each control rod scram accumulator. This is acceptable since the Required Actions for each Condition provide appropriate compensatory actions for each affected accumulator.

Complying with the Required Actions may allow for continued operation and subsequent affected accumulators governed by subsequent Condition entry and application of associated Required Actions.

A.1 and A.2 With one control rod scram accumulator inoperable and the reactor steam dome pressure 900 psig, the control rod may be declared "slow," since the control rod will still scram at the reactor operating pressure but may not satisfy the required scram times in Table 3.1.4-1. Required Action A.1 is modified by a Note indicating that declaring the control rod "slow" only applies if the associated control scram time was within the limits of Table 3.1.4-1 during the last scram time test. Otherwise, the control rod would already be considered "slow" and the further degradation of scram performance with an inoperable accumulator could result in excessive scram times. In this event, the associated control rod is declared inoperable (Required Action A.2) and LCO 3.1.3 is entered.

This would result in requiring the affected control rod to be fully inserted and disarmed, thereby satisfying its intended function, in accordance with ACTIONS of LCO 3.1.3.

The allowed Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is reasonable, based on the large number of control rods available to provide the scram function and the ability of the affected control rod to scram only with reactor pressure at high reactor pressures.

BWR/4 STS B 3.1.5-2 Rev. 3.0, 03/31/04

TSTF-518-T, Rev. 0 Control Rod Scram Accumulators B 3.1.5 BASES APPLICABILITY In MODES 1 and 2, the scram function is required for mitigation of DBAs and transients and, therefore, the scram accumulators must be OPERABLE to support the scram function. In MODES 3 and 4, control rods are not only allowed to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied. This provides adequate requirements for control rod scram accumulator OPERABILITY under these conditions. Requirements for scram accumulators in MODE 5 are contained in LCO 3.9.5, "Control Rod OPERABILITY - Refueling."

ACTIONS The ACTIONS table is modified by a Note indicating that a separate Condition entry is allowed for each control rod. This is acceptable since the Required Actions for each Condition provide appropriate compensatory action for each affected control rod. Complying with the Required Actions may allow for continued operation and subsequent affected control rods governed by subsequent Condition entry and application of associated Required Actions.

A.1 and A.2 With one control rod scram accumulator inoperable and the reactor steam dome pressure 900 psig, the control rod may be declared "slow," since the control rod will still scram at the reactor operating pressure but may not satisfy the required scram times in Table 3.1.4-1. Required Action A.1 is modified by a Note, which clarifies that declaring the control rod "slow" is only applicable if the associated control scram time was within the limits of Table 3.1.4-1 during the last scram time test.

Otherwise, the control rod would already be considered "slow" and the further degradation of scram performance with an inoperable accumulator could result in excessive scram times. In this event, the associated control rod is declared inoperable (Required Action A.2) and LCO 3.1.3 entered. This would result in requiring the affected control rod to be fully inserted and disarmed, thereby satisfying its intended function in accordance with ACTIONS of LCO 3.1.3.

The allowed Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is considered reasonable, based on the large number of control rods available to provide the scram function and the ability of the affected control rod to scram only with reactor pressure at high reactor pressures.

BWR/6 STS B 3.1.5-2 Rev. 3.0, 03/31/04

WOG-197, Rev. 0 TSTF-519-T, Rev. 0 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Increase Standardization in Condition and Required Action Notes NUREGs Affected: 1430 1431 1432 1433 1434 Classification 4) NUREG Only Change Recommended for CLIIP?: No Correction or Improvement: Improvement NRC Fee Status:

Benefit: Increase Consistency with Standard or Writer's Industry

Contact:

Ken Schrader, (805) 545-4328, kjse@pge.com 1.0 Description The Writer's Guide for Improved Standard Technical Specifications (Reference 1) describes the placement of Notes in the Technical Specification Actions Table in Sections 2.1.4, "Note Format," and 4.1.6, "Chapter 3 Actions Content." The guidance on Note placement describes the vast majority of the hundreds of instances in which a Note is required.

Two circumstances have been discovered in which the Writer's Guide did not provide guidance and, as a result, the placement of Notes in the Improved Standard Technical Specifications (ISTS) has been inconsistent:

1. Notes in the Condition Column of the Actions Table typically appear to the right of the Condition designator, but in ten cases appears above the Condition designator.

