ML17223A626

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Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2
ML17223A626
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 08/11/2017
From: David Gudger
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF9138, CAC MF9139
Download: ML17223A626 (28)
v • d • e


Text

200 Exelon Way Exelon Gene r ation Kennett Square. PA 19348 August 11, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 www.exeloncorp.com Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2 10 CFR 50.90

References:

1) Letter from James Barstow (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission -Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2, dated January 30, 2017 (ML17030A302)
2) U.S. Nuclear Regulatory Commission Electronic Mail Message from R. B. Ennis to Richard Gropp (Exelon Generation Company, LLC) -Peach Bottom Units 2 and 3 -Request for Additional Information

-TSTF-542 Amendment Request (CACs MF9138 and MF9139), dated August 2, 2017 (ML17214A616)

By letter dated January 30, 2017, (Reference 1), Exelon Generation Company, LLC, (Exelon) submitted a License Amendment Request (LAR) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, requesting changes to the 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 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. The requested TS changes were submitted based on Technical Specifications Task Force (TSTF) Traveler TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2. In a U.S. Nuclear Regulatory Commission (NRC) electronic mail message dated August 2, 2017, the NRC indicated that it had reviewed the information submitted in the Reference 1 submittal pertaining to the proposed LAR and requested additional information to support its continued review. The Reference 2 electronic mail message identified NRC questions, which were further discussed during an August 2, 2017, teleconference between Exelon and NRC representatives.

Accordingly, Attachment 1 provides Exelon's response to the draft request for additional information contained in Reference

2. Attachment 2 contains copies of updated TS mark-up pages in response the NRC's questions.

The updated TS mark-up pages supersede those same pages that were submitted in the Reference 1 letter.

U.S. Nuclear Regulatory Commission Response to Request for Additional Information License Amendment Request Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-277 and 50-278 August 11, 2017 Page 2 In addition, in order to more effectively facilitate the implementation of the amendments if approved by NRC, Exelon is requesting a change in the implementation schedule.

Currently, in the Reference 1 letter, Exelon requested the following:

EGG requests approval of the proposed amendment by September 30, 2017 in support of the Fa/12017 Unit 3 refueling outage. Once approved, the amendments shall be implemented on both units prior to the next refueling outage on either unit. Exelon is now requesting that the amendments be implemented based on the following proposed implementation schedule:

Exelon requests approval of the proposed amendments by September 30, 2017, and if approved the amendments shall be implemented on both units prior to the Unit 2 Fall 2018 refueling outage (P2R22}. Exelon has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRG in the Reference 1 letter. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendments do not involve a significant hazards consideration.

In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendments.

There are no regulatory commitments contained in this response.

If you have any questions or require additional information, please contact Richard Gropp at (610) 765-5557.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 11th day of August 2017. Resj?ctfully, U. i;,..-"J-( J y---David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1) Response to Request for Additional Information -Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2 2) Updated Technical Specifications Mark-up Pages cc: NRC Region I, Regional Administrator NRC Project Manager, NRA -Peach Bottom NRC Senior Resident Inspector

-Peach Bottom S. T. Gray, State of Maryland R. A. Janati, Bureau of Radiation Protection, Commonwealth of Pennsylvania ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 NRC Docket Nos. 50-277 and 50-278 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2 Attachment 1 Response to RAI Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-277 and 50-278 Page 1 of 7 Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-542. "Reactor Pressure Vessel Water Inventory Control," Revision 2 Background By letter dated January 30, 2017, (Reference 1 ), Exelon Generation Company, LLC, (Exelon) submitted a License Amendment Request (LAR) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, requesting changes to the 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. The requested TS changes were submitted based on Technical Specifications Task Force (TSTF) Traveler TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2. In a U.S. Nuclear Regulatory Commission (NRG) electronic mail message dated August 2, 2017, the NRG indicated that it had reviewed the information submitted in the Reference 1 submittal pertaining to the proposed LAR and requested additional information to support its continued review. The Reference 2 electronic mail message identified NRG questions, which were further discussed during an August 2, 2017, teleconference between Exelon and NRG representatives.

The questions from the Reference 2 electronic mail message are identified below followed by Exelon's response.

