Text

Issuance of Amendment No. 321 Re: Revision to Technical Specifications to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control (EPID L-2017-LLA-0311)
	ML18194A882
Person / Time
Site:	FitzPatrick
Issue date:	08/24/2018
From:	Booma Venkataraman; Plant Licensing Branch 1
To:	Bryan Hanson; Exelon Generation Co, Exelon Nuclear
	Venkataraman B, NRR/DORL/LPL1
References
	EPID L-2017-LLA-0311
	Download: ML18194A882 (6)
	v • d • e

SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT- ISSUANCE OF AMENDMENT NO. 321 RE: REVISION TO TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-542, REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" (EPID L-2017-LLA-0311)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 321 to Renewed Facility Operating License No. DPR-59 for the James A. FitzPatrick Nuclear Power Plant (JAFNPP). The amendment is in response to your application dated October 2, 2017, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17275A520.) as supplemented by letters dated January 22 and April 19, 2018. (ADAMS Accession Nos. ML18022A829 and ML18109A371, respectively.)

The amendment revises existing JAFNPP technical specification (TS) requirements related to "operations with a potential for draining the reactor vessel," with new requirements on reactor pressure vessel water inventory control to protect the JAFNPP TS Safety Limit 2.1.1.3, which states, "Reactor vessel water level shall be greater than the top of active irradiated fuel."

A copy of the related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

Tonya E. Hood, Project Manager

Plant Licensing Branch I

Division of Operating Reactor Licensing

Office of Nuclear Reactor Regulation

Enclosures:

1. Amendment No. 321 to DPR-59

2. Safety Evaluation

1.0 INTRODUCTION

By letter dated October 2, 2017 (Reference 1 ), and as supplemented by letters dated

January 22 and April 19, 2018 (References 2 and 3, respectively), Exelon Fitzpatrick, LLC and

Exelon Generation Company, LLC (the licensee) requested to adopt Technical Specifications

Task Force (TSTF) Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory

Control," (Reference 4) for the James A. FitzPatrick Nuclear Power Plant (JAFNPP). The final

safety evaluation (SE) for TSTF-542, Revision 2, was approved by the U.S. Nuclear Regulatory

Commission (NRC, the Commission) on December 20, 2016 (Reference 5).

The proposed changes would replace existing technical specification (TS) requirements

associated with "operations with a potential for draining the reactor vessel" (OPDRVs) with

revised TSs providing alternative requirements for reactor pressure vessel (RPV) water

inventory control (WIC). These alternative requirements would protect the JAFNPP TS Safety

Limit 2.1.1.3, which states, "Reactor vessel water level shall be greater than the top of active

irradiated fuel."

Additionally, a new definition "DRAIN TIME" would be added to the JAFNPP TSs, Section 1.1,

"Definitions." DRAIN TIME would establish requirements for the licensee to make RPV water

level inventory determinations and to calculate RPV water inventory drain rates for Modes 4 and

5 outage-related activities. Adequate licensee management of secondary containment

requirements or mitigation of certain emergency core cooling system (ECCS) safety

injection/spray systems during Modes 4 and 5 would require a properly calculated DRAIN TIME.

The licensee proposed several JAFNPP plant-specific variations from the TS changes

described in the applicable parts of TSTF-542, Revision 2, or the NRG-approved TSTF-542 SE.

These are explained and evaluated, respectively, in Sections 2.2.5 and 3.5 of this SE.

The supplemental letters dated January 22 and April 19, 2018, provided additional information

that clarified the application, did not expand the scope of the application as originally noticed,

and did not change the NRC staff's original proposed no significant hazards consideration

determination as published in the Federal Register on November 21, 2017 (82 FR 55405).

2.0 REGULATORY EVALUATION

2.1 System Description

The JAFNPP boiling-water reactor (BWR) RPV has a number of penetrations located below the

top of active irradiated fuel (TAF). These penetrations provide entry for control rod drives,

recirculation flow, reactor water cleanup (RWCU), and shutdown cooling. Since these

penetrations are below the TAF, this creates a potential to drain the reactor vessel water

inventory and lose effective core cooling. The loss of water inventory and effective core cooling

can potentially lead to fuel cladding failure and radioactive release.

During operation in Mode 1 (Power Operation - Reactor Mode Switch in Run), Mode 2

(Startup - Reactor Mode Switch in Refuel (with all reactor vessel head closure bolts fully

tensioned) or Startup/Hot Standby), and Mode 3 (Hot Shutdown - Reactor Mode Switch in

Shutdown and average reactor coolant temperature greater than(>) 212 degrees Fahrenheit

(°F), the TS for instrumentation and ECCS require operability of sufficient equipment to ensure

large quantities of water can be injected into the reactor vessel should level decrease below the

preselected value. These requirements are designed to mitigate the effects of a loss-of-coolant

accident (LOCA), but also provide protection for other accidents and transients that involve a

water inventory loss.

During operation in Mode 4 (Cold Shutdown - Reactor Mode Switch in Shutdown with all reactor

vessel head closure bolts fully tensioned and average reactor coolant temperature less than or

equal to (:S) 212 °F), and Mode 5 (Refueling - One or more reactor vessel head closure bolts

less than fully tensioned and Reactor Mode Switch in Shutdown or Refuel), the pressures and

temperatures that could cause a LOCA are not present. During certain phases of refueling

(Mode 5), a large volume of water is available above the RPV (i.e., the RPV head is removed,

the water level is greater than or equal to(~) 22 feet 2 inches above the top of the RPV flange),

and the spent fuel storage pool gates are removed (existing TS limiting condition for operation

(LCO) 3.5.2).

The large volume of water available in and above the RPV ( during much of the time when in

Mode 5) provides time for operator detection and manual operator action to stop and mitigate an

RPV draining event. However, at other times during a refueling outage (i.e., Mode 4 or

Mode 5), there may be a potential for significant drainage paths from certain outage activities,

human error, and other events when it is more likely to have some normally available

equipment, instrumentation, and systems inoperable due to maintenance and outage activities.

There may not be as much time for operator action as compared to times when there are large

volumes of water above the RPV.

In comparison to Modes 1, 2, and 3, with typical high temperatures and pressures (especially in

Modes 1 and 2), Modes 4 and 5 generally do not have the high pressure and temperature

considered necessary for a LOCA envisioned from a high energy pipe failure. Thus, while the

potential sudden loss of large volumes of water from a LOCA are not expected, operators

monitor for BWR RPV water level decrease from potential significant or even unexpected

drainage paths. These potential drainage paths in Modes 4 and 5 generally would require less

water replacement capability to maintain water above TAF. To address the drain down potential

during Modes 4 and 5, the current JAFNPP TSs contain specifications that are applicable during

an OPDRV, or require suspension of OPDRVs if certain equipment is inoperable. The term

OPDRV is not specifically defined in the TSs and historically has been subject to inconsistent

application by licensees. The changes discussed in this SE are intended to resolve any

ambiguity by creating new RPV WIC TSs with attendant equipment operability requirements,

required actions and surveillance requirements (SRs), and deleting references to OPDRVs

throughout the JAFNPP TSs.

2.2 Proposed TS Changes

Section 2.2.1 of this SE discusses the proposed addition of a new definition, "DRAIN TIME"

( evaluated below in SE Section 3.1 ). Section 2.2.2 of this SE discusses the proposed revisions

to TS 3.3, "INSTRUMENTATION," including the proposed revisions to TS 3.3.5.1, "Emergency

Core Cooling System (ECCS) Instrumentation," the proposed addition of a new TS 3.3.5.2,

"Reactor Pressure Vessel Water (RPV) Inventory Control Instrumentation," and the proposed

renumbering of existing TS 3.3.5.2, "Reactor Core Isolation Cooling (RCIC) System

Instrumentation," to TS 3.3.5.3. Section 2.2.3 of this SE discusses the proposed revisions to

TS 3.5, "Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC)

System," including the proposed revisions to TS 3.5.2, "ECCS - Shutdown" (evaluated below in

SE Section 3.3). Section 2.2.4 of this SE discusses the proposed deletion of existing TS

references to OPDRVs (evaluated below in SE Section 3.6). Section 2.2.5 of this SE discusses

JAFNPP plant-specific variations to TSTF-542, Revision 2 (evaluated below in SE Section 3.5).

In addition, the licensee proposes administrative changes to the table of contents (TOC) to

reflect the above TS changes.

2.2.1 Addition of DRAIN TIME Definition

The following definition of "DRAIN TIME" would be added to Section 1.1, "Definitions":

The DRAIN TIME is the time it would take for the water inventory in and above

the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF)

seated in the RPVassuming:

a) The water inventory above the TAF is divided by the limiting drain rate:

b) The limiting drain rate is the larger of the drain rate through a single

penetration flow path with the highest flow rate, or the sum of the drain

rates through multiple penetration flow paths susceptible to a common

mode failure (e.g., seismic event, loss of normal power, single human

error), for all penetration flow paths below the T AF except:

1. Penetration flow paths connected to an intact closed system, or

isolated by manual or automatic valves that are locked, sealed, or

otherwise secured in the closed position, blank flanges, or other

devices that prevent flow of reactor coolant through the penetration

flow paths;

2. Penetration flow paths capable of being isolated by valves that will

close automatically without offsite power prior to the RPV water level

being equal to the TAF when actuated by RPV water level isolation

instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior

to the RPV water level being equal to the TAF by a dedicated operator

trained in the task, who is in continuous communication with the

control room, is stationed at the controls, and is capable of closing the

penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are

assumed to open instantaneously and are not subsequently isolated, and

no water is assumed to be subsequently added to the RPV water

inventory;

d) No additional draining events occur; and

e) Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

2.2.2 TS 3.3, Instrumentation

The following subsections describe the existing and proposed changes to the JAFNPP TS,

Section 3.3, "Instrumentation."

2.2.2.1 TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation"

Proposed changes to TS 3.3.5.1 include the deletion of Note 1 in Required Actions B.1, C.1,

and E.1, which states:

Only applicable in MODES 1, 2, and 3.

For TS Table 3.3.5.1-1, the applicability in Modes 4 and 5 was proposed for deletion because

the instrumentation requirements during shutdown would be consolidated into the new

TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation."

Modes 4 and 5 applicability and associated requirements would be deleted for the following

functions:

1. Core Spray (CS) System

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

c. Reactor Pressure - Low (Injection Permissive)

d. Core Spray Pump Start-Time Delay Relay

e. Core Spray Pump Discharge Flow- Low (Bypass)

f. Core Spray Pump Discharge Pressure - High (Bypass)

- 5 -

2. Low Pressure Coolant Injection (LPCI) System

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

c. Reactor Pressure - Low (Injection Permissive)

f. Low Pressure Coolant Injection Pump Start - Time Delay Relay

g. Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass)

TS Table 3.3.5.1-1 Footnote (a), which states, "When associated ECCS subsystem(s) are

required to be OPERABLE per LCO 3.5.2," would be deleted. As a result, existing

Footnotes (b), (c), and (d) would be renumbered (a), (b), and (c), respectively.