2. Notes that apply to all Required Actions of a Condition are placed above the first Required Action and are the full width of the column. Notes that apply to a single Required Action are placed to the right of the designator of the Required Action. The Writer's Guide does not provide guidance on Note placement when there is a single Required Action in the Condition. In most cases, the Note appears to the right of the designator of these Required Action, but in eight cases it appears above the Required Action designator.

In order to provide consistency throughout the ISTS, changes are made to those few locations so that all Condition Notes appear to the right of the Condition designator and all Notes applicable to a single Required Action appear to the right of the Required Action designator. The Writer's Guide has been revised to include this guidance.

16-Oct-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-197, Rev. 0 TSTF-519-T, Rev. 0 2.0 Proposed Change The following Specifications are affected:

In all ISTS NUREGs:

• LCO 3.8.6, "Battery Parameters," Condition C

• LCO 3.8.8, "Distribution Systems - Operating," Required Action A.1 In NUREG-1431, Westinghouse Plants:

• LCO 3.2.1A, "FQ(Z) (CAOC-Fxy Methodology," Condition A

• LCO 3.2.1B, "FQ(Z) (RAOC-W(Z) Methodology)," Conditions A and B

• LCO 3.2.1C, "FQ(Z) (CAOC-W(Z) Methodology)," Conditions A and B

• LCO 3.3.1, "RTS Instrumentation," Required Action H.1

• LCO 3.4.11, "Pressurizer PORVs," Required Action F.1 In NUREG-1434, BWR/6 Plants:

• LCO 3.4.7, "RCS Leakage Detection Instrumentation," Required Action C.1 The change to the Note location does not affect the Bases of these Specifications.

3.0 Background

The industry and the NRC have worked to ensure that the ISTS provides a usable document for plant operators that minimizes the opportunity for misinterpretation. Consistent presentation is an important aspect of operator usability. When inconsistencies have been discovered, they should be corrected.

4.0 Technical Analysis The proposed changes do not affect the application of the ISTS and are made to improve the internal consistency of the ISTS NUREGs. As a result, the changes are considered editorial corrections and not technical changes.

It is not anticipated that any plant will propose a license amendment to make the proposed changes.

However, once these changes are incorporated into the ISTS NUREGs, the revised NUREG pages will be used as the basis of future technical changes which will be adopted by plants. In this manner, these inconsistencies will be eliminated in plant-specific Technical Specifications.

The change to the Required Action Note placement avoids a potential error-prone situation. If a Condition has a single Required Action and a Note located above the Required Action, that Note would apply to any Required Actions added to the Condition in the future. By placing the Note to the right of the Required Action designator, it requires a conscious decision by the licensee to apply the existing Note to new Required Actions.

16-Oct-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-197, Rev. 0 TSTF-519-T, Rev. 0 5.0 Regulatory Analysis 5.1 No Significant Hazards Consideration The TSTF has evaluated whether or not a significant hazards consideration is involved with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed change alters the format and location of notes that modify Conditions and Required Actions in the ACTIONS table of several Specifications in order to provide consistency in placement and format of such Notes throughout the Technical Specifications. The format and location of the notes does not alter their intent or application. As a result of this change, no initiators to any accidents previously evaluated are affected. As a result of this change, no mitigation systems or assumptions are affected. Therefore, it is concluded that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change alters the format and location of notes that modify Conditions and Required Actions in the ACTIONS table of several Specifications in order to provide consistency in placement and format of such Notes throughout the Technical Specifications. The format and location of the notes does not alter their intent or application. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The change does not alter assumptions made in the safety analysis but ensures that the instruments behave as assumed in the accident analysis. The proposed change has not effect on the safety analysis assumptions.

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

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

Response: No.

The proposed change alters the format and location of notes that modify Conditions and Required Actions in the ACTIONS table of several Specifications in order to provide consistency in placement and format of such Notes throughout the Technical Specifications. The format and location of the notes does not alter their intent or application. The change will have no effect on plant operation and merely increases the consistency in presentation in the Technical Specifications. Therefore, it is concluded that the proposed change does not involve a significant 16-Oct-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-197, Rev. 0 TSTF-519-T, Rev. 0 reduction in a margin of safety.