The updated TS mark-up pages included in this response supersede those same pages that were submitted in the Reference 1 letter. Technical Specifications Branch (STSB) PBAPS-STSB-RAl-1 Please propose separate mark-up pages for each unit for pages 3.3-47a, 3.3-47b, 3.3-47c, 3.3-47d, 3.5-15, 3.5-16, 3.5-17, and 3.5-18 since PBAPS Units 2 and 3 use separate TSs. The pages, as included in the original LAR, are labeled "PBAPS UNITS 2 & 3" at the bottom. Response As requested, unit-specific TS pages have been created for Pages 3.3-47a, 3.3-47b, 3.3-47c, 3.3-47d, 3.5-15, 3.5-16, 3.5-17, and 3.5-18. In addition, a minor editorial formatting change was also made to TS Page 3.3-47a for both units. Specifically, the term "Not Used" was added in the upper right-hand portion of the page to ensure consistency in TS page formatting.

The updated TS pages are included in Attachment 2 of this response.

PBAPS-STSB-RAI 2 In the proposed mark-up for TS page 3.3-47b, the positioning of the "NOTE" (i.e., "Separate Condition entry is allowed for each channel")

is not consistent with TSTF-542.

Because of the existing placement (i.e., above the word "ACTIONS"), it appears as though the note is meant to apply to the APPLICABILITY and not the ACTIONS table of LCO 3.3.5.4. Please Attachment 1 Response to RAI Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-277 and 50-278 Page 2 of 7 provide a revised mark-up of this TS page consistent with TSTF-542 (i.e., with note located below the word "ACTIONS'J, or justify this deviation.

Response As requested, TS Page 3.3-47b was revised for both units to relocate the "Note" to below the word "ACTIONS" as depicted below. The updated TS pages are included in Attachment 2 of this response.

Should read: ACTIONS ----------------

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

Separate Condition entry is allowed for each channel. CONDITION REQUIRED ACTION COMPLETION TIM E PBAPS-STSB-RAI 3 The PBAPS Unit 2 TS mark-up for page 3.3-54 has what appears to be an open parentheses mark after Function 5.a of Table 3.3.6.1-1, page 3 of 3. This differs from the mark-up for PBAPS Unit 3 and is not consistent with TSTF-542.

Please provide a revised mark-up of this TS page consistent with TSTF-542, or justify this deviation.

Response As requested, TS Page 3.3-54 was revised for Unit 2 to correct the discrepancy with the open parentheses marking after Function 5.a, RWCU Flow-High, on Table 3.3.6.1-1 (Page 3 of 3). After further review, it was determined that the open parentheses marking was inadvertently placed in the wrong location on the page. The open parentheses marking should have preceded the RWCU acronym that was included in the description for Function 5, Reactor Water Cleanup RWCU) System Isolation, as depicted below. The updated Unit 2 TS page is included in Attachment 2 of this response.

Should read: FUNCTION 5. Reactor Water Cleanup (RWCU) System Isolation

a. RWCU Flow-High Table 3.3.6.1-1 (page 3 of 3) Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE CONDIT IONS SYSTEM ACTION C.l REQUIREMENTS 1, 2. 3 1 F SR 3.3.6.1.1 SR 3.3.6.1.3 SR 3.3.6.1. 7 ALLOWABLE VALUE s 125% rate d fl ow ( 23. 0 i n-wc)

Attachment 1 Response to RAI Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-277 and 50-278 Page 3 of 7 PBAPS-STSB-RAI 4 The licensee proposed to add new TS LCO 3.5.4 in lieu of the marked-up TS LCO 3.5.2, "RPV Water Inventory Control," however, Exelon's proposed statement in Actions table Condition E differs from TSTF-542.

In Exelon's proposal, Condition E is phrased as "Required Action and associated completion time of Condition C and D not met." In TSTF-542, Condition Eis phrased as "Required Action and associated completion time of Condition C or D not met." Please provide a revised mark-up of this TS page consistent with TSTF-542, or justify this deviation.

Response As requested, TS Section 3.5.4, Condition Eon TS Page 3.5-17, was revised for both units as depicted below to reflect the comparable language as provided in TSTF-542.

The word "and" in the statement "Required Action and associated completion time of Condition C and D not met" has been replaced with the word "or" consistent with the TSTF guidance.

The updated TS pages are included in Attachment 2 of this response.

Should read: ACTIONS (continued)

D. (continued)

E. Required Action and associated Completion Time of Condition C or D not met. DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. PBAPS-STSB-RAI 5 D.4 Initiate action to verify Immediately one Standby Gas Treatment subsystem is capable of being placed into operation.

E.l Initiate action to restore DRAIN TIME to > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Immediately Exelon's proposed wording of PBAPS Surveillance Requirements (SRs) 3.5.4.4 and 3.5.4.5 differs from TSTF-542 in that the proposed SRs retain the word 'each' to describe the required EGGS injection/spray subsystem.