2.2.2.2 New TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory

Control Instrumentation"

The proposed new TS 3.3.5.2 would contain functions that are comprised of requirements

moved from TSs 3.3.5.1 and 3.3.6.1, as well as new requirements. The proposed new

TS 3.3.5.2 is shown below:

3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control

Instrumentation

LCO 3.3.5.2 The Reactor Pressure Vessel (RPV) Water Inventory Control

instrumentation for each Function in Table 3.3.5.2-1 shall be

OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME

A. One or more A.1 Enter the Immediately

channels Condition referenced in

inoperable. Table 3.3.5.2-1 for the

channel.

B. As required by B.1 Declare associated Immediately

Required penetration flow path{s)

Action A.1 and incapable of automatic

referenced in isolation.

Table 3.3.5.2-1.

AND

B.2 Calculate DRAIN TIME. Immediately

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CONDITION REQUIRED ACTION COMPLETION TIME

C. As required by C. 1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

Required

Action A.1 and

referenced in

Table 3.3.5.2-1.

D. As required by D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

Required OPERABLE status.

Action A.1 and

referenced in

Table 3.3.5.2-1.

E. Required E.1 Declare associated low Immediately

Action and pressure ECCS

associated injection/spray subsystem

Completion Time inoperable.

of Condition C or D

not met.

SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE

SR 3.3.5.2.1 Perform CHANNEL CHECK.

SR 3.3.5.2.2 Perform CHANNEL

FUNCTIONAL TEST.

FREQUENCY

In accordance with the

Surveillance Frequency

Control Program

In accordance with the

Surveillance Frequency

Control Program

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Table 3.3.5.2-1 (page 1 of 1)

Reactor Pressure Vessel {RPV} Water Inventory Control Instrumentation

APPLICABLE REQUIRED CONDITIONS

MODES OR REFERENCED

FUNCTION OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE

SPECIFIED PER REQUIRED REQUIREMENTS VALUE

CONDITIONS FUNCTION ACTION A.1

1. Core Spray

System

a. Reactor 4, 5 4(a) C SR 3.3.5.2.1 s 490 psig

Pressure - SR 3.3.5.2.2

Low

(Injection

Permissive)

4,5 1 per pump D SR 3.3.5.2.1 ::: 510 gpm

b. Core Spray (a) SR 3.3.5.2.2 and

Pump S 980 gpm

Discharge

Flow- Low

(Bypass) ::: 90 psig and

4,5 1 per pump D SR 3.3.5.2.1 s 110 psig

C. Core Spray (a) SR 3.3.5.2.2

Pump

Discharge

Pressure -

High

(Bypass)

2. Low Pressure

Coolant Injection

(LPCI) System

a. Reactor 4, 5 4(a) C SR 3.3.5.2.1 s 490 psig

Pressure - SR 3.3.5.2.2

Low

(Injection

Permissive)

b. Low Pressure 4,5 1 per pump D SR 3.3.5.2.1 ::: 1040 gpm

Coolant (a) SR 3.3.5.2.2 and

Injection s 1665 gpm

Pump

Discharge

Flow- Low

(Bypass)

3. RHR System

Isolation

a. Reactor (b) 2 in one trip B SR 3.3.5.2.1 ::: 177 inches

Vessel Water system SR 3.3.5.2.2

Level - Low,

Level3

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APPLICABLE REQUIRED CONDITIONS

MODES OR CHANNELS REFERENCED SURVEILLANCE ALLOWABLE FUNCTION OTHER PER FROM REQUIREMENTS VALUE SPECIFIED FUNCTION REQUIRED

CONDITIONS ACTION A.1

4. Reactor Water

Cleanup (RWCU)

System Isolation

a. Reactor (b) 2 in one trip B SR 3.3.5.2.1 .:".. 177 inches

Vessel Water system SR 3.3.5.2.2

Level - Low

Level3

(a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor

Pressure Vessel (RPV) Water Inventory Control."

(b) When automatic isolation of the associated penetration flow path( s) is credited in calculating

DRAIN TIME.

2.2.2.3 TS 3.3.5.2, "Reactor Core Isolation Cooling (RCIC) System

Instrumentation"

The existing TS 3.3.5.2, "Reactor Core Isolation Cooling (RCIC) System Instrumentation

Isolation," and its subsections would be renumbered to TS 3.3.5.3 in order to maintain the TS

numbering conventions.

2.2.3 TS Section 3.5, "Emergency Core Cooling System (ECCS) and Reactor

Core Isolation Cooling (RCIC) System"

The title of JAFNPP TS Section 3.5 would be revised from "Emergency Core Cooling System

(ECCS) and Reactor Core Isolation Cooling (RCIC) System" to "Emergency Core Cooling

Systems (ECCS), Reactor Pressure Vessel (RPV) Water Inventory Control, and Reactor Core

Isolation Cooling (RCIC) System." This also would affect TSs 3.5.1 and 3.5.3 with modification

of the title at the top of the page.

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The title of JAFNPP TS Section 3.5.2 would be revised from "ECCS - Shutdown" to "Reactor

Pressure Vessel (RPV) Water Inventory Control," and TS 3.5.2 would be revised as follows:

3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control

LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel

(T AF) shall be ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

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 REQUIRED ACTION COMPLETION TIME

A. Required low A.1 Restore required low 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

pressure ECCS pressure ECCS

injection/spray injection/spray

subsystem subsystem to

inoperable. OPERABLE status.

B. Required Action and B.1 Initiate action to Immediately

associated establish a method of

Completion Time of water injection

Condition A not met. capable of operating

without offsite

electrical power.

CONDITION

C. DRAIN TIME

< 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and

~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

- 10 -

REQUIRED ACTION COMPLETION TIME

C. 1 Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

containment boundary

is capable of being

established in less

than the DRAIN TIME.

AND

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

C.2 Verify each secondary

containment

penetration flow path

is capable of being

isolated in less than

the DRAIN TIME.

AND 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

C.3 Verify one standby

gas treatment

subsystem is capable

of being placed in

operation in less than

DRAIN TIME.

CONDITION

D. DRAIN TIME

< 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

- 11 -

REQUIRED ACTION

D. 1 ----------NOTE------------

Required ECCS

injection/spray

subsystem or

additional method of

water injection shall

be capable of

operating without

offsite electrical

power.

Initiate action to

establish an additional

method of water

injection with water

sources capable of

maintaining RPV water

level > T AF for

~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND

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

D.4 Initiate action to verify

one standby gas

treatment subsystem

is capable of being

placed in operation.

COMPLETION TIME

Immediately

E.

OR

CONDITION

Required Action and E.1

associated

Completion Time of

Condition C or D not

met.

DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

- 12 -

REQUIRED ACTION

Initiate action to

restore DRAIN TIME

to ::::: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

COMPLETION TIME

Immediately

The proposed TS 3.5.2 SRs would be added as shown below:

SURVEILLANCE FREQUENCY

SR 3.5.2.1 Verify DRAIN TIME ::::: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In accordance with

the Surveillance

Frequency Control

Program

SR 3.5.2.2 Verify, for a required low pressure coolant In accordance with

injection (LPCI) subsystem, the the Surveillance

suppression pool water level is ::::: 10.33 ft. Frequency Control

Program

SR 3.5.2.3 Verify, for a required Core Spray (CS) In accordance with

subsystem, the: the Surveillance

Frequency Control

a. Suppression pool water level is Program

10.33 ft; or

b. The water level in each condensate

storage tank is ::::: 324 inches

SR 3.5.2.4 Verify for the required ECCS In accordance with

injection/spray subsystem, the piping is the Surveillance

filled with water from the pump discharge Frequency Control

valve to the injection valve. Program

SR 3.5.2.5 Verify for the required ECCS In accordance with

injection/spray subsystem, each manual, the Surveillance

power operated, and automatic valve in Frequency Control

the flow path, that is not locked, sealed or Program

otherwise secured in position, is in the

correct position.

SR 3.5.2.6 Operate the required ECCS In accordance with

injection/spray subsystem through the the Surveillance

recirculation line for ::::: 10 minutes. Frequency Control

Program

- 13 -

SURVEILLANCE FREQUENCY

SR 3.5.2.7 Verify each valve credited for

automatically isolating a penetration flow

path actuates to the isolation position on

an actual or simulated isolation signal.

In accordance with

the Surveillance

Frequency

Control Program

SR 3.5.2.8 ------------------------NOTE-----------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray

subsystem can be manually operated.

In accordance with

the Surveillance

Frequency Control

Program

2.2.4 Deletion of OPDRV References and Other Changes

In its license amendment request {LAR) dated October 2, 2017 (Reference 1 ), the licensee

proposed to revise existing TS requirements related to OPDRVs or "Initiate action to suspend

OPDRVs" with new requirements on RPV WIC that would protect the JAFNPP TS Safety

Limit 2.1.1.3. To remain consistent with TSTF-542, Revision 2, all references to the term

OPDRVs in the JAFNPP TSs would be deleted. The existing TS locations of these references

are summarized below:

JAFNPP LCO Location of OPDRV Reference

3.3.6.1, Primary Containment Isolation Required Action J.2, Table 3.3.6.1-1,

Instrumentation Function 6.b. and Footnote (e) (See

Below)

3.3.6.2, Secondary Containment Table 3.3.6.2-1 Footnote (a)

Isolation Instrumentation

3.3.7.1, Control Room Emergency Applicability

Ventilation Air Supply (CREVAS)

System Instrumentation

3.6.1.3, Primary Containment Isolation Required Action G.1

Valves (PCIVs)

3.6.4.1, Secondary Containment Applicability, Condition C, Required

Action C.2

3.6.4.2, Secondary Containment Applicability, Condition D, Required

Isolation Valves (SCIVs) Action D.2

3.6.4.3, Standby Gas Treatment (SGT) Applicability, Condition C, Required

System Action C.2.2, Condition E, Required

Action E.2

3. 7.3, Control Room Emergency Applicability, Condition D, Required

Ventilation Air Supply (CREVAS) Action D.2.2, Condition F, Required

System Action F.2

3.7.4, Control Room Air Conditioning Applicability, Condition D, Required

(AC) System Action D.2.2, Condition E, Required

Action E.2

- 14 -

JAFNPP LCO Location of OPDRV Reference

3.8.2, AC Sources Shutdown Required Actions A.2.3, B.3, and

SR 3.8.2.1

3.8.5, DC Sources - Shutdown Required Action A.2.3

3.8.8, Distribution Systems-Shutdown Required Action A.2.3

For each of these TS, the applicability and/or Actions table sections would be revised to delete

references to OPDRVs and delete required actions for OPDRVs. Additionally, conforming

changes would be made by renumbering remaining required actions or in the case of

SR 3.8.2.1, to revise the title of a reference to LCO 3.5.2 to the newly proposed title, "Reactor

Pressure Vessel (RPV) Water Inventory Control."

2.2.5 JAFNPP Plant-Specific TSTF-542 TS Variations

In Section 2.2 of the LAR dated October 2, 2017 (Reference 1 ), the licensee identified several

JAFNPP plant-specific TS variations from the TS changes described in TSTF-542, Revision 2,

or the applicable parts of the NRC staff's SE. The licensee stated in the LAR that these

variations do not affect the applicability of the TSTF-542, Revision 2, or the NRC staff's SE to

the proposed license amendment. Specific details of these variations are described in the LAR.

