Text

Attachment 3 - Proposed Technical Specification Bases Changes (Mark-Up)
	ML22140A137
Person / Time
Site:	Point Beach
Issue date:	05/20/2022
From:	; Point Beach
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML22140A131	List: ML22140A132; ML22140A133; ML22140A134; ML22140A135; ML22140A136; ML22140A137; ML22140A138; ML22140A139; ML22140A140; ML22140A141; ML22140A142; ML22140A143; ML22140A144; NRC 2022-0007, Enclosure 11 - Monitoring Program;
References
	NRC 2022-0007
	Download: ML22140A137 (17)
	v • d • e

Point Beach Nuclear Plant, Units 1 and 2 NRC 2022-0007 Docket Nos. 50-266 and 50-301 Attachment 3 Page 58 of 136 ATTACHMENT 3 Point Beach Units 1 and 2 License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b Proposed Technical Specification Bases Changes (Mark-Up)

(33 pages follow)

RPS Instrumentation B 3.3.1 BASES ACTIONS A Note has been added to the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.1-1.

In the event a channel's as-found trip setpoint is found nonconservative with respect to the Allowable Value, or the transmitter, instrument loop, signal processing electronics, or bistable is found inoperable, then all affected Functions provided by that channel must be declared inoperable and the LCO Condition(s) entered for the protection Function(s) affected.

When the number of inoperable channels in a trip Function exceed those specified in one or other related Conditions associated with a trip Function, then the unit is outside the safety analysis. Therefore, LCO 3.0.3 must be immediately entered if applicable in the current MODE of operation.

A.1 Condition A applies to all RPS protection Functions. Condition A addresses the situation where one or more required channels or trains for one or more Functions are inoperable at the same time. The Required Action is to refer to Table 3.3.1-1 and to take the Required Actions for the protection functions affected. The Completion Times are those from the referenced Conditions and Required Actions.

B.1 and B.2 Condition B applies to the Manual Reactor Trip in MODE 1 or 2. With one channel inoperable, the inoperable channel must be restored to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . In this condition, the remaining

...or in accordance with the OPERABLE channel is adequate to perform the safety function.

Risk Informed Completion The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is reasonable considering that there Time Program are two automatic actuation trains and another manual initiation channel OPERABLE, and the low probability of an event occurring during this interval.

If the Manual Reactor Trip Function cannot be restored to OPERABLE status within the allowed 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time, the unit must be brought to a MODE in which the requirement does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 additional hours. The 6 additional hours to reach MODE 3 is reasonable, based on operating experience, to reach MODE 3 from full power operation in an orderly manner and without challenging unit systems. With the unit in MODE 3, this trip Function is no longer required to be OPERABLE.

...Condition Y must be entered and...

Point Beach B 3.3.1-32 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

RPS Instrumentation

...or in accordance with the B 3.3.1 Risk Informed Completion Time Program.

BASES ACTIONS (continued) A known inoperable channel must be placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Placing the channel in the tripped condition results in a partial trip condition requiring only one-out-of-two logic for actuation of the two-out-of-three trips and one-out-of-three logic for actuation of the two-out-of-four trips.

If the inoperable channel cannot be placed in the tripped condition within the specified Completion Time, the unit must be placed in a MODE where these Functions are not required OPERABLE. An additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is allowed to place the unit in MODE 3. Six hours is a reasonable time, based on operating experience, to place the unit in MODE 3 from full power in an orderly manner and without challenging unit systems. ...by Condition Y

...or in accordance with the E.1 and E.2 Risk Informed Completion Condition E applies to the Underfrequency Bus A01 and A02 trip Time Program. function. With one channel inoperable, the inoperable channel must be placed in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Placing the channel in the tripped condition results in a partial trip condition requiring only one additional channel to initiate a reactor trip above the P-7 setpoint. The

...time allowed 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to place the channel in the tripped condition is necessary due to plant design requiring maintenance personnel to effect the trip of the channel outside of the Control Room. An additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is allowed to reduce THERMAL POWER to below P-7 if the inoperable channel cannot be restored to OPERABLE status or placed in trip within the specified Completion Time. ...by Condition Z Allowance of this time interval takes into consideration the redundant capability provided by the remaining redundant OPERABLE channel and the low probability of occurrence of an event during this period that may require the protection afforded by this trip function.