Based on the above, the TSTF concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

5.2 Applicable Regulatory Requirements / Criteria 10 CFR 50.36 requires plants to have Technical Specifications. The proposed change alters the format and location of notes that modify Conditions and Required Actions in the ACTIONS table of several Specifications in order to provide consistency in placement and format of such Notes throughout the Technical Specifications. The format and location of the notes does not alter their intent or application. The proposed change clarifies the Technical Specification requirements to ensure that the requirements are consistently applied. In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

6.0 Environmental Consideration The proposed change is confined to (i) changes to surety, insurance, and/or indemnity requirements, or (ii) changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10).

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

7.0 References

1. TSTF-GG-05-01, "Writers Guide for Plant-Specific Improved Technical Specifications," June 2005.

Revision History OG Revision 0 Revision Status: Active Revision Proposed by: Comanche Peak Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 17-Sep-09 Owners Group Comments (No Comments)

Owners Group Resolution: Approved Date: 01-Nov-09 16-Oct-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-197, Rev. 0 TSTF-519-T, Rev. 0 OG Revision 0 Revision Status: Active TSTF Review Information TSTF Received Date: 16-Oct-09 Date Distributed for Review 16-Oct-09 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Date:

Affected Technical Specifications Action 3.8.6.C Battery Parameters Action 3.8.9.A Distribution Systems - Operating Action 3.2.1A.A FQ(Z) (CAOC-Fxy Methodology NUREG(s)- 1431 Only Action 3.2.1C.A FQ(Z) (CAOC-W(Z) Methodology) NUREG(s)- 1431 Only Action 3.2.1B.A FQ(Z) (RAOC-W(Z) Methodology) NUREG(s)- 1431 Only Action 3.2.1C.B FQ(Z) (CAOC-W(Z) Methodology) NUREG(s)- 1431 Only Action 3.2.1B.B FQ(Z) (RAOC-W(Z) Methodology) NUREG(s)- 1431 Only Action 3.3.1.H RTS Instrumentation NUREG(s)- 1431 Only Action 3.4.11.F Pressurizer PORVs NUREG(s)- 1431 Only Action 3.4.7.C RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only 16-Oct-09 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-519, Rev. 0 Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE-------------- -------------------NOTE--------------------

Required Action C.2 shall be Required Actions C.1 and C.2 are completed if electrolyte level only applicable if electrolyte level was below the top of plates. was below the top of plates.

C. -----------NOTE------------- C.1 Restore electrolyte level to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Required Action C.2 above top of plates.

shall be completed if electrolyte level was AND below the top of plates.

---

C.2 Verify no evidence of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> leakage.

One [or two] batter[y][ies on one train] with one or AND more cells electrolyte level less than minimum C.3 Restore electrolyte level to 31 days established design greater than or equal to limits. minimum established design limits.

D. One [or two] batter[y][ies D.1 Restore battery pilot cell 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> on one train] with pilot temperature to greater than cell electrolyte or equal to minimum temperature less than established design limits.

minimum established design limits.

E. One or more batteries in E.1 Restore battery parameters 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> redundant trains with for batteries in one train to battery parameters not within limits.

within limits.

BWOG STS 3.8.6-2 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC --------------------NOTE-------------------

electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC trains made inoperable by inoperable power distribution subsystems.

A.1 --------------NOTE--------------

Enter applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources -

Operating," for DC trains made inoperable by inoperable power distribution subsystems.

Restore AC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> distribution subsystem(s) to OPERABLE status.

B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> buses inoperable. subsystem(s) to OPERABLE status.

C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> electrical power power distribution distribution subsystems subsystem(s) to inoperable. OPERABLE status.

BWOG STS 3.8.9-1 Rev. 3.1, 12/01/05

TSTF-519, Rev. 0 FQ(Z) (CAOC-Fxy Methodology) 3.2.1A 3.2 POWER DISTRIBUTION LIMITS 3.2.1A Heat Flux Hot Channel Factor (FQ(Z)) ( CAOC-Fxy Methodology)

LCO 3.2.1A FQ(Z) shall be within the limits specified in the COLR.

APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE--------------- A.1 Reduce THERMAL 15 minutes after each Required Action A.4 shall be POWER 1% RTP for FQ(Z) determination completed whenever this each 1% FQ(Z) exceeds Condition is entered. limit.

AND A. ------------NOTE------------

Required Action A.4 A.2 Reduce Power Range 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each shall be completed Neutron Flux - High trip FQ(Z) determination whenever this Condition setpoints 1% for each is entered. 1% FQ(Z) exceeds limit.