2.2.5.1 Variation 1, Relocation of LPCI Injection Mode Notes from SRs to TS LCO

The licensee proposed to relocate JAFNPP TS notes in SRs 3.5.1.2 and 3.5.2.4 to notes in

LCOs 3.5.1 and 3.5.2. The notes permit the LPCI subsystem to be considered operable during

alignment and operation for decay heat removal (OHR) if capable of being manually realigned

and not otherwise inoperable.

2.2.5.2 Variation 2, CS and LPCI Manual Initiation Logic

There are Standard Technical Specifications (STS) SRs proposed in TSTF-542 related to

"manual initiation," that do not appear in the current JAFNPP TSs. The "manual initiation" logic

does not exist in the JAFNPP design. These functions, as well as related TSTF-542,

Revision 2, SRs 3.3.5.2.3 and 3.5.2.8, do not apply to JAFNPP.

As an alternative, the licensee proposed that TS 3.5.2 include SR 3.5.2.8 to verify that the

JAFNPP-required ECCS injection/spray subsystem can be manually operated through the

manipulation of subsystem components from the Main Control Room (MCR).

2.2.5.3 Variation 3, RWCU System Isolation Occurs at Reactor Vessel Water

Level - Low Level 3

The licensee stated in the LAR that the JAFNPP design for RWCU isolation is on Reactor

Vessel Water Level - Low (Level 3), not Reactor Vessel Water Level - Low, Low (Level 2) in the

JAFNPP design. Therefore, the licensee proposed to revise JAFNPP TS Table 3.3.5.2-1 to

reflect this plant-specific design difference.

- 15 -

2.2.5.4 Variation 4, CS Time Delay Relay Function Deleted in Modes 4 and 5

The licensee stated in the LAR that the JAFNPP TS for the CS time delay relay function does

not appear in the STS table and this function is proposed to be deleted in Modes 4 and 5 using

the same justification provided in TSTF-542 for deletion of the LPCI time delay relay.

2.2.5.5 Variation 5, CS Pump Discharge Pressure - High (Bypass) Function

The JAFNPP CS pump discharge pressure high bypass function does not appear in the STS

table. Therefore, the licensee proposed to carry this function into TS Table 3.3.5.2-1 consistent

with the justification for CS and LPCI pump discharge flow low bypass functions.

2.2.5.6 Variation 6, JAFNPP TSs Contain the Surveillance Frequency

Control Program

The JAFNPP TSs contain a TS 5.5.15, Surveillance Frequency Control Program. Therefore,

the SR frequencies for Specification 3.3.5.2 and 3.5.2 are "In accordance with the Surveillance

Frequency Control Program."

2.3 Applicable Regulatory Requirements

2.3.1 Rules

The regulation under Title 1 O of the Code of Federal Regulations ( 1 O CFR), Paragraph

50.36(a)(1 ), requires an applicant for an operating license to include in the application proposed

TSs in accordance with the requirements of 10 CFR 50.36. The applicant must also include in

the application, a "summary statement of the bases or reasons for such specifications, other

than those covering administrative controls." However per 10 CFR 50.36(a)(1 ), these TS bases

"shall not become part of the technical specifications."

The categories of items required to be in the TSs are provided in 10 CFR 50.36(c). As required

by 10 CFR 50.36( c )( 1 )(i)(A), safety limits for nuclear are limits upon important process variables

that are found to be necessary to reasonably protect the integrity of certain of the physical

barriers that guard against the uncontrolled release of radioactivity. If any safety limit is

exceeded, the reactor must be shut down. The licensee shall notify the Commission, review the

matter, and record the results of the review, including the cause of the condition and the basis

for corrective action taken to preclude recurrence. Operation must not be resumed until

authorized by the Commission.

The regulation under 10 CFR 50.36(c)(2)(i) requires that the TSs include LCOs, which are the

lowest functional capability or performance levels of equipment required for safe operation of

the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the

licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the

condition can be met.

The regulation under 10 CFR 50.36(c)(2)(ii) requires licensees to establish TS LCOs for items

meeting one or more of the listed criteria. Specifically, Criterion 4, "A structure, system, or

component which operating experience or probabilistic risk assessment has shown to be

significant to public health and safety," supports the establishment of LCOs for RPV WIC due to

insights gained via operating experience.

- 16 -

The regulation under 10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs,

which are requirements relating to test, calibration, or inspection to assure that the necessary

quality of systems and components is maintained, that facility operation will be within safety

limits, and that the LCOs will be met.

Pursuant to 1 O CFR 50.90, whenever a holder of an operating license desires to amend the

license, application for an amendment must be filed with the Commission fully describing the

changes desired, and following as far as applicable, the form prescribed for original

applications. The technical information to be included in an application for an operating license

is governed in particular by 10 CFR 50.34(b).

As described in 1 O CFR 50.92(a), in determining whether an amendment to a license will be

issued to the applicant, the Commission will be guided by the considerations which govern the

issuance of initial licenses to the extent applicable and appropriate. The general considerations

that guide the Commission include, as stated in 10 CFR 50.40(a), how the TSs provide

reasonable assurance that the health and safety of the public will not be endangered. Also, to

issue an operating license, of which TSs are a part, the Commission must make the findings of

10 CFR 50.57, including the 10 CFR 50.57(a)(3)(i) finding that there is reasonable assurance

that the activities authorized by the operating license can be conducted without endangering the

health and safety of the public.

2.3.2 Guidance

The NRC staff's guidance for review of TSs is in Chapter 16, "Technical Specifications," of

NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for

Nuclear Power Plants" (SRP), March 2010 (Reference 6). As described therein, as part of the

regulatory standardization effort, the NRC staff prepared STS for each of the light-water reactor

nuclear designs.

NUREG-1433, Revision 4, "Standard Technical Specifications, General Electric BWR/4," April

2012 (Reference 7), contains the STS for BWR/4 plants and therefore is applicable to JAFNPP.

2.3.3 Conformance to Applicable Design Requirements

The construction permit for JAFNPP was issued by the Atomic Energy Commission (AEC) on

May 20, 1970. On February 20, 1971, the AEC published in the Federal Register(36 FR 3255)

a final rule that added Appendix A to 10 CFR Part 50, "General Design Criteria for Nuclear

Power Plants" (hereinafter referred to as the "final GDC"). As discussed in Chapter 16,

Appendices, Section 16.6 to the JAFNPP Final Safety Analysis Report (FSAR), JAFNPP was

evaluated against the 10 CFR 50, Appendix A, GDC for Nuclear Power Plants, effective May 21,

1971. It was concluded that JAFNPP conformed with the intent of the AEC GDC for Nuclear

Power Plants to the maximum extent possible consistent with the state of design and

construction at the time of issuance of the criteria.

The following criteria for JAFNPP are related to the evaluation of this LAR:

• Criterion 13 - Instrumentation and control. Instrumentation shall be provided to monitor

variables and systems over their anticipated ranges for normal operation, for anticipated

operational occurrences, and for accident conditions as appropriate to assure adequate

safety, including those variables and systems that can affect the fission process, the

integrity of the reactor core, the reactor coolant pressure boundary, and the containment

- 17 -

and its associated systems. Appropriate controls shall be provided to maintain these

variables and systems within prescribed operating ranges.

• Criterion 14 - Reactor coolant pressure boundary. The reactor coolant pressure

boundary shall be designed, fabricated, erected, and tested so as to have an extremely

low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture.

• Criterion 30 - Quality of reactor coolant pressure boundary. Components which are part

of the reactor coolant pressure boundary shall be designed, fabricated, erected, and

tested to the highest quality standards practical. Means shall be provided for detecting

and, to the extent practical, identifying the location of the reactor coolant leakage source.

• Criterion 33 - Reactor coolant makeup. A system to supply reactor coolant makeup for

protection against small breaks in the reactor coolant pressure boundary shall be

provided. The system safety function shall be to assure that specified acceptable fuel

design limits are not exceeded as a result of reactor coolant loss due to leakage from the

reactor coolant pressure boundary and rupture of small piping or other small

components which are part of the boundary. The system shall be designed to assure

that for onsite electric power system operation (assuming offsite power is not available)

and for offsite electric power system operation (assuming onsite power is not available)

the system safety function can be accomplished using the piping, pumps, and valves

used to maintain coolant inventory during normal reactor operation.

• Criterion 35 - Emergency core cooling. A system to provide abundant emergency core

cooling shall be provided. The system safety function shall be to transfer heat from the

reactor core following any loss of reactor coolant at a rate such that ( 1) fuel and clad

damage that could interfere with continued effective core cooling is prevented and

(2) clad metal-water reaction is limited to negligible amounts.

3.0 TECHNICAL EVALUATION

Section 2.2 of this SE lists the proposed TS changes, as included in the licensee's letters dated

October 2, 2017, and January 22 and April 19, 2018 (References 1, 2, and 3, respectively), for

the licensee to adopt TSTF-542, Revision 2. The licensee states in the LAR dated October 2,

2017, that it performed a review of the information provided in approved TSTF-542, Revision 2

(Reference 4), as well as the SE provided to the TSTF group on December 20, 2016

(Reference 5). The licensee concluded that the justifications presented in TSTF-542,

Revision 2, and the SE prepared by the NRC staff are applicable to JAFNPP and justify this

amendment for the incorporation of the changes into the JAFNPP TSs. The following sections

include the NRC staff's evaluation of each of these proposed changes.

3.1 Staff Evaluation of Proposed DRAIN TIME Definition

As discussed in Section 2.2.1 of this SE, the DRAIN TIME is the time it would take the RPV

water inventory to drain from the current level to the TAF assuming the most limiting of the RPV

penetrations flow paths with the largest flow rate, or a combination of penetration flow paths that

could open due to a common mode failure, were to open.

The NRC staff reviewed the proposed DRAIN TIME definition from TSTF-542, Revision 2. For

the purpose of NRC staff considerations, the term "break" describes a pathway for water to

drain from the RPV that has not been prescribed in the "DRAIN TIME" definition in TSTF-542,

Revision 2. Based on the information furnished by the licensee, the NRC staff has determined

that the licensee is appropriately adopting the principles of DRAIN TIME, as specified in

TSTF-542, Revision 2.

The NRC staff has reasonable assurance that the licensee will include all RPV penetrations

below the TAF in the determination of DRAIN TIME as potential pathways. As part of this

evaluation, the staff reviewed requests for additional information used during the development

of TSTF-542, Revision 2, which provided examples of bounding DRAIN TIME calculations for

three examples: (1) water level at or below the RPV flange; (2) water level above the RPV

flange with fuel pool gates installed, and (3) water level above the RPV flange with fuel pool

gates removed. The DRAIN TIME is calculated by taking the water inventory above the break

and dividing by the limiting drain rate until the TAF is reached. The limiting drain rate is a

variable parameter depending on the break size and the reduction of elevation head above

break location during the drain down event. The discharge point will depend on the lowest

potential drain point for each RPV penetration flow path on a plant-specific basis. This

calculation provides a conservative approach to determining the DRAIN TIME of the RPV.