TSTF-542 replaced SR 3.5.4.4's word 'each' with 'the' while SR 3.5.4.5's word 'each' is replaced with 'for the.' Please provide a revised up of this TS page consistent with TSTF-542, or justify this deviation.

Attachment 1 Response to RAI Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-277 and 50-278 Page 4 of 7 Response As requested, TS Surveillance Requirements (SRs) 3.5.4.4 and 3.5.4.5 on TS Page 3.5-18, were revised for both units as depicted below to reflect the wording consistent with the TSTF-542 guidance.

Specifically, the word "each" was replaced with the word " the" in TS SR 3.5.4.4, and the word "each" was replaced with the phrase "for the" in TS SR 3.5.4.5. The updated TS pages are included in Attachment 2 of this response.

Should read: SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.4.4 SR 3.5.4.5 SURVEILLANCE V erify, for the required ECCS i njection/spray subsystem, locations s usceptible to gas accumulation are s ufficiently filled with water. ----------------

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

Not required to be met for system vent flow paths open under administrative control. Verify for the required ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

PBAPS-STSB-RAI 6 FREQUENCY In accordance with the Surveillance Frequency Control Program. In ac co rda nc e with t h e S u rve illa nce Frequenc y C o ntr o l Pr o gram. Exelon's proposed wording of PBAPS SR 3.5.4.8 differs from both the TSTF-542 mark-up of SR 3.5.2.8 and PBAPS current TS SR 3.5.2.6. The TSTF-542 wording for the corresponding SR is: "Verify the required EGGS injection/spray subsystem actuates on a manual initiation signal." The justification in the LAR on page 2 of 5 of Attachment 1 states: EGG proposes to revise PBAPS TS Surveillance Requirement (SR) 3.5.4.8 and TS Bases 3.3.5.4 to clarify that for manual initiations PBAPS utilizes hand switches in lieu of push buttons. There are currently no functions in PBAPS TS Table 3.3.5.1-1 for manual initiation of the Attachment 1 Response to RAI Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-277 and 50-278 Page 5 of 7 Core Spray (CS) and Low Pressure Coolant Injection (LPG/) systems. Please clarify whether the hand switches identified initiate CS and LPG/ actuation, or if these hand switches only start the pumps, requiring operators to manually align the other CS and LPG/ components for injection.

Please further explain and provide additional justification for the wording proposed in the LAR. Response The response to this question is separated into two parts. 1) Please clarify whether the hand switches identified initiate CS and LPG/ actuation, or if these hand switches only start the pumps, requiring operators to manually align the other CS and LPG/ components for injection.

  • The Emergency Core Cooling System (ECCS) hand switches referenced in the LAA only start I stop the associated ECCS pump. Licensed Operators will manually align the ECCS train (valves) from their associated remote control switches (located in the Main Control Room (MCA)) or locally for injection as required for makeup. 2) Please further explain and provide additional justification for the wording proposed in the LAR. The additional justification for the wording proposed in the LAA is provided below.
  • ECCS manual pushbutton actuation utilizes ECCS auto initiation logic such that use of a pushbutton will automatically actuate multiple ECCS pumps. For Residual Heat Removal (AHR), when either loop's pushbutton is armed and depressed, ALL AHR pumps will start and injection valves will align. For CS, when a loop pushbutton is armed and depressed, the associated CS loop's pumps will start and injection valves will align. ECCS manual pushbuttons provide a backup method of injection to the automatic Design Basis Accident (OBA) Loss of Coolant Accident (LOCA) response provided by the initiation logic. ECCS Manual pushbuttons are not currently required by PBAPS TS. Automatic ECCS (OBA LOCA) initiation logic is required in Modes 1, 2 and 3 and not Modes 4 and 5 (Reference Table 3.3.5.1-1 Pages 1 and 2 Functions 1 a, 1 b, 1 c and Functions 2.a, 2.b and 2.c). Use of ECCS manual pushbuttons will exceed the expected makeup requirements of most water inventory control leaks. Each ECCS train injection capability will likely far exceed the expected makeup requirements from a water inventory control leak.
  • Use of the hand control switches for the pumps and valves from the MCA to align the required ECCS train for injection provides controlled makeup for potential water inventory control leaks. Because of the restrictions on DRAIN TIME, sufficient time will be available following an unexpected draining event to manually align and initiate ECCS train(s) to maintain Reactor Pressure Vessel (RPV) level above Top of Active Fuel (TAF).