Point Beach B 3.3.1-34 12/19/01

This page is for information only. No changes are proposed for this page.

RPS Instrumentation B 3.3.1 BASES ACTIONS (continued) H.1 Condition H applies to one inoperable Source Range Neutron Flux trip channel when in MODE 2, below the P-6 setpoint, and performing a reactor startup. With the unit in this Condition, below P-6, the NIS source range performs the monitoring and protection functions. With one of the two channels inoperable, operations involving positive reactivity additions shall be suspended immediately.

This will preclude any power escalation. With only one source range channel OPERABLE, core protection is severely reduced and any actions that add positive reactivity to the core must be suspended immediately.

I.1 Condition I applies to two inoperable Source Range Neutron Flux trip channels when in MODE 2, below the P-6 setpoint and performing a reactor startup, or in MODE 3, 4, or 5 with the RTBs closed and the Rod Control System capable of rod withdrawal. With the unit in this Condition, below P-6, the NIS source range perform the monitoring and protection functions. With both source range channels inoperable, the RTBs must be opened immediately. With the RTBs open, the core is in a more stable condition.

J.1 and J.2 Condition J applies to one inoperable source range channel in MODE 3, 4, or 5 with the RTBs closed and the Rod Control System capable of rod withdrawal. With the unit in this Condition, below P-6, the NIS source range performs the monitoring and protection functions. With one of the source range channels inoperable, 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is allowed to restore it to an OPERABLE status. If the channel cannot be returned to an OPERABLE status, 1 additional hour is allowed to open the RTBs.

Once the RTBs are open, the core is in a more stable condition.

K.1 and K.2 Condition K applies to the following reactor trip Functions:

Pressurizer Pressure-Low; Pressurizer Water Level-High;Reactor Coolant Flow-Low (Two Loops);

Undervoltage Bus A01 and A02.

Point Beach B 3.3.1-36 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

RPS Instrumentation B 3.3.1

...or in accordance with the BASES Risk Informed Completion Time Program.

ACTIONS (continued) With one channel inoperable, the inoperable channel must be placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Placing the channel in the tripped condition results in a partial trip condition requiring only one additional channel to initiate a reactor trip above the P-7 interlock and below the P-8 setpoint. These Functions do not have to be OPERABLE below the P-7 interlock because there are no loss of flow trips below the P-7 interlock. An additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is allowed to reduce THERMAL POWER to below P-7 if the inoperable channel cannot be restored to OPERABLE status or placed in trip within the specified Completion Time.

...by Condition Z Allowance of this time interval takes into consideration the redundant capability provided by the remaining redundant OPERABLE channel, and the low probability of occurrence of an event during this period that may require the protection afforded by the Functions associated with Condition K.

...or in accordance with the L.1 and L.2 Risk Informed Completion Condition L applies to the Reactor Coolant Flow-Low (Single Loop)

Time Program. reactor trip Function. With one channel inoperable, the inoperable channel must be placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . If the channel cannot be restored to OPERABLE status or the channel placed in trip within the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , then THERMAL POWER must be reduced below the P-8 setpoint within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This places the unit in a

... time allowed, then MODE where the LCO is no longer applicable. This trip Function does not have to be OPERABLE below the P-8 setpoint because other RPS Condition AA must be trip Functions provide core protection below the P-8 setpoint.

entered. Condition AA requires that the... M.1 and M.2

...or in accordance with the Condition M applies to the RCP Breaker Position (Single Loop) reactor Risk Informed Completion trip Function. There is one breaker position device per RCP breaker.

Time Program. With one channel inoperable, the inoperable channel(s) must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . If the channel cannot be restored to OPERABLE status within the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , then THERMAL POWER must be reduced below the P-8 setpoint within the next

...time allowed, Condition 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

AA must be entered and ...

This places the unit in a MODE where the LCO is no longer applicable.