The NRC staff concluded that the licensee will use methods resulting in conservative

calculations to determine RPV DRAIN TIME, thereby, protecting the JAFNPP TS Safety

Limit 2.1.1.3, which meets the requirements of 10 CFR 50.36(c)(3). Based on these

considerations, the NRC staff has determined that the licensee's proposed addition of DRAIN

TIME definition to the JAFNPP TSs is acceptable.

3.2 Staff Evaluation of Proposed TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation"

The existing JAFNPP TS 3.3.5.2, "Reactor Core Isolation Cooling (RCIC) System

Instrumentation," would be renumbered as TS 3.3.5.3. This achieves consistency within the

TSs and is acceptable.

The purpose of the proposed new TS 3.3.5.2 regarding RPV WIC Instrumentation is to support

the requirements of new TS LCO 3.5.2, and the proposed new definition of DRAIN TIME. There

are instrumentation and controls that are required for manual pump starts or required as a

permissive or operational controls on the equipment of the systems that provide water injection

capability, certain start commands, pump protection, and isolation functions. These instruments

are required to be operable if the systems that provide water injection and isolation functions are

to be considered operable as described in Section 3.3 this SE for new TS 3.5.2. In the JAFNPP

design, 'manual initiation logic' does not exist; however, reactor operators can manually

manipulate subsystem components from the control room for injecting water. This is more

complex than the preferred simple push button switch start but can still be accomplished within

the time frames assumed in development of TSTF-542, Revision 2. This variation is evaluated

in Section 3.5.2 of this SE.

Specifically, the proposed new TS 3.3.5.2 regarding RPV WIC Instrumentation is to support the

operation of the CS and LPCI manual starts when needed as well as the system isolation of the

residual heat removal (RHR) system and the RWCU system. The equipment involved with each

of these systems is described in the evaluation of TS 3.5.2 and the Bases for LCO 3.5.2.

3.2.1 Staff Evaluation of Proposed TS 3.3.5.2 LCO and Applicability

In the LAR dated October 2, 2017 (Reference 1 ), the licensee proposed new TS 3.3.5.2 to

provide alternative instrumentation requirements to support manual initiation of the low pressure

ECCS injection/spray subsystem required in new TS 3.5.2 and automatic isolation of

penetration flow paths that may be credited in the determination of DRAIN TIME. The current

TSs contain instrumentation requirements related to OPDRVs in TS Tables 3.3.5.1-1, 3.3.6.1-1,

and 3.3.6.2-1, and TS 3.3.7.1. These requirements from TS Tables 3.3.5.1-1 and 3.3.6.1-1

would be consolidated into new TS 3.3.5.2.

The proposed LCO 3.3.5.2 would state:

The Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation for

each Function in Table 3.3.5.2-1 shall be OPERABLE.

The proposed applicability would state:

According to Table 3.3.5.2-1.

Revision 2 of TSTF-542 selected TS Table 3.3.5.2-1 to contain those instrumentation functions

needed to support manual initiation of the low pressure ECCS injection/spray subsystem

required by LCO 3.5.2 and automatic isolation of penetration flow paths that may be credited in

a calculation of DRAIN TIME. The functions in TS Table 3.3.5.2-1 are moved from existing

TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," and TS 3.3.6.1,

"Primary Containment Isolation Instrumentation," functions that are required in Modes 4 or 5 or

during OPDRVs. Creation of TS 3.3.5.2 places these functions in a single location with

requirements appropriate to support the safety function for TS 3.5.2. As identified in

Section 2.2.5.2 of this SE, the JAFNPP design does not include a manual initiation logic for the

CS or LPCI systems. Therefore as an alternative, the licensee proposed to include an

SR 3.5.2.8 to TS 3.5.2 to verify that the required ECCS injection/spray subsystems can be

manually operated from the MCR.

The NRC staff concluded that the licensee's proposed alternative is acceptable for JAFNPP

since either CS or LPCI (or both) subsystems would be available to perform the intended

function to inject water into the RPV which meets the intent of the NRG-approved TSTF-542,

Revision 2.

3.2.2 Staff Evaluation of Proposed TS 3.3.5.2 Actions

As discussed in Section 2.2.2.2 above, the NRC staff has determined that the licensee's

proposed new TS 3.3.5.2 Actions are sufficient and necessary because when one or more

instrument channels are inoperable, the equipment and function controlled by these instruments

cannot complete the required function in the normal manner. The Actions are evaluated as

follows:

Action A would be applicable when one or more instrument channels are inoperable

from TS Table 3.3.5.2-1 and directs the licensee to immediately enter the

Condition referenced in TS Table 3.3.5.2-1 for that channel.

Action B (concerning the RHR System Isolation and RWCU System Isolation functions)

would be applicable when automatic isolation of the associated penetration flow path is

credited as a path for potential drainage in calculating DRAIN TIME. If the

instrumentation is inoperable, Required Action 8.1 directs an immediate declaration that

the associated penetration flow path(s) are incapable of automatic isolation. Required

Action B.2 requires an immediate re-calculation of DRAIN TIME, but automatic isolation

of the affected penetration flow paths cannot be credited.

Action C (concerning low reactor pressure permissive functions necessary for ECCS

subsystem manual injection valve opening) would address an event in which the

permissive is inoperable. The function must be placed in the trip condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

With the permissive function instrument in the trip condition, manual initiation valve

opening may now be performed using the control board hand-switches. This 1-hour

completion time is acceptable, because despite the preferred start method being

prevented, the reactor operator can take manual control of the pump and the injection

valve to inject water into the RPV and achieve the safety function in that time. The time

of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months also provides reasonable time for evaluation and placing the channel in trip.

Action D (concerning pump discharge flow bypass functions) would address actions

when the bypass is inoperable and then there is a risk that the associated ECCS pump

could overheat when the pump is operating and the associated injection valve is not fully

open. In this condition, the operator can take manual control of the pump and the

injection valves. Similar to the justification for Action C, while this is not the preferred

method, if a manual initiation function is inoperable, the CS and LPCI subsystem pumps

can be started manually and the valves can be opened manually. The 24-hour

completion time is acceptable, because the functions can be performed manually and it

allows time for the operator to evaluate and have necessary repairs completed.

Action E becomes necessary if the required actions and associated completion times of

Conditions C or D are not met. In this condition, the associated low pressure ECCS

injection/spray subsystem may be incapable of performing the intended function, and the

ECCS subsystem must be declared inoperable immediately.

These Actions direct the licensee to take appropriate actions as necessary and enter

immediately into the Conditions referenced in TS Table 3.3.5.2-1. The NRC staff determined

that these actions satisfy the requirements of 10 CFR 50.36( c)(2)(i) by providing a remedial

action permitted by the TSs until the LCO can be met. Therefore, the staff concludes that there

is reasonable assurance that the licensee will take appropriate actions during an unexpected

draining event to either prevent or mitigate RPV water level being lowered to the JAFNPP TS

Safety Limit 2.1.1.3 and, therefore, the proposed actions are acceptable.

3.2.3 Staff Evaluation of Proposed TS 3.3.5.2 Surveillance Requirements

The proposed new TS 3.3.5.2 SRs include Channel Checks and Channel Functional Tests

numbered SR 3.3.5.2.1 and SR 3.3.5.2.2, respectively. The NRC staff determined that these

tests are sufficient and adequate, because they are essential to ensure that the functions of

TS 3.3.5.2 are operable (i.e., capable of performing the specified safety function in support of

TS 3.5.2, DRAIN TIME, and the protection from a potential drain down of the RPV in Modes 4

and 5). The NRC staff determined that the proposed SRs of LCO 3.3.5.2, as described in

Section 3.3.3 of the TSTF-542 justification, satisfy 10 CFR 50.36(c)(3) by providing the specific

SRs relating to test, calibration, or inspection to assure that the necessary quality of systems

and components is maintained.

Surveillance requirement 3.3.5.2.1 would require a Channel Check and applies to all functions

in the TS Table 3.3.5.2-1. Performance of the Channel Check ensures that a gross failure of

instrumentation has not occurred. A Channel Check is normally a comparison of the parameter

indicated on one channel to a similar parameter on other related channels. A Channel Check is

significant in assuring that there is a low probability of an undetected complete channel failure

and is a key safety practice to verifying the instrumentation continues to operate properly

between each Channel Functional Test. The frequency is in accordance with the Surveillance

Frequency Control Program (SFCP), which is consistent with the existing requirements and

supports operating shift situational awareness.

Surveillance requirement 3.3.5.2.2 would require a Channel Functional Test and applies to all

functions in the TS Table 3.3.5.2-1. A Channel Functional Test is the injection of a simulated or

actual signal into the channel as close to the sensor as practicable to verify operability of all

devices in the channel required for channel operability. It would be performed on each required

channel to ensure that the entire channel will perform the intended function. The frequency

would be in accordance with the SFCP. The NRC staff has determined that this is acceptable

because it is consistent with the existing requirements for these functions and is based upon

operating experience that demonstrates channel failure is rare. In addition, this SR could be

included as part of a refueling activity, since during refueling outages, periods in Modes 4 and 5

are often 30 days or less.

In the LAR dated October 2, 2017 (Reference 1 ), the licensee originally proposed a

SR 3.3.5.2.3 to perform a logic system functional test even though Section 2.2.6 of

Attachment 1 of the LAR stated that no manual initiation logic existed at JAFNPP. See

Variation 2 of Section 3.5 of this SE for a full discussion. Additionally, no TS functions included

in the proposed TS Table 3.3.5.2-1 referenced SR 3.3.5.2.3. Because of the apparent

discrepancy, the NRC staff requested clarification via use of a request for additional information

dated March 26, 2018 (Reference 8). In its response letter dated April 19, 2018 (Reference 3),

the licensee identified the inclusion of SR 3.3.5.2.3 as an error and proposed removal of the

logic system functional test. The NRC staff accepts removal of formerly proposed SR 3.3.5.2.3

because of the reasoning in Variation 2 of Section 3.5 of this SE and the clarification provided in

Reference 3.

Revision 2 of TSTF-542 did not include SRs to verify or adjust the instrument setpoint derived

from the allowable value using a channel calibration or a surveillance to calibrate the trip unit.

Since a draining event in Mode 4 or 5 is not an analyzed accident, there is no accident analysis

on which to base the calculation of a setpoint. The purpose of the function is to allow ECCS

manual initiation or to automatically isolate a penetration flow path, but no specific RPV water

level is assumed for those actions. Therefore, the Mode 3 allowable value was chosen for use

in Modes 4 and 5 as it will perform the desired function. Calibrating the functions in Modes 4

and 5 is not necessary, as TS 3.3.5.1 and TS 3.3.6.1 continue to require the functions to be

calibrated on an established interval. Also, a draining event in Modes 4 or 5 is not an analyzed

accident and, therefore, there are no accident analysis assumptions on response time. The

NRC staff concluded this is adequate to ensure the channel responds with the required pumping

systems to inject water when needed and isolation equipment to perform when commanded.

Based on the above, the NRC staff concludes that the proposed SRs of LCO 3.3.5.2 satisfy

1 O CFR 50.36(c)(3) by providing the specific SRs relating to test, calibration, or inspection to

assure that the necessary quality of systems and components is maintained and, are, therefore,

acceptable.