Attachment 1 Response to RAI Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-277 and 50-278 Page 6 of 7

PBAPS-STSB-RAI 7 The required channels per function of proposed function 3.a of proposed Table 3.3.5.4-1 appears to be incorrect in two ways. Firstly, since function 3.a comes from existing PBAPS Table 3.3.6.1-1, the removed note at the bottom of the page seems to indicate that only one channel per trip system may be needed. Additionally, when compared to corresponding function of Table 3.3.5.2-1 of TSTF-542, it appears to be missing the text "In one trip system" after the numeral 2" in the 'Required Channels per Function' column. The column header of PBAPS current TS Table 3.3.6.1-1 is entitled "REQUIRED CHANNELS PER TRIP SYSTEM" as described in the approved TSTF traveler model safety evaluation.

Please provide justification for the existing markups or provide new markups for function 3.a of proposed Table 3.3.5.4-1 for each unit. Response Consistent with TSTF-542, PBAPS relocated the RHR Shutdown Cooling (SOC) Isolation Function 6.b, "Reactor Vessel Water level -Low (Level 3)" for Modes 4 and 5 from Primary Containment Isolation System (PCIS) Instrumentation Table 3.3.6.1-1 to Table 3.3.5.4 Function 3.a. Table 3.3.6.1-1 utilizes "REQUIRED CHANNELS PER TRIP SYSTEM" whereas Table 3.3.5.4 utilizes "REQUIRED CHANNELS PER FUNCTION." Consistent with TSTF-542, PBAPS design consists of two trip systems with two channels per trip system. The isolation function requires one channel from each trip system to initiate the isolation.

The isolation function must be maintained operable to exclude RHR SOC penetration flow paths from the DRAIN TIME calculation.

The isolation function is operable when one channel from each trip system is operable or tripped. The RHR SOC penetration flow path has two series isolation valves (i.e., M0-017 and M0-018). Either isolation valve will isolate the penetration.

Operability of the isolation function requires either of these valves to be operable to isolate the penetration.

Current PBAPS TS Instrumentation Section 3.3 tables do not utilize the verbiage "in one trip system," in the "required channels" column. When the Table 3.3.6.1-1 Function 6.b was moved to Table 3.3.5.4 Function 3.a, the existing convention was maintained.

This deviation is administrative in nature and does not conflict with the intent of TSTF-542.

Current PBAPS TS Table 3.3.6.1-1 contains a NOTE that allows one channel per trip system for either isolation valve when RHR SOC system integrity is maintained for Modes 4 and 5. TSTF-542 excludes RHR SOC penetration flow paths from the DRAIN TIME calculation if either the flow path can be isolated by the automatic SOC isolation or by maintaining the system in an intact closed loop configuration (i.e., when system integrity is maintained).

The new TSTF-542 requirements for use of the isolation function to exclude RHR SOC penetration flow paths from the DRAIN TIME calculation conflict with the previous Table 3.3.6.1-1, Page 3 of 3, note. Therefore, the note is proposed for deletion.

Attachment 1 Response to RAI Application to Revise TS to Adopt TSTF-542 Docket Nos. 50-277 and 50-278 Page 7 of 7 PBAPS-STSB-RAI 8 The required channels per function of proposed function 4.a of proposed Table 3.3.5.4-1 appears to be missing the text "In one trip system" after the numeral 2" in the 'Required Channels per Function' column when compared to the corresponding function of Table 3.3.5.2-1 of TSTF-542.

The column header of PBAPS current TS Table 3.3.6.1-1 is entitled "REQUIRED CHANNELS PER TRIP SYSTEM" as described in the approved TSTF traveler model safety evaluation.

Please provide justification for the existing markup or provide a new markup for that function for each unit. Response Consistent with TSTF-542, the PBAPS design consists of two trip systems with two channels per trip system. The isolation function requires one channel from each trip system to initiate the isolation.

The isolation function must be maintained operable to exclude RWCU penetration flow paths from the DRAIN TIME calculation.

The isolation FUNCTION is operable when one channel from each trip system is operable or tripped. The RWCU penetration flow path has two series isolation valves (i.e., M0-015 and M0-018). Either isolation valve will isolate the penetration.

Operability of the isolation function requires either of these valves to be operable to isolate the penetration.

Current PBAPS TS Instrumentation Section 3.3 tables do not utilize the verbiage "in one trip system," in the "required channels" column. When the Table 3.3.5.4 Function 4.a was added, the existing convention was maintained.

This deviation is administrative in nature and does not conflict with the intent of TSTF-542.