AND FQ(Z) not within limit.

A.3 Reduce Overpower T trip 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each setpoints 1% for each FQ(Z) determination 1% FQ(Z) exceeds limit.

AND A.4 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action A.1 B. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

WOG STS 3.2.1A-1 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B 3.2 POWER DISTRIBUTION LIMITS 3.2.1B Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z) Methodology)

LCO 3.2.1B FQ(Z), as approximated by FQC ( Z) and FQW ( Z) , shall be within the limits specified in the COLR.

APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE-------------- A.1 Reduce THERMAL 15 minutes after each Required Action A.4 shall be POWER 1% RTP for FQC ( Z) determination completed whenever this each 1% FQC ( Z) exceeds Condition is entered. limit.

AND A. ------------NOTE------------

Required Action A.4 A.2 Reduce Power Range 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each shall be completed Neutron Flux - High trip FQC ( Z) determination whenever this Condition setpoints 1% for each is entered. 1% FQC ( Z) exceeds limit.

AND FQC ( Z) not within limit.

A.3 Reduce Overpower T trip 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each setpoints 1% for each FQC ( Z) determination 1% FQC ( Z) exceeds limit.

AND A.4 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action A.1 WOG STS 3.2.1B-1 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE-------------- B.1 Reduce AFD limits 1% for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Required Action B.4 shall be each 1% FQW ( Z) exceeds completed whenever this limit.

Condition is entered.

---

AND B. ------------NOTE------------ B.2 Reduce Power Range 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Required Action B.4 Neutron Flux - High trip shall be completed setpoints 1% for each 1%

whenever this Condition that the maximum allowable is entered. power of the AFD limits is

---

reduced.

FQW ( Z ) not within limits. AND B.3 Reduce Overpower T trip 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> setpoints 1% for each 1%

that the maximum allowable power of the AFD limits is reduced.

AND B.4 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the maximum allowable power of the AFD limits C. Required Action and C.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

WOG STS 3.2.1B-2 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 FQ(Z) (CAOC-W(Z) Methodology) 3.2.1C 3.2 POWER DISTRIBUTION LIMITS 3.2.1C Heat Flux Hot Channel Factor (FQ(Z) (CAOC-W(Z) Methodology)

LCO 3.2.1C FQ(Z), as approximated by FQC ( Z) and FQW ( Z) , shall be within the limits specified in the COLR.

APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE-------------- A.1 Reduce THERMAL 15 minutes after each Required Action A.4 shall be POWER 1% RTP for FQC ( Z) determination completed whenever this each 1% FQC ( Z) exceeds Condition is entered. limit.

AND A. ------------NOTE------------

Required Action A.4 A.2 Reduce Power Range 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each shall be completed Neutron Flux - High trip FQC ( Z) determination whenever this Condition setpoints 1% for each is entered. 1% FQC ( Z) exceeds limit.

AND FQC ( Z) not within limit.

A.3 Reduce Overpower T trip 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each setpoints 1% for each FQC ( Z) determination 1% FQC ( Z) exceeds limit.

AND A.4 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action A.1 WOG STS 3.2.1C-1 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 FQ(Z) (CAOC-W(Z) Methodology) 3.2.1C ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE-------------- B.1 Reduce THERMAL 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Required Action B.4 shall be POWER 1% RTP for completed whenever this each 1% FQW ( Z) exceeds Condition is entered. limit.

AND B. ------------NOTE------------

Required Action B.4 B.2 Reduce Power Range 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> shall be completed Neutron Flux - High trip whenever this Condition setpoints 1% for each 1%

is entered. FQW ( Z) exceeds limit.

AND FQW ( Z ) not within limits.

B.3 Reduce Overpower T trip 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> setpoints 1% for each 1%

FQW ( Z) exceeds limit.

AND B.4 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action B.1 C. Required Action and C.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

WOG STS 3.2.1C-2 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.2 Increase THERMAL 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> POWER to > P-10.

G. Two Intermediate Range G.1 --------------NOTE--------------

Neutron Flux channels Limited plant cooldown or inoperable. boron dilution is allowed provided the change is accounted for in the calculated SDM.

Suspend operations Immediately involving positive reactivity additions.

AND G.2 Reduce THERMAL 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> POWER to < P-6.