3.2.4 Staff Evaluation of Proposed TS Table 3.3.5.2-1, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation"

In order to support the requirements of proposed TS 3.5.2, the associated instrumentation

requirements would be designated in TS Table 3.3.5.2-1. These instruments are required to be

operable if the systems that provide water injection and isolation functions are to be considered

operable as described in the NRC staff's evaluation of TS 3.5.2 (Section 3.3 of this SE).

Proposed TS Table 3.3.5.2-1 specifies the instrumentation that shall be operable for each

function in the table for Modes 4 and 5 (or other specified conditions), the required number of

channels per function, conditions referenced from Required Action A.1, SR for the functions, the

allowable value, and footnotes concerning items of the table.

Proposed TS Table 3.3.5.2-1, "Reactor Pressure Vessel (RPV) Water Inventory Control

Instrumentation," presents details on the functions required to support the equipment and

functions of TS 3.5.2. The NRC staff finds the presentation in this table to be acceptable,

because this section sufficiently discusses the purpose of the functions, the applicability, the

number of required channels, the references to the Condition to be entered by letter (e.g., A, B,

and C) if the function is inoperable, the applicable SRs, the selection of the allowable value, and

justification of differences between the existing and proposed TS functions. This RPV WIC

Instrumentation set is acceptable, because it is adequate to ensure the channels of

instrumentation respond with the required accuracy permitting pumps and associated systems

to operate to inject water when needed and isolating equipment when commanded to support

the prevention of or mitigate a potential RPV draining event.

Each of the ECCS subsystems in Modes 4 and 5 can be started by manual alignment of a small

number of components. Automatic initiation of an ECCS injection/spray subsystem may be

undesirable because it could lead to overflowing the RPV cavity, due to injection rates of

thousands of gallons per minute (gpm). Thus, there is adequate time to take manual actions

(e.g., hours versus minutes). Considering the action statements as the DRAIN TIME decreases

(the proposed TS 3.5.2, Action E, prohibits plant conditions that could result in a DRAIN TIME

less than(<) 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ), there is sufficient time for the reactor operators to take manual action to

stop the draining event and to manually start an ECCS injection/spray subsystem or the

additional method of water injection as needed. Consequently, there is no need for automatic

initiation of ECCS to respond to an unexpected draining event. This is acceptable, because a

draining event is a slow evolution when compared to a design basis LOCA assumed to occur at

a significant power level.

3.2.4.1 Staff Evaluation of Proposed TS Table 3.3.5.2-1, Functions

For the TS Table 3.3.5.2-1, Functions 1.a. and 2.a., CS and LPCI Systems, Reactor

Pressure - Low (Injection Permissive), these signals are used as permissives and protection for

these low pressure ECCS injection/spray subsystem manual initiation functions. This function

would ensure that the reactor pressure has fallen to a value below these subsystems' maximum

design pressure before permitting the operator to open the injection valves of the low pressure

ECCS subsystems. Even though the reactor pressure is expected to virtually always be below

the ECCS maximum design pumping pressure during Modes 4 and 5, the Reactor

Pressure - Low signals are required to be operable to permit manual initiation of the ECCS

equipment to inject water into the vessel, if needed. The proposed allowable value would be

s; 490 pounds per square inch gauge (psig) with four required channels per function.

- 23 -

For the TS Table 3.3.5.2-1, Functions 1.b., 2.b., and 1.c., CS and LPCI Pump Discharge

Flow - Low (Bypass), and CS Pump Discharge Pressure - High (Bypass), these minimum flow

instruments are provided to protect the associated low pressure ECCS pumps from overheating

when the pump is operating and the associated injection valve is not fully open.

Each CS pump and LPCI subsystem has one differential pressure indicating switch used to

detect the associated subsystems' flow rates. In addition, for CS, one pressure indicating

switch per pump is used to detect the associated pump's discharge pressure. The logic is

arranged such that each differential pressure indicating switch causes its associated minimum

flow valve to open. For CS both the differential pressure indicating switch and the pressure

switch must actuate to cause the valve to open. The logic will close the minimum flow valve

once the closure setpoint of the associated pressure indicating switch is exceeded.

The proposed allowable values for each of these instruments will be unchanged and moved

from TS Table 3.3.5.1-1 to the proposed TS Table 3.3.5.2-1.

For the TS Table 3.3.5.2-1, Function 3.a., RHR System Isolation, Reactor Vessel Water

Level - Low, Level 3, the function is only required to be operable when automatic isolation of the

associated penetration flow path is credited in the DRAIN TIME calculation. The number of

required instrument channels is "2 in one trip system" which retains the requirement that the two

instrument channels must be associated with the same trip system. Each trip system isolates

one of two redundant isolation valves, and only one trip system is required to be operable to

ensure that automatic isolation of one of the two isolation valves will occur on low reactor vessel

water level indication. The allowable value was chosen to be the same as the Primary

Containment Isolation Instrumentation Reactor Vessel Water Level - Low, Level 3 Allowable

Value from LCO 3.3.6.1.

In current TS Table 3.3.6.1-1, there is a footnote referenced by this function that states:

Only one trip system required in MODES 4 and 5 when RHR Shutdown Cooling

System integrity maintained.

As stated above, it is understood that only one trip system is required to be operable to ensure

automatic isolation and the concept that shutdown cooling system integrity be maintained;

therefore, this footnote is not needed and not carried forward for this function into proposed TS

Table 3.3.5.2-1.

For TS Table 3.3.5.2-1, Function 4.a., RWCU System Isolation, Reactor Vessel Water

Level - Low, Level 3, the function is only required to be operable when automatic isolation of the

associated penetration flow path is credited in the DRAIN TIME calculation. The number of

required channels is "2 in one trip system" which retains the requirement that the two instrument

channels must be part of the same trip system. Only one trip system is required to be operable

to ensure that automatic isolation of one of the two isolation valves will occur on low reactor

vessel water level. The Allowable Value was chosen to be the same as the RPS Reactor

Vessel Water Level - Low, Level 3 Allowable Value.

The NRC staff determined that the proposed new LCO 3.3.5.2 correctly specifies the lowest

functional capability or performance levels of equipment required for safe operation of the

facility. There is reasonable assurance that the required actions to be taken when the LCO is

not met can be conducted without endangering the health and safety of the public. This meets

- 24 -

the requirements of 10 CFR 50.36(c)(2)(i) and, therefore, the staff concluded that the licensee's

proposed changes to LCO 3.3.5.2 are acceptable.

3.3 Staff Evaluation of TS 3.5.2 - Reactor Pressure Vessel {RPV) Water

Inventory Control

The NRC staff reviewed the water sources that would be applicable to the proposed new

TS 3.5.2.

The licensee's proposed TS 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control,"

LCO contains two parts. The first part states that:

DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The second part states that:

One low pressure ECCS injection/spray subsystem shall be OPERABLE.

The proposed applicability for TS 3.5.2 is Modes 4 and 5. Both of these conditions must be met

during operational Modes 4 and 5 to meet the proposed LCO. "One low pressure ECCS

injection/spray subsystem" would consist of either one CS subsystem or one LPCI subsystem.

At JAFNPP, a CS subsystem consists of two motor-driven pumps, piping, and valves to transfer

water from the suppression pool or condensate storage tanks to the RPV. At JAFNPP, LPCI is

one mode of operation of the RHR system and the LPCI subsystems share four common

pumps. An LPCI subsystem consists of two motor-driven pumps, piping, and valves to transfer

water from the suppression pool to the RPV.

The ECCS pumps are high-capacity pumps, with flow rates of thousands of gallons per minute.

Most RPV penetration flow paths would have a drain rate on the order of tens or hundreds of

gallons per minute. The manual initiation/start of an ECCS pump would provide the necessary

water source to counter these expected drain rates. The LPCI subsystem is to be considered

operable during alignment and operation for DHR if capable of being manually realigned and not

otherwise inoperable. Decay heat removal in Modes 4 and 5 is not affected by the proposed

change. The requirements on the number of RHR shutdown cooling subsystems that must be

operable and in operation to ensure adequate DHR from the core are unchanged. These

requirements can be found in JAFNPP TS 3.4.8, "Residual Heat Removal (RHR) Shutdown

Cooling System-Cold Shutdown," TS 3.9.7, "Residual Heat Removal (RHR)-High Water Level,"

and TS 3.9.8, "Residual Heat Removal (RHR)-Low Water Level." Based on these

considerations, the NRC staff finds that the water sources provide assurances that the lowest

functional capability required for safe operation is maintained and supports the safety limit.

The NRC staff reviewed the proposed TS 3.5.2, focusing on ensuring the fuel remains covered

with water and the changes made compared to the current TSs. The proposed TS 3.5.2

contains Conditions A through E based on either required ECCS injection/spray subsystem

operability or DRAIN TIME.

The existing TS LCO states that two ECCS injection/spray subsystems shall be operable,

whereas the proposed LCO 3.5.2 states that only one ECCS injection/spray subsystem shall be

operable. This change is reflected in Condition A. Changing from two ECCS injection/spray

subsystems to one ECCS injection/spray subsystem is satisfactory because this level of

- 25 -

redundancy is not required given the low drain rates during Modes 4 and 5. With one ECCS

injection/spray subsystem and non-safety related injection sources, defense-in-depth will be

maintained. The defense-in-depth measure is consistent with other events considered during

shutdown with no additional single failure assumed. The DRAIN TIME controls, in addition to

the required ECCS injection/spray subsystem, provide reasonable assurance that an

unexpected draining event can be prevented or mitigated before the RPV water level would be

lowered to the JAFNPP TS Safety Limit 2.1.1.3.

The proposed Modes 4 and 5 applicability of TS 3.5.2 is appropriate given that the TS

requirements on ECCS in Modes 1, 2, and 3 will be unaffected.

The proposed Condition A states that if the required ECCS injection/spray subsystem is

inoperable, it is to be restored to operable status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The proposed Condition B states that if Condition A is not met, a method of water injection

capable of operating without offsite electrical power should be established immediately. The

proposed Condition B provides adequate assurance of an available water source should

Condition A not be met within the 4-hour completion time.

The proposed Condition C states that for a DRAIN TIME< 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , to (Required

Action C. 1) verify secondary containment boundary is capable of being established in less than

the DRAIN TIME, and (Required Action C.2) verify each secondary containment penetration

flow path is capable of being isolated in less than DRAIN TIME, and (Required Action C.3) verify

one SGT subsystem is capable of being placed in operation in less than the DRAIN TIME all

with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The proposed Condition C provides adequate protection

should the DRAIN TIME be < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and ~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months because of the ability to establish

secondary containment, isolate additional flow paths, and have the SGT subsystem capable of

being placed in operation.