References

1) Letter from James Barstow (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission

-Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2, dated January 30, 2017 (ML17030A302)

2) U.S. Nuclear Regulatory Commission Electronic Mail Message from R. B. Ennis to Richard Gropp (Exelon Generation Company, LLC) -Peach Bottom Units 2 and 3 -Request for Additional Information

-TSTF-542 Amendment Request (CACs MF9138 and MF9139), dated August 2, 2017(ML17214A616)

ATTACHMENT 2 PEACH BOTIOM ATOMIC POWER STATION UNITS2 AND 3 NRC Docket Nos. 50-277 and 50-278 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2 Updated Technical Specifications Mark-up Pages Unit 2 Unit 3 3.3-47a 3.3-47a 3.3-47b 3.3-47b 3.3-47c 3.3-47c 3.3-47d 3.3-47d 3.3-54 3.5-15 3.3-15 3.5-16 3.3-16 3.5-17 3.5-17 3.5-18 3.5-18 PBAPS TSTF-542, Rev 2 New PBAPS TS Section 3.3.5.3 3.3 INSTRUMENTATION 3.3.5.3 Not Used PBAPS UNIT 2 3.3-47a Not Used 3.3.5.3 Amendment No. XXX PBAPS TSTF-542, Rev 2 3.3 INSTRUMENTATION RPV Water Inventory Control Instrumentation 3.3.5.4 3.3.5.4 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.4 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.4-1 shall be OPERABLE. APPLICABILITY:

A ccording to Table 3.3.5.4-1. ACTIONS ---------------------------------NOTE---------------------------------

Separate Condition entry is allowed for each channel. CONDITION A. One or more channels inoperable. B. As required by Required Action A. l and referenced in Table 3.3.5.4-1. C. As required by Required Action A.l and referenced in Table 3.3.5.4-1. D. As required by Required Action A.l and referenced in Table 3.3.5.4-1. PBAPS UNIT 2 A. l B. l AND --B.2 C. l D.1 REQUIRED ACTION Enter the Condition referenced in Table 3.3.5.4-1 for the channel. Declare associated penetration flow path(s) incapable of automatic isolation. Calculate DRAIN Place channel in trip. TIME. Restore channel to OPERABLE status 3.3-47b COMPLETION TIME Immediately Immediately Immediately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 24 hours (continued)

Amendment No. XXX PBAPS TSTF-542, Rev 2 RPV Water Inventory Control Instrumentation 3.3.5.4 ACTIONS (continued)

CONDITION E. Required Action and E.l associated Completion Time of Condition C or D not met. SURVEILLANCE REQUIREMENTS REQUIRED ACTION Declare associated low pressure ECCS in j ection/spray subsystem inoperable. COMPLETION TIME Immediately

NOTE--------

1. Refer to Table 3.3.5.4-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE SR 3.3.5.4.1 Perform CHANNEL CHECK. SR 3.3.5.4.2 Perform CHANNEL FUNCTIONAL TEST. SR 3.3.5.4.3 Perform LOGIC SYSTEM FUNCTIONAL TEST. PBAPS UNIT 2 3.3-47c FREQUENCY In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. (continued)

Amendment No. XXX PBAPS TSTF-542, Rev 2 FUNCTION 1. Core Spray System a. Reactor (Injection Permissive)

b. Core Spray Pump Discharge Flow--Low (Bypass) c. Manual Initiation
2. Low Pressure Coolant Injection (LPCI) System a. Reactor Pressure-Low (Injection Permissive)
b. Low Pressure Coolant Injection Pump Discharge Flow -Low (Bypass) c. Manual Initiation
3. RHR System Isolation
a. Reactor Vessel Water Level -Low, Level 3 4. Reactor Water Cleanup (RWCU) System Isolation
a. Reactor Vessel Water Level -Low, Level 3 RPV Water Inventory Control Instrumentation 3.3.5.4 Table 3.3.5.4-1 (page 1 of 1) RPV Water Inventory Control Instrumentation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 4,5 4,5 4 , 5 4 , 5 4,5 4,5 (b) (b) REQUIRED CHANNELS PER FUNCTION 4 1 per pump (a) 1 per subsystem (a) 4 1 per pump (a), (c) 1 per subsystem (a) 2 2 CONDITIONS REFERENCED FROM REQUIRED ACTION A.l c D D c D 0 B B SURVEILLANCE REQUIREMENTS SR 3.3.5.4.1 SR 3.3.5.4.2 SR 3.3.5.4.1 SR 3.3.5.4.2 SR 3.3.5.4.3 SR 3.3.5.4.1 SR 3.3.5.4.2 SR 3.3.5.4.1 SR 3.3.5.4.2 SR 3.3.5.4.3 SR 3.3.5.4.1 SR 3.3.5.4.2 SR 3.3.5.4.1 SR 3.3.5.4.2 ALLOWABLE VALUE <: 425.0 psig and s 475.0 psig <: 319.0 psid and s 351.0 psid A <: 425.0 psig and s 475.0 psig <: 299.0 psid and s. 331.0 psid NA 1.0 inches 1.0 inches (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.4, "Reactor Pressure Vessel Water Inventory Control." (b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME. (c) Function not required to be OPERABLE while associated pump i s operating in decay heat removal when minimum flow valve is closed and deactivated.