This Function does not have to be OPERABLE below the P-8 setpoint because other RPS Functions provide core protection below the P-8 setpoint.

Point Beach B 3.3.1-37 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

RPS Instrumentation B 3.3.1 BASES

...or in accordance with the Risk Informed Completion ACTIONS (continued) N.1 and N.2 Time Program.

Condition N applies to the RCP Breaker Position (Two Loop) reactor trip Function. With one channel inoperable, the inoperable channel must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . If the channel cannot be restored to OPERABLE status in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , then THERMAL POWER must be reduced below the P-7 interlock within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This places the unit in a MODE where the LCO is no longer applicable. This function does not have to be OPERABLE below the P-7 interlock because there are no loss of flow trips below the P-7 interlock. The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on

...within the time allowed, operating experience, to reduce THERMAL POWER to below the P-7 Condition Z must be interlock from full power in an orderly manner without challenging unit systems.

entered and...

...or in accordance with the O.1 and O.2 Risk Informed Completion Condition O applies to Turbine Trip on Low Autostop Oil Pressure or on Time Program.

Turbine Stop Valve Closure. With one channel inoperable, the inoperable channel 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 . If placed in the tripped condition, this results in a partial trip condition requiring only one additional channel to initiate a reactor trip. If the channel cannot be restored to OPERABLE status or placed in the trip

...within the time allowed, condition, then power must be reduced below the P-9 setpoint within Condition BB must be the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

entered and...

.., or in accordance with the P.1 and P.2

... Condition Y must be entered and ...

Risk Informed Completion Condition P applies to the SI Input from ESFAS reactor trip and the Time Program,..

RPS Automatic Trip Logic in MODES 1 and 2. These actions address the train orientation of the RPS for these Functions. With one train inoperable, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months are allowed to restore the train to OPERABLE status (Required Action P.1) or the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (Required Action P.1) is reasonable considering that in this Condition, the remaining OPERABLE train is adequate to perform the safety function and given the low probability of an event during this interval. The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (Required Action P.2) is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging unit systems.

... allowed by Condition Y... The Required Actions have been modified by a Note that allows bypassing one train for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for surveillance testing, provided the other train is OPERABLE.

Point Beach B 3.3.1-38 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

RPS Instrumentation B 3.3.1

... Condition Y must .., or in accordance with the Risk be entered and... Informed Completion Time Program,...

BASES ACTIONS (continued) Q.1 and Q.2 ... allowed by Condtion Y...

Condition Q applies to the RTBs in MODES 1 and 2. With one RTB inoperable, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore the RTB to OPERABLE status or the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging unit systems. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Completion Times are equal to the time allowed by LCO 3.0.3 for shutdown actions in the event of a complete loss of RPS Function. Placing the unit in MODE 3 removes the requirement for this particular Function.

The Required Actions have been modified by a Note allowing one channel to be bypassed for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months provided the other channel is OPERABLE.

R.1 and R.2 Condition R applies to the P-6 interlock (in MODE 2) and the P-10 interlock. With one or more channels inoperable for one-out-of-two or two-out-of-four coincidence logic, the associated interlock must be verified to be in its required state for the existing unit condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Verifying the interlock status manually accomplishes the interlock's Function. The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is based on operating experience and the minimum amount of time allowed for manual operator actions. The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging unit systems. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Completion Times are equal to the time allowed by LCO 3.0.3 for shutdown actions in the event of a complete loss of RPS Function.

S.1 and S.2 Condition S applies to the P-7, P-8, and P-9 interlocks. With one or more channels inoperable for one-out-of-two or two-out-of-four coincidence logic, the associated interlock must be verified to be in its required state for the existing unit condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or the unit must be placed in MODE 2 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . These actions are conservative for the case where power level is being raised. Verifying the interlock status manually accomplishes the interlock's Function.

The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is based on operating experience and the minimum amount of time allowed for manual operator actions. The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 2 from full power in an orderly manner and without challenging unit systems.