The proposed Condition D states that when DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to (Required Action D.1)

immediately 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 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , (Required Action D.2)

immediately initiate action to establish secondary containment boundary, (Required Action D.3)

immediately initiate action to isolate each secondary containment penetration flow path or verify

it can be manually isolated from the control room, and (Required Action D.4) immediately initiate

action to verify one SGT subsystem is capable of being placed in operation. Additionally, there

is a note stating that required ECCS injection/spray subsystem or additional method of water

injection shall be capable of operating without offsite electrical power, which is similar to

proposed Condition B. The existing JAFNPP TS for Condition D (Required Action C.2 and

associated Completion Time not met) is similar to the proposed Condition D. The proposed

Condition D provides adequate protection should the DRAIN TIME be < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months because of the

ability to establish additional method of water injection (without electric power), establish

secondary containment, isolate additional flow paths, and have the SGT subsystem capable of

being placed in operation.

The proposed new Condition E states that when the required action and associated completion

time of Condition C or D is not met, or the DRAIN TIME is < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , then (Required Action E.1)

initiate action to restore DRAIN TIME to~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months immediately. The proposed Condition Eis

acceptable as it provides the necessary step to restore the DRAIN TIME to~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months should

the other conditions not be met, or if the DRAIN TIME is < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

- 26 -

The NRC staff evaluated the proposed changes to TS 3.5.2 and finds them acceptable based

on the actions taken to mitigate the RPV water level reaching the JAFNPP TS Safety

Limit 2.1.1.3 with the water sources available and maintaining DRAIN TIME ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

LCO 3.5.2 correctly specifies the lowest functional capability or performance levels of equipment

required for safe operation of the facility. The NRC staff concludes there is reasonable

assurance that the TS Required Actions to be taken when the LCO is not met can be conducted

without endangering the health and safety of the public and, therefore, they are acceptable.

3.3.1 Staff Evaluation of Proposed TS 3.5.2 Surveillance Requirements

The proposed TS 3.5.2 SRs (Section 2.2.3 of this SE) includes verification of DRAIN TIME,

verification of water levels/volumes that support ECCS injection/spray subsystems, verification

of water filled pipes to preclude water hammer events, verification of correct valves positions for

the required ECCS injection/spray subsystem, operation of the ECCS injection/spray systems

through the recirculation line, verification of valves credited for automatic isolation actuated to

the isolation position, and verification that the required ECCS injection/spray subsystem can be

manually operated. Each of the eight SRs are described below.

• SR 3.5.2.1: The DRAIN TIME would be determined or calculated, and required to be

verified to be~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months in accordance with the SFCP. This is a new surveillance and

would verify that the LCO for DRAIN TIME is met. Numerous indications of changes in

RPV level are available to the operator. The period of 36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months s3 is considered

reasonable to identify and initiate action to mitigate draining of reactor coolant. Changes

in RPV level would necessitate recalculation of the DRAIN TIME.

• SR 3.5.2.2: The suppression pool water level(~ 10.33 ft.) for a required LPCI

subsystem would be required to be verified to ensure pump net positive suction head

and vortex prevention is available for the LPCI injection subsystem required to be

operable by the LCO. This SR is retained from the existing SR 3.5.2.1 and would be

required to be performed in accordance with the SFCP.

• SR 3.5.2.3: The suppression pool water level(~ 10.33 ft.} or condensate storage tank

level(~ 324 inches) for a required CS subsystem would be required to be verified to

ensure pump net positive suction head and vortex prevention is available for the CS

subsystem required to be operable by the LCO. This SR is retained from the existing

SR 3.5.2.2 and would be required to be performed in accordance with the SFCP. The

note prior to part b is removed due to the removal of all OPDRV references.

• SR 3.5.2.4: The SR to verify the ECCS injection/spray subsystem piping is sufficiently

filled with water would be retained from the existing SR 3.5.2.3. The proposed change

would update the SR to reflect the change to LCO 3.5.2, which would require, in part,

one low pressure ECCS injection/spray subsystem to be operable instead of two. The

wording would change from "Verify, for each required ECCS ... " to "Verify, for the

required ECCS ... " This change clarifies the requirement to maintain consistency with the

proposed LCO. This SR would be performed in accordance with the SFCP.

• SR 3.5.2.5: The SR to verify the correct alignment for manual, power operated, and

automatic valves in the required ECCS subsystem flow p~th would be retained from the

3 Typically equivalent to three operator shifts.

- 27 -

existing SR 3.5.2.4. Again similar to proposed SR 3.5.2.4, the proposed SR wording,

"Verify for the required ECCS injection/spray subsystem each manual. .. " would replace

"Verify each required ECCS injection/spray subsystem manual ... " SR 3.5.2.5 would

provide assurance that the proper flow path will be available for ECCS operation to

support TS 3.5.2. This SR would not apply to valves that are locked, sealed, or

otherwise secured in position, since these valves would be verified to be in the correct

position prior to locking, sealing, or securing. The note just prior to the SR allowing one

LPCI subsystem to be considered operable during alignment and operation for OHR is

relocated to the LCO. This is an administrative deviation further discussed in

Section 3.5 of this SE (Variation 1 ). This SR would be performed in accordance with the

SFCP.

• SR 3.5.2.6: The required ECCS injection/spray subsystem would be required to be

operated through its recirculation line for~ 10 minutes in accordance with the SFCP.

This would demonstrate that the subsystem is capable for operation to support TS 3.5.2

and is retained from SR 3.5.2.5.

• SR 3.5.2. 7: Verification that each valve credited for automatically isolating a penetration

flow path actuates to the isolation position on an actual or simulated RPV water level

isolation signal would be required to prevent RPV water inventory from dropping below

the JAFNPP TS Safety Limit 2.1.1.3 should an unexpected draining event occur. This

SR would be performed in accordance with the SFCP and is new for JAFNPP.

• SR 3.5.2.8: This SR would state, "Verify the required ECCS injection/spray subsystem

can be manually operated." This SR is retained from existing JAFNPP SR 3.5.2.6. It

demonstrates that the required CS or LPCI subsystem could be manually operated

through the manipulation of subsystem components in the MCR to provide additional

RPV water inventory, if needed. By operating the associated pump and valve switches

which operates all active components, water flow can be demonstrated by recirculation

through the test line. Vessel injection/spray may be excluded from the SR, per the

accompanying note. Previously, JAFNPP relied only on automatic initiation of ECCS

subsystems and manual actuation, while possible, this was not discussed in the TSs.

Section 3. 5 of this SE, evaluation of Variation 2, contains amplifying information. As

further discussed in Section 3.3 of this SE, manual initiation is sufficient to counter

expected drain rates within the DRAIN TIME. This SR would be performed in

accordance with the SFCP.

The NRC staff evaluated each of these proposed SRs associated with the new LCO 3.5.2 and

determined that they are appropriate for ensuring the operability of the equipment and

instrumentation specified in LCO 3.5.2. That traveler is TSTF-523, "Generic Letter 2008-01,

Managing Gas Accumulation," which was approved by the NRC on January 14, 2014. The

TSTF-523 traveler affected existing SR 3.5.2.3, which verifies that the ECCS piping is full of

water, and existing SR 3.5.2.4, which verified that the valves are in correct position.

Furthermore, the NRC staff concluded that each of the proposed SRs are acceptable since they

meet the requirements of 10 CFR 50.36(c)(2)(ii) regarding insights gained via operating

experience and 10 CFR 50.36( c)(3) for SRs by ensuring that the necessary quality of systems

and components is maintained.

3.4 Staff Evaluation of TS Table 3.3.5.1, Emergency Core Cooling System Instrumentation

Limiting Condition for Operation 3.3.5.1 currently states that, "The ECCS instrumentation for

each Function in Table 3.3.5.1-1 shall be OPERABLE," with the applicability as stated in the

table. TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation," currently

contains requirements for function operability during Modes 4 and 5 when the associated ECCS

subsystem(s) are required to be operable per LCO 3.5.2, "ECCS - Shutdown." Conforming

changes were proposed for the Actions table of LCO 3.3.5.1 as well.

For the following functions in TS Table 3.3.5.1-1, Mode 4 and 5 requirements would be deleted:

1. Core Spray System:

(a) Reactor Vessel Water Level - Low Low Low (Level 1)

(c) Reactor Pressure - Low (Injection Permissive)

( d) Core Spray Pump Start - Time Delay Relay

(e) Core Spray Pump Discharge Flow - Low (Bypass)

(f) Core Spray Pump Discharge Pressure - High (Bypass)

2. Low Pressure Coolant Injection:

(a) Reactor Vessel Water Level - Low Low Low (Level 1)

(c) Reactor Pressure - Low (Injection Permissive)

(f) Low Pressure Coolant Injection Pump Start - Time Delay Relay

(g) Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass)

The Mode 4 and 5 requirements for the nine functions above would be deleted to support the

consolidation of RPV WIC Instrumentation requirements into the proposed new TS 3.3.5.2. The

requirements for Functions 1.c., 1.e., 1.f., 2.c., and 2.g., would be moved to proposed new TS

Table 3.3.5.2-1 as discussed in Section 3.2.4.1 of this SE.

For the other TS Table 3.3.5.1-1, Functions, 1.a., 1.d., 2.a., and 2.f., the Mode 4 and 5

requirements would not be retained. The JAFNPP TSs currently requires automatic initiation of

ECCS pumps on low Reactor Vessel water level. Functions 1.a. and 2.a., provide signals that

automatically initiate the associated CS or LPCI pumps. Functions 1.d. and 2.f., are time delay

relay functions that prevent overloading of the power source during an automatic initiation.

However, as stated previously in this SE in Modes 4 and 5, automatic initiation of ECCS pumps

could result in overfilling the refueling cavity or water flowing into the main steam lines,

potentially damaging plant equipment. The NRC staff finds the deletion of TS

Table 3.3.5.1-1, Functions 1.a. and 2.a., to be acceptable because manual ECCS initiation is

preferred over automatic initiation during Modes 4 and 5, and the operator would be able to use

the most appropriately sized pumps if needed to mitigate a draining event.

The NRC staff finds the deletion of TS Table 3.3.5.1-1, Functions 1.d. and 2.f., to be acceptable

for the CS and LPCI pump start time delay relays because the staggered starting of ECCS

pumps is unnecessary for manual ECCS operation. Unlike automatic starts, which initiate all of

the ECCS pumps to start requiring the delay logic, the operator will control which ECCS pumps

to start, one at a time as needed for water inventory control.

- 29 -

3.5 Staff Evaluation of the Proposed Technical Variations

The licensee proposed the following variations from the TS changes described in TSTF-542 or

the applicable parts of the NRC staff's SE for TSTF-542 (Reference 5). The licensee stated in

the LAR that these variations do not affect the applicability of TSTF-542, Revision 2, or the NRC

staff's SE for TSTF-542 to the proposed license amendment. The NRC staff evaluated each

variation below.

3.5.1 Variation 1, Relocation of LPCI Injection Mode Notes From SRs to LCO

The licensee proposed to relocate JAFNPP TS notes in SRs 3.5.1.2 and 3.5.2.4 to TS notes in

LCOs 3.5.1 and 3.5.2. In both cases, the notes permit the LPCI subsystem to be considered

operable during alignment and operation if capable of being manually realigned and not

otherwise inoperable.