H. One Source Range --------------------NOTE-------------------

Neutron Flux channel Limited plant cooldown or boron inoperable. dilution is allowed provided the change is accounted for in the calculated SDM.

H.1 --------------NOTE--------------

Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM.

Suspend operations Immediately involving positive reactivity additions.

WOG STS 3.3.1-4 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 Pressurizer PORVs 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two [or three] block --------------------NOTE-------------------

valves inoperable. Required Action F.1 does not apply when block valve is inoperable solely as a result of complying with Required Actions B.2 or E.2.

F.1 --------------NOTE--------------

Required Action F.1 does not apply when block valve is inoperable solely as a result of complying with Required Actions B.2 or E.2.

Restore one block valve to 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s]

OPERABLE status [if three block valves are inoperable].

[

G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition F not AND met.

G.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> WOG STS 3.4.11-3 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE-------------- -------------------NOTE--------------------

Required Action C.2 shall be Required Actions C.1 and C.2 are completed if electrolyte level only applicable if electrolyte level was below the top of plates. was below the top of plates.

C. -----------NOTE------------- C.1 Restore electrolyte level to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Required Action C.2 above top of plates.

shall be completed if electrolyte level was AND below the top of plates.

---

C.2 Verify no evidence of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> leakage.

One [or two] batter[y][ies on one train] with one or AND more cells electrolyte level less than minimum C.3 Restore electrolyte level to 31 days established design greater than or equal to limits. minimum established design limits.

D. One [or two] batter[y][ies D.1 Restore battery pilot cell 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> on one train] with pilot temperature to greater than cell electrolyte or equal to minimum temperature less than established design limits.

minimum established design limits.

E. One or more batteries in E.1 Restore battery parameters 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> redundant trains with for batteries in one train to battery parameters not within limits.

within limits.

WOG STS 3.8.6-2 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC --------------------NOTE-------------------

electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC trains made inoperable by inoperable power distribution subsystems.

A.1 --------------NOTE--------------

Enter applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources -

Operating," for DC trains made inoperable by inoperable power distribution subsystems.

Restore AC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> distribution subsystem(s) to OPERABLE status.

B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> buses inoperable. subsystem(s) to OPERABLE status.

C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> electrical power power distribution distribution subsystems subsystem(s) to inoperable. OPERABLE status.

WOG STS 3.8.9-1 Rev. 3.1, 12/01/05

TSTF-519, Rev. 0 Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE-------------- --------------------NOTE-------------------

Required Action C.2 shall be Required Actions C.1 and C.2 are completed if electrolyte level only applicable if electrolyte level was below the top of plates. was below the top of plates.

C. -----------NOTE------------- C.1 Restore electrolyte level to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Required Action C.2 above top of plates.

shall be completed if electrolyte level was AND below the top of plates.

---

C.2 Verify no evidence of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> leakage.

One [or two] batter[y][ies on one train] with one or AND more cells electrolyte level less than minimum C.3 Restore electrolyte level to 31 days established design greater than or equal to limits. minimum established design limits.

D. One [or two] batter[y][ies D.1 Restore battery pilot cell 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> on one train] with pilot temperature to greater than cell electrolyte or equal to minimum temperature less than established design limits.

minimum established design limits.

E. One or more batteries in E.1 Restore battery parameters 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> redundant trains with for batteries in one train to battery parameters not within limits.

within limits.

CEOG STS 3.8.6-2 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC --------------------NOTE-------------------

electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC trains made inoperable by inoperable power distribution subsystems.

A.1 --------------NOTE--------------

Enter applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources -

Operating," for DC trains made inoperable by inoperable power distribution subsystems.

Restore AC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> distribution subsystem(s) to OPERABLE status.

B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> buses inoperable. subsystem(s) to OPERABLE status.

C. One or more C.1 Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> DC electrical power power distribution distribution subsystems subsystem(s) to inoperable. OPERABLE status.

CEOG STS 3.8.9-1 Rev. 3.1, 12/01/05

TSTF-519, Rev. 0 Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE-------------- --------------------NOTE-------------------

Required Action C.2 shall be Required Actions C.1 and C.2 are completed if electrolyte level only applicable if electrolyte level was below the top of plates. was below the top of plates.

C. -----------NOTE------------- C.1 Restore electrolyte level to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Required Action C.2 above top of plates.

shall be completed if electrolyte level was AND below the top of plates.