Point Beach B 3.3.1-39 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

RPS Instrumentation B 3.3.1 BASES ACTIONS (continued) T.1 and T.2 Condition T applies to the RTBs and the RTB Undervoltage and Shunt Trip Mechanisms in MODES 3, 4, or 5 with the RTBs closed and the Rod Control System capable of rod withdrawal.

With one trip mechanism or RTB inoperable, the inoperable trip mechanism or RTB must be restored to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The Completion Time is reasonable considering that the remaining OPERABLE trip mechanism or RTB is adequate to perform the safety function, and given the low probability of an event occurring during this interval.

If the RTB or trip mechanism cannot be restored to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the unit must be placed in a MODE in which the requirement does not apply. This is accomplished by opening the RTBs within the next hour (49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months total time). The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provides sufficient time to accomplish this action in an orderly manner and takes into account the low probability of an event occurring in this interval.

, ...or in accordance with U.1 and U.2 the Risk Informed ...Condition Y must be entered and...

Completion Time Program,.. Condition U applies to the RTB Undervoltage and Shunt Trip Mechanisms, or diverse trip features, in MODES 1 and 2. With one of the diverse trip features inoperable, it must be restored to an OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or the unit must be placed in a MODE where the requirement does not apply. This is accomplished by placing the unit in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months total time).

The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is a reasonable time, based on operating experience, to reach MODE 3 from full power in an orderly

... allowed by manner and without challenging unit systems.

Condition Y...

With the unit in MODE 3, Condition T would apply to any inoperable RTB trip mechanisms. The affected RTB shall not be bypassed while one of the diverse features is inoperable except for the time required to perform maintenance to one of the diverse features. The allowable time for performing maintenance of the diverse features is 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for the reasons stated under Condition Q.

The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is reasonable considering that in this Condition there is one remaining diverse feature for the affected RTB, and one OPERABLE RTB capable of performing the safety function and given the low probability of an event occurring during this interval.

Point Beach B 3.3.1-40 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

ESFAS Instrumentation B 3.3.2 BASES ACTIONS B.1, B.2.1 and B.2.2 (continued)

Condition B applies to manual initiation of:

SI; and

.., or in accordance with the Risk Containment Isolation. Informed Completion Time Program,...

If a channel is inoperable, 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months are allowed to return it to OPERABLE status. The specified Completion Time is reasonable considering that there are two automatic actuation trains and another manual initiation train OPERABLE for each Function, and the low probability of an event occurring during this interval. If the channel cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months total time) and in MODE 5 within an additional 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months (84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months total time). The allowable Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

.., Condition L must ...of Condition L...

be entered and... C.1, C.2.1 and C.2.2 Condition C applies to the automatic actuation logic and actuation relays for the following functions:

The COMPLETION TIME of Condition C is modified by a note SI; which, due to limitations in the Seabrook PRA model, prohibits Containment Spray; and a Completion Time extension in .., or in accordance with the Risk Containment Isolation. Informed Completion Time Program,...

accordance with the a Risk Informed Completion Time for If one train is inoperable, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months are allowed to restore the train to Function 2b, Containment Spray - OPERABLE status. The specified Completion Time is reasonable Automatic Actuation Logic and considering that there is another train OPERABLE, and the low Actuation Relays, of Technical probability of an event occurring during this interval. If the train Specification 3.3.2, Table 3.3-2. cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months total time) and in MODE 5 within an additional 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months (42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months total time). The Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

...of Condition L...

.., Condition L must be entered and...

Point Beach B 3.3.2-28 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

ESFAS Instrumentation B 3.3.2 BASES The COMPLETION TIME of ACTIONS D.1, D.2.1 and D.2.2 (continued) Condition D is modified by a note Condition D applies to: which, due to limitations in the Seabrook PRA model, prohibits a Containment Pressure-High; Completion TIme extension in accordance with the Risk Informed Pressurizer Pressure-Low; Completion Time for Function 2c, Containment Spray - Containment Steam Line Pressure-Low; Pressure High-High, of Technical Containment Pressure-High High; Specification 3.3.2, Table 3.3-2.