The NRC staff finds that the added notes to LCOs 3.5.1 and 3.5.2 associated with the LPCI

subsystem are appropriate and consistent with TSTF-542, Revision 2, which places this note

within the LCO. Without the note, the associated RHR pump would be declared inoperable,

which would be contrary to the intent of the existing notes for SRs 3.5.1.2 and 3.5.2.4 which

allow the LPCI subsystem to be operable when aligned for OHR. Therefore, the NRC staff

concludes that Variation 1 is acceptable.

3.5.2 Variation 2, CS and LPCI Manual Initiation Logic

There are STS SRs proposed in TSTF-542, Revision 2, related to "manual initiation," that do not

appear in the current JAFNPP TSs. The licensee stated in the LAR that the "manual initiation"

logic does not exist in the JAFNPP design. Since this is the case, these functions as well as

related TSTF-542, Revision 2, SRs 3.3.5.2.3 and 3.5.2.8 do not apply to JAFNPP.

As an alternative, the licensee proposed that TS 3.5.2 include an SR 3.5.2.8 to verify that the

JAFNPP-required ECCS injection/spray subsystem can be manually operated through the

manipulation of subsystem components from the MCR.

Additionally, as stated by the licensee in the LAR dated October 2, 2017:

The manual operation of the required ECCS injection/spray subsystem for the

control of reactor cavity or RPV inventory is a relatively simple evolution and

involves the manipulation of a small number of components. These subsystem

alignments can be performed by licensed operators from the Main Control Room.

This alternative is justified by the fact that a draining event is a slow evolution

when compared to a design basis loss of coolant accident, which is assumed to

occur at full power, and thus, there is adequate time to take manual actions

(i.e., hours versus minutes). Adequate time to take action is assured since the

proposed TS 3.5.2, Condition E, prohibits plant conditions that result in drain

times that are less than one hour. Therefore, there is sufficient time for the

licensed operators to take manual action to stop an unanticipated draining event,

and to manually start an ECCS injection/spray subsystem or the additional

method of water injection.

- 30 -

Since the ECCS injection/spray subsystem can be placed in service using

manual means in a short period of time (i.e., within the time frames assumed in

the development of TSTF-542), using controls and indications that are readily

available in the Main Control Room, manual operation of the required subsystem

would be an equivalent alternative to system initiation via manual initiation logic.

Current SR 3.5.1.6 and SR 3.5.2.4 manually operate the ECCS injection/spray

pumps to verify each required ECCS injection/spray pump develops the specified

flow rate against a system head corresponding to the specified reactor pressure

at a frequency specified by the lnservice Testing (1ST} Program. The 1ST

Program requires the ECCS injection/spray subsystems motor operated injection

valves, minimum flow valves and test flow path valves (with the exception of the

CS test flow path valves) be cycled to demonstrate operability and compliance

with 1ST stroke time requirements at a frequency specified by the 1ST Program.

The CS test flow path valves are part of the 1ST Program but do not have stroke

time requirements. The CS valves are cycled for position indication verification

only.

The manual operation of the ECCS injection/spray subsystem to demonstrate

operability required by the proposed SR 3.5.2. 7 is equivalent to the testing that is

presently required to be performed on the ECCS injection/spray subsystems.

The NRC staff reviewed the licensee's proposed alternative and determined that although

JAFNPP does not have the capability to start an ECCS subsystem with a single push button,

the components that provide ECCS injection/spray into the RPV can be started from the MCR,

as required, to support Modes 4 and 5 operations. The manipulation of low pressure ECCS

subsystem components from the MCR would be verified in accordance with new SR 3.5.2.8.

This SR verifies that the required CS or LPCI subsystem (including associated pump switches,

and valves) can be manually operated to provide additional RPV water inventory, if needed.

Therefore, the NRC staff concludes that Variation 2 is acceptable.

3.5.3 Variation 3, RWCU System Isolation Occurs at Reactor Vessel Water

Level - Low Level 3

The licensee stated in the LAR that the JAFNPP design for RWCU isolation is on Reactor

Vessel Water Level - Low (Level 3), not Reactor Vessel Water Level - Low, Low (Level 2) as in

STS. The licensee states in the LAR:

The intent of the TSTF is to change the applicability of this function, but does not

change the setpoint or allowable value. This variation is technical however is

consistent with the intent of TSTF 542.

This variation clarifies the JAFNPP design differences when compared to TSTF-542,

Revision 2, concerning the requirements for RWCU isolation. The NRC staff concludes that

Variation 3 is acceptable because the JAFNPP function proposed for RWCU system isolation is

appropriate to meet the intent of TSTF-542, Revision 2.

3.5.4 Variation 4, CS Time Delay Relay Function Deleted in Modes 4 and 5

The licensee stated in the LAR that the JAFNPP TS for the CS time delay relay function

(Function 1.d. of TS Table 3.3.5.1-1) does not appear in the STS table and this function is

- 31 -

proposed to be deleted in Modes 4 and 5 using the same justification provided in the TSTF for

deletion of the LPCI time delay relay function (Function 2.f. of TS Table 3.3.5.1-1 ). The TSTF

discussion in part mentions that the time delay relay is part of the automatic initiation system

which will not be needed in Modes 4 and 5 because manual manipulation of the necessary

components for CS subsystem initiation will be used from the control room to provide make-up

water to the RPV in a drain down event.

The NRC staff finds that electrical emergency bus staggering is not necessary for manual

operation. This function can be removed from the TS because the required ECCS subsystem is

proposed to be started by manual operation. Therefore, NRC staff concludes that Variation 4 is

acceptable.

3.5.5 Variation 5, CS Pump Discharge Pressure - High (Bypass) Function

The JAFNPP CS pump discharge pressure high bypass function (Function 1.f. of TS

Table 3.3.5.1-1) does not appear in the STS table. The licensee proposed to carry this function

into proposed TS Table 3.3.5.2-1 consistent with the justification for CS and LPCI pump

discharge flow low bypass functions.

The licensee explains in Section 2.2.7 of the LAR dated October 2, 2017:

JAFNPP TS Table 3.3.3.5.1-1 contains Function 1.f, "Core Spray Pump

Discharge Pressure - High (Bypass)", that does not appear in the STS table.

The Function is required to be operable in Modes 1, 2, 3, 4 and 5. The

Function is required for protection of the low pressure ECCS pump from

overheating when the associated injection valve is not fully open, similar to STS

Function 1.d and 2.g, "Core Spray and Low Pressure Coolant Injection Pump

Discharge Flow- Low (Bypass)". Modes 4 and 5 of JAFNPP TS Function 1.f are

being moved to the new TS 3.3.5.2 as Function 1.c. Justification for this move is

consistent with the justification provided in TSTF-542 Section 3.4.2 for STS

Functions 1.d and 2.g from TS Table 3.3.5.1-1.

The NRC staff reviewed the proposed change and concludes that the inclusion of Function 1.c.

in TS Table 3.3.5.2-1 in addition to Function 1.b. is consistent with the requirements described

in TSTF-542 Section 3.3.4.2 regarding ECCS pump minimum flow instrumentation. Therefore,

the NRC staff concludes that Variation 5 is acceptable.

3.6 Staff Evaluation of Proposed Deletion of Reference to OPDRVS

(incl. Related Requirements

Section 2.2.4 of this SE lists the numerous OPDRVs references located in the JAFNPP TSs

where the licensee proposed deletion of phrases used for controls during OPDRVs from the

various TS elements.

The proposed changes remove the following from the current JAFNPP TS: the term "operations

with a potential for draining the reactor vessel," the acronym "OPDRVs," and related concepts

such as "RHR Shutdown Cooling System integrity maintained," and Required Actions to

"suspend OPDRVs." The TS OPDRV requirements have existed for many years, but there is no

clearly stated description of the event that is being prevented or mitigated. However, from the

existing TS requirements, one can infer the postulated event that forms the basis of the existing

TS.

The current JAFNPP TSs contain instrumentation requirements related to OPDRVs in four TSs;

three of them, which have the OPDRVs phrases described above, and TS 3.3.5.1. The

proposed TS 3.3.5.2 consolidates the instrumentation requirements into a single location to

simplify the presentation and provide requirements consistent with TS 3.5.2. The remaining

TSs with OPDRVs requirements are for containment, containment isolation valves, SGT

system, control room habitability, temperature control, and electrical sources. Each of these

systems' requirements during OPDRVs were proposed for consolidation into new TS 3.5.2 for

RPV WIC, based on the appropriate plant conditions and calculated DRAIN TIME.

The NRC staff has determined that the deletion of OPDRVs references, along with the

corresponding editorial changes, are appropriate because the proposed TSs governing RPV

WIC and the associated instrumentation, TSs 3.5.2 and 3.3.5.2, respectively, are a clarified and

simplified alternative set of controls for ensuring RPV water level is maintained above the

JAFNPP TS Safety Limit 2.1.1.3.

3.7 Staff Evaluation of TS 3.10, Special Operations and TSTF 484, "Use of TS 3.10.1 for Scram Time Testing activities"

The current JAFNPP TS LCO 3.10.1, "lnservice Leak and Hydrostatic Testing Operation,"

allows performance of an inservice leak or hydrostatic test with the average reactor coolant

temperature greater than 212 °F, while considering operational conditions to still be in Mode 4,

provided certain secondary containment and SGT system LCOs were met.

The licensee's adoption of TSTF-484 (Reference 9) revised this LCO to expand its scope to

include operations where RCS temperature exceeds 212 °F: (1) as a consequence of

maintaining adequate reactor pressure for an inservice leak or hydrostatic test, or (2) as a

consequence of maintaining adequate reactor pressure for control rod scram time testing

initiated in conjunction with an inservice leak or hydrostatic test.

When the NRC approved LCO 3.10.1 and TSTF-484 for JAFNPP, the staff stated, in part, that

"two low-pressure emergency core cooling systems (ECCS) injection/spray [i.e., CS or LPCI]

subsystems are required to be operable in Mode 4 by TS 3.5.2, ECCS-Shutdown"; however, per

the new LCO 3.5.2 adopted as part of TSTF-542, Revision 2, only one low pressure ECCS

injection/spray subsystem would be required to be operable in Mode 4.

The NRC staff determined that changing from two ECCS injection/spray subsystems to one

ECCS injection/spray subsystem is acceptable because this level of redundancy is not required,

even during application of LCO 3.10.1. When the licensee applies LCO 3.10.1 at the end of a

refueling outage, an exceptionally large volume of water is present in the reactor vessel since

the vessel is nearly water solid. There is much more water in the reactor vessel than is present

during power operation and more than that present during most of an outage. Small leaks from

the RCS would be detected by inspections before a significant loss of inventory occurred. In the

event of a large RCS leak, the RPV would rapidly depressurize and allow operation of the low

pressure ECCS. At low decay heat values, and near Mode 4 conditions, the stored energy in

the reactor core will be very low. Therefore, the reasoning that operators would have time to

respond with manual actions to start any ECCS pumps and properly align valves for injection

from the control room remains valid.

As previously stated in Section 3.3 of this SE, with one ECCS injection/spray subsystem and

non-safety related injection sources, defense-in-depth will be maintained. The defense-in-depth

measure is consistent with other events considered during shutdown with no additional single

failure assumed. The DRAIN TIME controls, in addition to the required ECCS injection/spray

subsystem, provide reasonable assurance that an unexpected draining event can be prevented

or mitigated before the RPV water levelwould be lowered to the TAF.