PBAPS UNIT 2 3.3-47d Amendment No. XXX Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 3 of 3) Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.1 REQUIREMENTS VALUE s. Reactor Water Cleanup (RWCU) System Isolation

a. RWCU Flow-High 1,2 , 3 1 F SR 3.3.6.1.1 s 125% rated SR 3. 3.6.1. 3 flow (23.0 SR 3.3.6.1.7 in-we) b. SLC System Initiation 1, 2, 3 1 H SR 3.3.6.1. 7 NA c. Reactor Vessel Water 1,2 , 3 2 F SR 3.3.6.1.1
,, 1.0 inches Level-Low (Level 3) SR 3.3.6.1.2 SR 3. 3.6.1. s SR 3. 3.6.1. 7 6. RHR Shutdown Cooling System Isolation
a. Reactor Pressure-High 1,2,3 1 F SR 3.3.6.1.3 s 70.0 psig SR 3.3.6.1.7
b. Reactor Vessel Water 3,4,S I SR 3.3.6.1.1 ;;,, 1.0 inches Level-Low (Level 3) SR 3.3.6.1.2 SR 3.3.6.1. s SR 3.3.6.1. 7 7. Feedwater Recirculation Isolation
a. Reactor Pressure-High 1,2,3 2 F SR 3.3.6.1.1 s 600 psig SR 3.3.6.1.2 SR 3.3.6.1.S SR 3.3.6.1. 7 8. Traversing Incore Probe Isolation
a. Reactor Vessel Water 1,2,3 2 SR 3.3.6.1.1 ;;,, 1.0 inches Level-Low (Level 3) SR 3.3.6.1.2 SR 3. 3.6.1. s SR 3.3.6.1.7
b. Drywell Pressure-High 1,2,3 2 J SR 3.3.6.1.1 s 2.0 psig SR 3.3.6.1.2 SR 3.3.6.1.5 SR 3. 3.6.1. 7 (a) Deleted PBAPS UNIT 2 3.3-54 Amendment No.

PBAPS TSTF-542, Rev 2 New PBAPS TS Section 3.5.4 RPV Water Inventory Control 3.5.4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL (WIC), AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.4 Reactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.4 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. AND One low pressure ECCS injection/spray subsystem shall be OPERABLE. ---------------------------NOTE-----------

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY

MODES 4 and 5 ACTIONS CONDITION A. Required ECCS injection/spray subsystem inoperable. B. Required Action and associated Completion Time of Condition A not met. C. DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and > 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. PBAPS UNIT 2 A.1 B.1 C. l AND REQUIRED ACTION Restore required ECCS injection/spray subsystem to OPERABLE status. Initiate action to establish a method of w ater injection capable of operating without offsite elect r ical power. Verify secondary containment boundary is capable of being established in less than the DRAIN TIME. 3.5-15 COMPLETION TIME 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Immediately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (continued)

Amendment No. XXX PBAPS TSTF-542, Rev 2 ACTIONS (continued)

c. (continued)

D. DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. PBAPS UNIT 2 RPV Water Inventory Control 3.5.4 C.2 AND C.3 Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME. Verify one standby gas treatment subsystem is capable of being placed in operation in less than DRAIN TIME. D.l --------NOTE----------Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power. Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4 hours Immediately AND Immediately D.2 Initiate action to establish secondary containment boundary. AND D. 3 Initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room. AND 3.5-16 Immediately (continued)

Amendment No. XXX PBAPS TSTF-542, Rev 2 RPV Water Inventory Control 3.5.4 ACTIONS (continued)