High Steam Flow Coincident With Safety Injection Coincident With Tavg-Low; High High Steam Flow Coincident With Safety Injection;

.., or in accordance with the Risk SG Water level-Low Low; and Informed Completion Time Program,...

SG Water level-High.

If one channel is inoperable, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore the channel to OPERABLE status or to place it in the tripped condition. Placing the channel in the tripped condition is necessary to maintain a logic configuration that satisfies redundancy requirements.

... the time allowed requires entering Condition M and... Failure to restore the inoperable channel to OPERABLE status or place it in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months requires the unit be placed in MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

... of Condition M...

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.

Point Beach B 3.3.2-29 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

ESFAS Instrumentation B 3.3.2 BASES ACTIONS E.1, E.2.1, and E.2.2 (continued)

Condition E applies to manual initiation of Containment Spray. If one or both channels are inoperable, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to return the inoperable channel(s) to OPERABLE status. The Completion Time of one hour is reasonable considering that there are OPERABLE automatic actuation functions credited to perform the safety function and the low probability of an event occurring during this interval. If the inoperable channel(s) cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply.

This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months total time) and in MODE 5 within an additional 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months (37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months total time). The allowable Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

... within the time allowed, F.1, F.2.1, and F.2.2 Condition M must be entered and...

.., or in accordance with the Condition F applies to Manual Initiation of Steam Line Isolation.

Risk Informed Completion Time Program,... If a channel is inoperable, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to return it to an OPERABLE status. The Completion Time of one hour is reasonable considering the low probability of an event occurring during this interval. If the Function cannot be returned to OPERABLE status, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly manner and without challenging unit systems. In MODE 4, the unit does not have any analyzed transients or conditions that require the explicit use of the protection functions noted above.

... of Condition M...

G.1, G.2.1, and G.2.2 Condition G applies to the automatic actuation logic and actuation relays for the Steam Line Isolation, Feedwater Isolation, Condensate

.., or in accordance with the Isolation and AFW actuation Functions.

Risk Informed Completion Time Program,... If one train is inoperable, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months are allowed to restore the train to OPERABLE status. The Completion Time for restoring a train to OPERABLE status is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be returned to OPERABLE status, the unit must be brought to MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion

... within the time allowed, ConditionPoint M must be entered and...

Beach B 3.3.2-30 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

ESFAS Instrumentation B 3.3.2 BASES

... of Condition M...

ACTIONS Times are reasonable, based on operating experience, to reach the (continued) required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Placing the unit in MODE 4 removes all requirements for OPERABILITY of the protection channels and actuation functions. In this MODE, the unit does not have analyzed transients or conditions that require the explicit use of the protection functions noted above.

.., or in accordance with the Risk H.1 and H.2 Informed Completion Time Program,...

Condition H applies to the Undervoltage Bus A01 and A02 Function.

If one channel is inoperable, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months are allowed to restore one channel to OPERABLE status or place it in the tripped condition. If placed in the tripped condition, this Function is then in a partial trip condition where one-out-of-two logic will result in actuation. The 6

... time allowed... hours to place the channel in the tripped condition is necessary due to plant design requiring maintenance personnel to effect the trip of the channel outside of the control room. Failure to restore the inoperable channel to OPERABLE status or place it in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months requires the unit to be placed in MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Time of 6

... Condition M... hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit systems. In MODE 3, this Function is no longer required OPERABLE.

... the time allowed requires entry into Condition K and I.1, I.2.1 and I.2.2 Condition I applies to the Pressurizer Pressure SI Block.

With one or more channels inoperable, the operator must verify that the interlock is in the required state for the existing unit condition.

This action manually accomplishes the function of the block.

Determination must be made within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is equal to the time allowed by LCO 3.0.3 to initiate shutdown actions in the event of a complete loss of ESFAS function. If the block is not in the required state (or placed in the required state) for the existing unit condition, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Placing the unit in MODE 4 removes all requirements for OPERABILITY of the Pressurizer Pressure SI block.