After considering the reasoning presented elsewhere in this SE for TSTF-542, Revision 2, and

after additional review of the SE for JAFNPP TS 3.10.1 and TSTF-484, the NRC staff

determined that LCOs 3.3.5.2 and 3.5.2 adopted as part of TSTF-542, Revision 2, are

satisfactory and will therefore be acceptable even during application of LCO 3.10.1.

Proposed Changes to the TS Table of Contents

In the LAR, the licensee proposed administrative changes to the table of contents (TOC) to

reflect the above TS changes. These changes are administrative and do not affect the

applicability of TSTF 542, Revision 2, to the JAFNPP TSs. In addition, the proposed changes

do not change any requirements in the JAFNPP TS. Therefore, the NRC staff concludes that

these changes are acceptable.

3.8 Technical Conclusion

The JAFNPP TS Safety Limit 2.1.1.3 requires that the RPV water level shall be greater than the

TAF. Maintaining RPV water level above the TAF ensures that the fuel cladding fission product

barrier is protected during shutdown conditions. The proposed changes to the TS establish new

LCO requirements that address the preventive and mitigative equipment and associated

instrumentation that provide an alternative means to support the JAFNPP TS Safety

Limit 2.1.1.3 during Mode 4 and 5 operations.

During operation in Modes 4 and 5, the reactor coolant system is at a low operating temperature

(:S 212 °F) and is depressurized. An event involving a loss of inventory while in the shutdown

condition does not exceed the capacity of one ECCS subsystem. The accident that is

postulated to occur during shutdown conditions, the fuel handling accident, does not involve a

loss of inventory. Therefore, the equipment and instrumentation associated with the reactor

vessel water inventory control TS do not provide detection or mitigation related to this design

basis accident.

The proposed TS LCO 3.5.2 contains requirements for operability of one ECCS subsystem

along with requirements to maintain a sufficiently long DRAIN TIME so that plant operators

would have time to diagnose and mitigate an unplanned draining event. The NRC staff has

determined that LCOs 3.5.2 and 3.3.5.2 provide for the lowest functional capability or

performance levels of equipment required for safe operation of the facility, and therefore, meet

the LCO requirements of 10 CFR 50.36(c)(2)(i).

Additionally, the proposed TS LCOs 3.5.2 and 3.3.5.2 provide remedial actions to be taken in

the event the LCO is not satisfied and, therefore, meeting the requirements of

10 CFR 50.36(c)(2)(i). The NRC staff has determined that the remedial actions provide

reasonable assurance that an unexpected draining event can be prevented or mitigated before

the RPV water level would be lowered to the TAF.

The NRC staff evaluated the proposed DRAIN TIME definition, TS 3.5.2, which contains the

requirements for RPV WIC, and TS 3.3.5.2, which contains the requirements for instrumentation

necessary to support TS 3.5.2. Based on the considerations discussed above, the NRC staff

concludes that the proposed revisions are acceptable because they consolidate and clarify the

RPV WIC requirements, which meet 10 CFR 50.36(c)(2)(ii) Criterion 4 to establish LCOs for

structures, systems, or components significant to public health and safety as evidenced by

operating experience.

The licensee proposed to delete OPDRVs references from JAFNPP TS elements. The NRC

staff reviewed the proposed changes and determined that the deletion of OPDRVs references,

along with the corresponding editorial changes, are appropriate because the proposed TSs

governing RPV WIC and the associated instrumentation, TSs 3.5.2 and 3.3.5.2, respectively,

are a clarified and simplified alternative set of controls for ensuring that RPV water level is

maintained above the JAFNPP TS Safety Limit 2.1.1.3.

The NRC staff reviewed the SRs associated with the new LCOs 3.5.2 and 3.3.5.2. The NRC

staff has determined that the proposed TS 3.5.2 SRs are acceptable since they support DRAIN

TIME requirements, assure that water inventory is available for ECCS injection/spray subsystem

RPV injection and pump performance, ECCS injection/spray subsystem are adequately filled,

the subsystems have verified valve positions to support RPV injection, verified pumps provide

adequate flow to support DRAIN TIME and RPV injection, verification of automatic isolation, and

ECCS injection/spray subsystems can be manually operated to inject. The NRC staff finds that

the two SRs proposed for TS 3.3.5.2 are sufficient and adequate, because they are essential to

ensure that the functions are capable of performing their specified safety functions in support of

TS 3.5.2, DRAIN TIME, and the protection from a potential drain down of the RPV in Modes 4

and 5. Therefore, the NRC staff concludes that the proposed SRs satisfy 10 CFR 50.36(c)(3).

The NRC staff evaluated the proposed changes against JAFNPP's applicable design

requirements listed in Section 2.3.3 of this SE. The NRC staff finds that the proposed changes

for Mode 4 and 5 operations related to the new DRAIN TIME definition and the removal of

OPDRVs references are consistent with the GDCs in that the JAFNPP design requirements are

maintained for instrumentation, reactor coolant leakage detection, the reactor coolant pressure

boundary, and reactor coolant makeup.

The regulation at 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons

for such specifications, other than those covering administrative controls, shall also be included

in the application, but shall not become part of the TSs. In accordance with this requirement,

the licensee provided TS Bases changes in Attachment 3 of the LAR dated October 2, 2017.

The NRC staff concluded that the TS Bases changes provided describe the basis for the

affected TS and follow the Final Policy Statement on Technical Specifications Improvements for

Nuclear Power Reactors (58 FR 39132; July 22, 1993).

Additionally, the proposed TS changes were reviewed for technical clarity and consistency with

the existing JAFNPP requirements for customary terminology and formatting. The NRC staff

found that the proposed changes were consistent with TSTF-542, Revision 2, and Chapter 16 of

the SRP.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the appropriate official for the State of New

York was notified of the NRC's proposed issuance of the amendment on August 10, 2018. The

State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of facility

components located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves no significant increase in the

amounts, and no significant change in the types, of any effluents that may be released offsite,

and that there is no significant increase in individual or cumulative occupational radiation

exposure. The Commission has previously issued a proposed finding that the amendment

involves no significant hazards consideration (82 FR 55406; November 21, 2017), and there has

been no public comment on such finding. Accordingly, the amendment meets the eligibility

criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in

connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there

is reasonable assurance that the health and safety of the public will not be endangered by

operation in the proposed manner, (2) there is reasonable assurance that such activities will be

conducted in compliance with the Commission's regulations, and (3) the issuance of the

amendment will not be inimical to the common defense and security or to the health and safety

of the public.

7.0 REFERENCES

1. Barstow, James, Exelon Generation Company, LLC, letter to U.S. Nuclear Regulatory

Commission, "Application to Revise Technical Specifications to Adopt [Technical

Specifications Task Force] TSTF-542, 'Reactor Pressure Vessel Water Inventory

Control,' Revision 2," dated October 2, 2017 (Agencywide Documents Access and

Management System (ADAMS) Accession No. ML 17275A520).

2. Gudger, David T., Exelon Generation Company, LLC, letter to U.S. Nuclear Regulatory

Commission, "Supplemental Response Concerning License Amendment Request to

Revise Technical Specifications to Adopt TSTF-542, 'Reactor Pressure Vessel Water

Inventory Control,' Revision 2," dated January 22, 2018 (ADAMS Accession

No. ML 18022A829).

3. Gudger, David T., Exelon Generation Company, LLC, letter to U.S. Nuclear Regulatory

Commission, "Response to Request for Additional Information Application to Revise

Technical Specifications to Adopt TSTF-542, 'Reactor Pressure Vessel Water Inventory

Control,' Revision 2," dated April 19, 2018 (ADAMS Accession No. ML 18109A371).

4. Technical Specifications Task Force letter to U.S. Nuclear Regulatory Commission,

"Response to NRC Request for Additional Information Regarding TSTF-542, Revision 1,

'Reactor Pressure Vessel Water Inventory Control' and Submittal of Revision 2," dated

March 14, 2016 (ADAMS Accession No. ML 16074A448).

5. Klein, Alexander, U.S. Nuclear Regulatory Commission, letter to Technical

Specifications Task Force, "Final Safety Evaluation of Technical Specifications Task

Force Traveler TSTF-542, Revision 2, 'Reactor Pressure Vessel Water Inventory

Control' (TAC No. MF3487)," dated December 20, 2016 (ADAMS Accession

No. ML 16343B008).

6. U.S. Nuclear Regulatory Commission, NUREG-0800, Revision 3, "Standard Review

Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Chapter 16.0,

"Technical Specifications," March 2010 (ADAMS Accession No. ML 100351425).

7. Haskell II, Russell, U.S. Nuclear Regulatory Commission, electronic mail to Christian

Williams, Exelon Generation Company, LLC, "James A. FitzPatrick Nuclear Power Plant,

Unit 1 - Request for Information to Adopt Traveler TSTF-542, 'Reactor Pressure Vessel

Water Inventory Control' (EPID: L-2017-LLA-0311 )," dated March 26, 2018 (ADAMS

Accession No. ML 18085A692).

8. U.S. Nuclear Regulatory Commission, NUREG-1433, Revision 4.0, "Standard Technical

Specifications, General Electric BWR/4," April 2012 (ADAMS Accession

No. ML 12104A192).

9. Beska, John P., U.S. Nuclear Regulatory Commission, letter to Michael Kansler, Entergy

Nuclear Operations, Inc., "James A. FitzPatrick Nuclear Power Plant - Issuance of

Amendment Re: Technical Specification 3.10.1, lnservice Leak and Hydrostatic Testing

Operation, Consistent with Technical Specifications Task Force Traveler-484," dated

June 21, 2007 (ADAMS Accession No. ML071550079).

Principal Contributors: Pete Snyder, NRR

Diana Woodyatt, NRR

Daniel Warner, NRR

Date of issuance: August 2 4 , 2 o 18

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

ML18194A882

Text

Dear Mr. Hanson:

Enclosures:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

2.1 System Description

2.2.1 Addition of DRAIN TIME Definition

2.2.4 Deletion of OPDRV References and Other Changes

3.0 TECHNICAL EVALUATION

3.1 Staff Evaluation of Proposed DRAIN TIME Definition

3.2 Staff Evaluation of Proposed TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation"

3.2.1 Staff Evaluation of Proposed TS 3.3.5.2 LCO and Applicability

3.2.2 Staff Evaluation of Proposed TS 3.3.5.2 Actions

3.2.3 Staff Evaluation of Proposed TS 3.3.5.2 Surveillance Requirements

3.2.4 Staff Evaluation of Proposed TS Table 3.3.5.2-1, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation"

3.4 Staff Evaluation of TS Table 3.3.5.1, Emergency Core Cooling System Instrumentation

3.5 Staff Evaluation of the Proposed Technical Variations

3.6 Staff Evaluation of Proposed Deletion of Reference to OPDRVS

3.7 Staff Evaluation of TS 3.10, Special Operations and TSTF 484, "Use of TS 3.10.1 for Scram Time Testing activities"

3.8 Technical Conclusion

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

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