D. (continued)

D.4 Initiate action to verify one Standby Gas Treatment subsystem is capable of being placed into operation. E. Required Action and associated Completion Time of Condition C or D not met. E.1 Initiate action to restore DRAIN TIME to > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. OR DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. SURVEILLANCE REQUIREMENTS SR 3.5.4.1 SR 3.5.4.2 SR 3.5.4.3 PBAPS UNIT 2 SURVEILLANCE Verify DRAIN TIME > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Verify , for a required low pressure coolant injection (LPCI) subsystem , the suppression pool water level 11.0 ft. Verify , for a required Core Spray (CS) subsystem , the: a. Suppression pool water level is > 11.0 ft. or b. Condensate storage tank water level is > 17.3 ft. 3.5-17 Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. (continued)

Amendment No. XXX PBAPS TSTF-542, Rev 2 RPV Water Inventory Control 3.5.4 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.4.4 SR 3.5.4.5 SR 3.5.4.6 SR 3.5.4.7 SR 3.5.4.8 PBAPS UNIT 2 SURVEILLANCE Verify , for the required ECCS injection/spray subsystem , locations susceptible to gas accumulation are sufficiently filled with water. ----------------

NOTE----------

N ot required to be met fo r s y stem vent flow paths open under administrative control. Verify for the required ECCS injection/spray subsystem manual, power operated , and automatic valve in the flow path , that is not locked , sealed, or otherwise secured in position , is in the correct position. Operate the required ECCS injection/spray subsystem through the recirculation line for > 10 minutes. Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal. -------------------NOTE-----

Vessel i njection/spray may be excluded. Verify the required ECCS injection/spray subsystem can be manually actuated. 3.5-18 FREQUENCY In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency C ontrol Program. In accordance with the Surveillance Frequency Control Program. Amendment No. XXX PBAPS TSTF-542, Rev 2 New PBAPS TS Section 3.3.5.3 3.3 INSTRUMENTATION 3.3.5.3 Not Used PBAPS UNIT 3 3.3-47a Not Used 3.3.5.3 Amendment No. XXX PBAPS TSTF-542, Rev 2 3.3 INSTRUMENTATION RPV Water Inventory Control Instrumentation 3.3.5.4 3.3.5.4 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.4 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.4-1 shall be OPERABLE. APPLICABILITY

According to Table 3.3.5.4-1. ACTIONS ---------------------------------NOTE----------------------

Separate Condition entry is allowed fo r each channel. CONDITION A. One or more channels inoperable. B. As required by Required Action A.1 and referenced in Table 3.3.5.4-1. C. As required by Required Action A.1 and referenced in Table 3.3.5.4-1. D. As required by Required Action A.1 and referenced in Table 3.3.5.4-1. PBAPS UNIT 3 A.1 B.1 AND --B.2 C.l D. l REQUIRED ACTION Enter the Condition referenced in T ab l e 3.3.5.4-1 f o r the channel. Declare associated penetrati o n flow path (s) incapable of automatic isolation. Calculate DRAIN Place channel in trip. TIME. Restore channel to OPERABLE status 3.3-47b COMPLETION TIME Immediately Immediately Immediately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 24 hours (continued)

Amendment No. XXX PBAPS TSTF-542, Rev 2 RPV Water Inventory Control Instrumentation 3.3.5.4 ACTIONS (continued)

CONDITION E. Required Action and E.l associated Completion Time of Condition C or D not met. SURVEILLANCE REQUIREMENTS REQUIRED ACTION Declare associated low pressure ECCS injection/spray subsystem inoperable. COMPLETION TIME Immediately

NOTE-

1. Refer to Table 3.3.5.4-1 to determine which SRs apply for each ECCS Function. SURVEILLANCE SR 3.3.5.4.1 Perform CHANNEL CHECK. SR 3.3.5.4.2 Perform CHANNEL FUNCTIONAL TEST. SR 3.3.5.4.3 Perform LOGIC SYSTEM FUNCTIONAL TEST. PBAPS UNIT 3 3.3-4 7c FREQUENCY In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. (continued)

Amendment No. XXX PBAPS TSTF-542, Rev 2 FUNCTION 1. Core Spray System a. Reactor (Injection Permissive)