Point Beach B 3.3.2-31 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

Pressurizer PORVs B 3.4.11 BASES ACTIONS (continued) B.1, B.2, and B.3 If one PORV is inoperable and not capable of being manually cycled, it must be either restored, or isolated by closing the associated block valve and removing the power to the associated block valve. The Completion Times of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months are reasonable, based on challenges to the PORVs during this time period, and provide the operator adequate time to correct the situation. If the inoperable valve cannot be restored to OPERABLE status, it must be isolated within the specified time.

Because there is at least one PORV that remains OPERABLE, an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is provided to restore the inoperable PORV to OPERABLE status. If the PORV cannot be restored within this additional time, the plant must be brought to a MODE in which the LCO

.., or in accordance with the does not apply, as required by Condition D.

Risk Informed Completion Time Program,.. C.1 and C.2 If one block valve is inoperable, then it is necessary to either restore the block valve to OPERABLE status within the Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or place the associated PORV in manual control. The prime importance for the capability to close the block valve is to isolate a stuck open PORV. Therefore, if the block valve cannot be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the Required Action is to place the PORV in manual control to preclude its automatic opening for an overpressure event and to avoid the potential for a stuck open PORV at a time that the block valve is inoperable. The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time period, and provides the operator time to correct the situation. Because at least one PORV remains OPERABLE, the operator is permitted a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the inoperable block valve to OPERABLE status. The time allowed to restore the block valve is based upon the Completion Time for restoring an inoperable PORV in Condition B, since the PORVs may not be capable of mitigating an event if the inoperable block valve is not full open. If the block valve is restored within the Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the power will be restored to the PORV. If it cannot be restored within this additional time, the plant must be brought to a

.., or in accordance with the MODE in which the LCO does not apply, as required by Condition D.

Risk Informed Completion Time Program,.. The Required Actions C.1 and C.2 are modified by a Note stating that the Required Actions do not apply if the sole reason for the block valve being declared inoperable is as a result of power being removed to comply with other Required Actions. In this event, the Required Actions for inoperable PORV(s) (which require the block valve power to be removed once it is closed) are adequate to address the condition.

While it may be desirable to also place the PORV(s) in manual control, Point Beach B 3.4.11-4 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

ECCS - Operating B 3.5.2 BASES APPLICABILITY In MODES 1, 2, and 3, the ECCS OPERABILITY requirements for the limiting Design Basis Accident, a large break LOCA, are based on full power operation. Although reduced power would not require the same level of performance, the accident analysis does not provide for reduced cooling requirements in the lower MODES. The SI pump performance requirements are based on a small break LOCA. MODE 2 and MODE 3 requirements are bounded by the MODE 1 analysis.

This LCO is only applicable in MODE 3 and above. Below MODE 3, the low pressurizer pressure and low steam generator pressure automatic SI signals are manually bypassed by operator control, and system functional requirements are relaxed as described in LCO 3.5.3, "ECCS Shutdown."

In MODES 5 and 6, plant conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops MODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops MODE 5, Loops Not Filled." MODE 6 core cooling requirements are addressed by LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation High Water Level," and LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation Low Water Level."

ACTIONS A.1 ... front stop...

With one train inoperable, the inoperable components must be returned to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is based on an NRC reliability evaluation (Ref. 5) and is a reasonable time

.., or in accordance with the for repair of many ECCS components.

Risk Informed Completion Time Program, ... An ECCS train is inoperable if it is not capable of delivering the limiting design basis analysis flow rate to the RCS or if the train is not capable of supporting recirculation mode operation. Individual components are inoperable if they are not capable of performing their design function or supporting systems are not available.

The LCO requires the OPERABILITY of a number of independent subsystems. Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component in a train does not render the ECCS incapable of performing its function. Neither does the inoperability of multiple components in the same train (e.g. the A SI pump and the A RHR pump), result in a loss of function for the ECCS.

The intent of this Condition is to maintain a combination of equipment such that a single OPERABLE ECCS train remains available.