---

C.2 Verify no evidence of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> leakage.

One [or two] batter[y][ies on one division] with one AND or more cells electrolyte level less than minimum C.3 Restore electrolyte level to 31 days established design greater than or equal to limits. minimum established design limits.

D. One [or two] batter[y][ies D.1 Restore battery pilot cell 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> on one division] with temperature to greater than pilot cell electrolyte or equal to minimum temperature less than established design limits.

minimum established design limits.

E. One or more batteries in E.1 Restore battery parameters 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> redundant divisions with for batteries in one division battery parameters not to within limits.

within limits.

BWR/4 STS 3.8.6-2 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 [Division 1] and [Division 2] AC, DC, [and AC vital bus] electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC --------------------NOTE-------------------

electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC divisions made inoperable by inoperable power distribution subsystems.

A.1 --------------NOTE--------------

Enter applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources -

Operating," for DC trains made inoperable by inoperable power distribution subsystems.

Restore AC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> distribution subsystem(s) to OPERABLE status.

B. [ One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> ]

buses inoperable. distribution subsystem(s) to OPERABLE status.

C. One or more [station C.1 Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> service] DC electrical power distribution power distribution subsystem(s) to subsystems inoperable. OPERABLE status.

BWR/4 STS 3.8.9-1 Rev. 3.1, 12/01/05

TSTF-519, Rev. 0 RCS Leakage Detection Instrumentation 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. [ Drywell air cooler --------------------NOTE-------------------

condensate flow rate Not applicable when the required monitoring system drywell atmospheric monitoring inoperable. system is inoperable.

C.1 --------------NOTE--------------

Not applicable when the required drywell atmospheric monitoring system is inoperable.

Perform SR 3.4.7.1. Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> ]

D. [ Required drywell D.1 Restore required drywell 30 days atmospheric monitoring atmospheric monitoring system inoperable. system to OPERABLE status.

AND OR Drywell air cooler condensate flow rate D.2 Restore drywell air cooler 30 days ]

monitoring system condensate flow rate inoperable. monitoring system to OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A, B, AND

[C, or D] not met.

E.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> F. All required leakage F.1 Enter LCO 3.0.3. Immediately detection systems inoperable.

SURVEILLANCE REQUIREMENTS BWR/6 STS 3.4.7-2 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE-------------- --------------------NOTE-------------------

Required Action C.2 shall be Required Actions C.1 and C.2 are completed if electrolyte level only applicable if electrolyte level was below the top of plates. was below the top of plates.

C. -----------NOTE------------- C.1 Restore electrolyte level to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Required Action C.2 above top of plates.

shall be completed if electrolyte level was AND below the top of plates.

---

C.2 Verify no evidence of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> leakage.

One [or two] batter[y][ies on one division] with one AND or more cells electrolyte level less than minimum C.3 Restore electrolyte level to 31 days established design greater than or equal to limits. minimum established design limits.

D. One [or two] batter[y][ies D.1 Restore battery pilot cell 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> on one division] with temperature to greater than pilot cell electrolyte or equal to minimum temperature less than established design limits.

minimum established design limits.

E. One or more batteries in E.1 Restore battery parameters 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> redundant divisions with for batteries in one division battery parameters not to within limits.

within limits.

BWR/6 STS 3.8.6-2 Rev. 3.0, 03/31/04

TSTF-519, Rev. 0 Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 [Division 1], [Division 2], and [Division 3] AC, DC, [and AC vital bus]

electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more [Division 1 --------------------NOTE-------------------

and 2] AC electrical Enter applicable Conditions and power distribution Required Actions of LCO 3.8.4, "DC subsystems inoperable. Sources - Operating," for DC divisions made inoperable by inoperable power distribution subsystems.

A.1 --------------NOTE--------------

Enter applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources -

Operating," for DC trains made inoperable by inoperable power distribution subsystems.

Restore [Division 1 and 2] 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> AC electrical power distribution subsystem(s) to OPERABLE status.

B. [ One or more [Division 1 B.1 Restore [Division 1 and 2] 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> ]

and 2] AC vital buses AC vital bus distribution inoperable. subsystem(s) to OPERABLE status.

C. One or more [Division 1 C.1 Restore [Division 1 and 2] 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 2] DC electrical DC electrical power BWR/6 STS 3.8.9-1 Rev. 3.1, 12/01/05