b. Core Spray Pump Discharge Flow--Low (Bypass) c. Manual Initiation
2. Low Pressure Coolant Injection (LPCI) System a. Reactor Pressure-Low (Injection Permissive)
b. Low Pressure Coolant Injection Pump Discharge Flow -Low (Bypass) c. Manual Initiation
3. RHR System Isolation
a. Reactor Vessel Water Level -Low, Level 3 4. Reactor Water Cleanup (RWCU) System Isolation
a. Reactor Vessel Water Level -Low, Level 3 RPV Water Inventory Control Instrumentation 3.3.5.4 Table 3.3.5.4-1 (page 1 of 1) RPV Water Inventory Control Instrumentation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 4 , 5 4,5 4,5 4,5 4,5 4 , 5 (b) (b) REQUIRED CHANNELS PER FUNCTION 4 1 per pump (a) 1 per subsystem (a) 4 1 per pump (a), (c) 1 per subsystem (a) 2 2 CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 c D D c D D B B SURVEILLANCE REQUIREMENTS SR 3.3.5.4.1 SR 3.3.5.4.2 SR 3.3.5.4.1 SR 3.3.5.4.2 SR 3.3.5.4.3 SR 3.3.5.4.1 SR 3.3.5.4.2 SR 3.3.5.4.1 SR 3.3.5.4.2 SR 3.3.5.4.3 SR 3.3.5.4.1 SR 3.3.5.4.2 SR 3.3.5.4.1 SR 3.3.5.4.2 ALLOWABLE VALUE ?. 425.0 psig ands_ 475.0 psig ?. 319 .0 psid and s_ 351.0 psid NA ?. 425.0 psig and s_ 475.0 psig ?. 299.0 psid and s_ 331. 0 psid NA 2:. 1. 0 inches 2:. 1.0 inches (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.4, "Reactor Pressure Vessel Water Inventory Control." (b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME. (c) Function not required to be OPERABLE while associated pump is operating in decay heat removal when minimum flow valve is closed and deactivated.

PBAPS UNIT 3 3.3-47d Amendment No. XXX PBAPS TSTF-542, Rev 2 New PBAPS TS Section 3.5.4 RPV Water Inventory Control 3.5.4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL (WIC), AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.4 Reactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.4 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. AND One low pressure ECCS injection/spray subsystem shall be OPERABLE. ---------------------------NOTE-------------------------

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and o peration for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY

MODES 4 and 5 ACTIONS CONDITION A. Required ECCS injection/spray subsystem inoperable. 8. Required Action and associated Completion Time of Condition A not met. C. DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and > 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. PBAPS UNIT 3 A. l B.l C.l AND REQUIRED ACTION Restore required ECCS injection/spray subsystem to OPERABLE status. Initiate action to establish a method of water injection capable of operating without offsite electrical power. Verify secondary containment boundary is capable of being established in less than the DRAIN TIME. 3.5-15 COMPLETION TIME 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Immediately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (continued)

Amendment No. XXX PBAPS TSTF-542, Rev 2 ACTIONS (continued)

C. (continued)

D. DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. PBAPS UNIT 3 RPV Water Inventory Control 3.5.4 C.2 Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME. AND C.3 Verify one standby gas treatment subsystem is capable of being placed in operation in less than DRAIN TIME. D.l --------NOTE-------Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power. Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4 hours Immediately AND Immediately D.2 Initiate action to establish secondary containment boundary. AND D.3 Initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room. AND 3.5-16 Immediately (continued)

Amendment No. XXX PBAPS TSTF-542, Rev 2 RPV Water Inventory Control 3.5.4 ACTIONS (continued)

D. E. (continued)

Required Action and associated Completion Time of Condition C or D not met. OR DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. D.4 Initiate action to verify one Standby Gas Treatment subsystem is capable of being placed into operation. E.1 Initiate action to restore DRAIN TIME to > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. SURVEILLANCE REQUIREMENTS SR 3.5.4.1 SR 3.5.4.2 SR 3.5.4.3 PBAPS UNIT 3 SURVEILLANCE Verify DRAIN TIME > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Verify , for a required low pressure coolant injection (LPCI) subsystem , the suppression pool water level is 11.0 ft. Verify , for a required Core Spray (CS) subsystem , the: a. Suppression pool water level is > 11. 0 ft. or b. Condensate storage tank water level is > 17.3 ft. 3.5-17 Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. In accordance w ith the Surveillance Frequency Control Program. (continued)

Amendment No. XXX PBAPS TSTF-542, Rev 2 RPV Water Inventory Control 3.5.4 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.4.4 SR 3.5.4.5 SR 3.5.4.6 SR 3.5.4.7 SR 3.5.4.8 PBAPS UNIT 3 SURVEILLANCE Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water. ----------------NOTE------------------

N ot required to be met for system vent flow paths open under administrative control. Verify for the required ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position , is in the correct position.

Operate the required ECCS injection/spray subsystem through the recirculation line for > 10 minutes. Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal. -------------------NOTE

V essel injection/spray may be e x cluded. Verify the required ECCS injection/spray subsystem can be manually actuated. 3.5-18 FREQUENCY In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. Amendment No. XXX

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