Point Beach B 3.5.2-5 10/20/01

ECCS - Operating B 3.5.2 BASES ACTIONS (continued) An event accompanied by a loss of offsite power and the failure of an EDG can disable one ECCS train until power is restored. A reliability The Risk Informed analysis (Ref. 5) has shown that the impact of having one full ECCS Completion Time Program train inoperable is sufficiently small to justify continued operation for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

further evaluates the plant risk associated with this With more than one component inoperable such that both ECCS trains Condition to determine an are not available, the facility is in a condition outside design and appropriate Completion Time licensing basis. Therefore, LCO 3.0.3 must be immediately entered.

extension.

B.1 and B.2 If the inoperable trains cannot be returned to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.5.2.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an actuation signal is allowed to be in a non-accident position provided the valve will automatically reposition within the proper stroke time. This Surveillance does not require any testing or valve manipulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct position. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Surveillance frequency is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include a stationing of a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

Point Beach B 3.5.2-6 Unit 1 - Amendment No. 253 Unit 2 - Amendment No. 257

Containment Air Locks B 3.6.2 BASES ACTIONS (continued) B.1, B.2, and B.3 With an air lock interlock mechanism inoperable in one or more air locks, the Required Actions and associated Completion Times are consistent with those specified in Condition A. The Required Actions have been modified by two Notes. Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both bulkheads in the same air lock are inoperable. With both bulkheads in the same air lock inoperable, an OPERABLE isolation boundary is not available. Required Actions C.1 and C.2 are the appropriate remedial actions. Note 2 allows entry into and exit from containment under the control of a dedicated individual stationed at the air lock to ensure that only one bulkhead door and its associated equalization valve is opened at a time (i.e., the individual performs the function of the interlock).

Required Action B.3 is modified by a Note that applies to air lock doors and equalization valves located in high radiation areas and allows these doors and valves to be verified locked closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted.

Therefore, the probability of misalignment of the door or equalization valve, once it has been verified to be in the proper position, is small.

C.1, C.2, and C.3 With one or more air locks inoperable for reasons other than those described in Condition A or B, Required Action C.1 requires action to be initiated immediately to evaluate previous combined leakage rates using current air lock test results. An evaluation is acceptable, since it is overly conservative to immediately declare the containment inoperable if both bulkheads in an air lock are inoperable. In many instances (e.g., only one seal per door has failed), containment remains OPERABLE, yet only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (per LCO 3.6.1) would be provided to restore the air lock bulkhead to OPERABLE status prior to requiring a plant shutdown. In addition, even with both doors failing the seal test, the overall containment leakage rate can still be within limits.

Required Action C.2 requires that one door and its associated equalization valve in the affected containment air lock must be verified to be closed within the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time. This specified time period is consistent with the ACTIONS of LCO 3.6.1, which requires

.., or in accordance with the that containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Risk Informed Completion Time Program,... Additionally, the affected air lock(s) must be restored to OPERABLE status within the 36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Completion Time. The specified time period is Point Beach B 3.6.2-5 7/30/02

Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued) A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable containment isolation valve. Complying with the Required Actions may allow for continued operation, and subsequent inoperable containment isolation valves are governed by subsequent Condition entry and application of associated Required Actions.

The ACTIONS are further modified by a third Note, which ensures appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by an inoperable containment isolation valve.

In the event the containment isolation valve leakage results in exceeding the overall containment leakage rate, Note 4 directs entry into the applicable Conditions and Required Actions of LCO 3.6.1.

A.1 and A.2 In the event one containment isolation valve in one or more penetration flow paths is inoperable, the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic containment isolation valve, a closed manual valve, a blind flange, and a check valve with flow through the valve secured.

For a penetration flow path isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available one to containment. Required Action A.1 must be completed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable, considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1,

.., or in accordance with the 2, 3, and 4.

Risk Informed Completion Time Program, For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time and that have been isolated in accordance with Required Action A.1, the affected penetration flow paths must be verified to be isolated on a periodic basis. This is necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of being automatically isolated will be in the isolation position should an event occur. This Required Action does not require any testing or device manipulation. Rather, it involves verification that those isolation devices outside containment and capable of being mispositioned are in the correct position. The Completion Time of "once per 31 days for

... following isolation...

Point Beach B 3.6.3-4 11/18/2003

ML22140A137

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