TSTF-23-07, TSTF Response to NRC Request for Additional Information on TSTF-592, Revision 1, Revise Automatic Depressurization System (ADS) Instrumentation Requirements

TSTF Response to NRC Request for Additional Information on TSTF-592, Revision 1, Revise Automatic Depressurization System (ADS) Instrumentation Requirements

ML23256A352
Person / Time
Site:	99902042, Technical Specifications Task Force
Issue date:	09/13/2023
From:	Lashley P, Lueshen K, Richards A, Sparkman W, Vaughan J Technical Specifications Task Force
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
TSTF-23-07
Download: ML23256A352 (1)

Text

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 804-339-7034 Administration by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF September 13, 2023 TSTF-23-07 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

TSTF Response to NRC Request for Additional Information on TSTF-592, Revision 1, "Revise Automatic Depressurization System (ADS)

Instrumentation Requirements" On June 27, 2023, the TSTF submitted traveler TSTF-592, Revision 1, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23178A184). On August 10, 2023, the NRC provided a Request for Additional Information (RAI) (ADAMS Accession No. ML23222A227).

The TSTF's response to the NRC RAI is attached.

The responses to the NRC's questions resulted in a revision to the traveler. Revision 2 of TSTF-592 is enclosed.

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

Andrew M. Richards, Jr. (PWROG/W)

Phil H. Lashley (BWROG)

Kevin Lueshen (PWROG/CE)

Jordan L. Vaughan (PWROG/B&W)

Wesley A. Sparkman (PWROG/AP1000)

Attachment Enclosure cc:

Michelle Honcharik, Technical Specifications Branch Mahmoud Jardaneh, Technical Specifications Branch

TSTF Response to NRC Questions on TSTF-592, Revision 1, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements" Page A-1 The NRC request is repeated below in italics, followed by the TSTF response in unitalicized text.

INTRODUCTION By letter dated June 27, 2023 (ADAMS Accession No. ML23178A184), the Technical Specifications Task Force (TSTF) submitted to the U.S. Nuclear Regulatory Commission (NRC)

Traveler TSTF-592, Revision 1, Revise Automatic Depressurization System (ADS)

Instrumentation Requirements. TSTF-592 would revise Technical Specification (TS) 3.3.5.1, Emergency Core Cooling System (ECCS) Instrumentation, Actions related to the Automatic Depressurization System (ADS) initiation instrumentation to correct several overly restrictive requirements, and to treat less significant channel inoperabilitys consistently. The proposed change modifies NUREG-1433, Standard Technical Specifications - General Electric BWR/4 Plants, and NUREG-1434, Standard Technical Specifications, General Electric BWR/6 Plants (the STS).

The purpose of the ECCS instrumentation is to initiate appropriate responses from systems to ensure that the fuel is adequately cooled in the event of a design basis accident or transient.

The ECCS is designed to cool the reactor core following a loss of coolant accident (LOCA). The typical boiling water reactor (BWR) ECCS has low-pressure and high-pressure subsystems. The low-pressure ECCS subsystems are designed to mitigate a large break LOCA where reactor vessel pressure rapidly decreases to the point at which the low-pressure ECCS pumps can inject water. There are two redundant divisions for each of the low-pressure ECCS subsystems. For example, BWR/4 plants typically have two Low Pressure Coolant Injection (LPCI) subsystems and two Core Spray (CS) subsystems. BWR/6 plants typically have one Low Pressure Core Spray (LPCS) subsystem and three LPCI subsystems. There is a single high pressure ECCS subsystem.

For example, BWR/4 plants have High Pressure Coolant Injection (HPCI), and BWR/6 plants have High Pressure Core Spray (HPCS). The high-pressure ECCS subsystem is designed to mitigate small break LOCAs during which reactor vessel pressure remains higher than the ability of the low-pressure ECCS pumps to inject water.

The ECCS instrumentation actuates in part, the ADS. The ADS provides redundancy for the single high-pressure ECCS subsystem. In the event of failure of the high-pressure ECCS subsystem, the ADS valves open to rapidly reduce the reactor vessel pressure to the point at which a low-pressure ECCS pump can inject water.

To complete its review of TSTF-592, the NRC staff has determined that additional information is needed. The regulatory basis and the requested additional information are as follows.

REGULATORY BASIS FOR REQUEST The regulation at 10 CFR 50.36, Technical specifications, establishes the NRC regulatory requirements related to the content of the TS.

TSTF Response to NRC Questions on TSTF-592, Revision 0, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements" Page A-2 10 CFR 50.36(a)(1) states in part: A summary statement of the bases or reasons for such specification shall also be included in the application but shall not become part of the technical specifications.

10 CFR 50.36(c)(2) states: Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

REQUESTS FOR ADDITIONAL INFORMATION

1. Traveler TSTF-592 Revision 1, Section 3, Technical Evaluation states the following:

Therefore, Required Action H.1 states, Declare ADS valves inoperable when ADS Trip Systems A and B lose initiation capability due to Core Spray/LPCI Discharge Pressure -

High channels inoperable.

Traveler TSTF-592, Revision 1, proposed Required Action H.1 does not state what is quoted above. Provide correction to the traveler, as appropriate.

TSTF Response TSTF-592, Revision 1, revised Required Action H.1 toseparate the Required Action into a Required Action and a Note, but the justification was not revised to reflect this change. The justification has been revised to be consistent with the TS changes.

2. Traveler TSTF-592, Revision 1, response to the NRC staffs question (number seven) regarding the Bases expression or tripping appears to have two different outcomes for the same situation. For example, the response states in part, The last sentence of the NUREG-1433 Bases for Required Actions H.1, H.2, and H.3 is revised in the enclosed traveler to state, while allowing time for restoration or tripping of channels. [emphasis added].

It was also noted that in the existing Bases for Required Actions G.1 and G.2 in NUREG 1433 and NUREG-1434, the third paragraphs describe restoration or tripping of channels. Tripping of channels is not a Required Action under Condition G.

Therefore, the Bases text is revised to state restoration of channels.

In NUREG-1433 and 1434, "tripping" of channels is also not a proposed Required Action under proposed Condition H. Therefore, provide a justification for including "or tripping" in NUREG 1433 and NUREG-1434 Bases associated with proposed Required Actions H.1, H.2, and H.3.

TSTF Response to NRC Questions on TSTF-592, Revision 0, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements" Page A-3 TSTF Response The NUREG-1433 and 1434 Bases for Required Action H.1, H.2, or H.3, are revised to delete the phrase, "or tripping.

3. Traveler TSTF-592, Revision 1, Section 2.4, Description of Proposed Change, states the following for the proposed Completion Times associated with proposed Required Action H.2 (BWR/4 and BWR/6 TS 3.3.5.1): The option of including a Risk Informed Completion Time alternative is included but is outside the scope of this traveler to provide the technical justification. The sentence quoted above is confusing. Staff notes that the current Required Action G.2, was approved for use with the risk-informed completion time (RICT) program in TSTF 505. Therefore, the justification was provided in that traveler for including it in the RICT program. Staff notes that proposed Required Action H.2 addresses functions that are proposed to be split off from the current Required Action G.2. Both Completion Times for proposed Required Action H.2 have the option to apply a risk informed completion time and the Completion Times are the same as the current Required Action G.2. For clarity in TSTF 592, provide a similar explanation/justification and a reference to TSTF-505.

TSTF Response The traveler justification has been revised in Sections 2.4 and 3 to acknowledge that plants with an existing RICT applied to Required Action G.2 can also apply it to the modified Required Action G.2 and the new Required Action H.2.

4. Traveler TSTF-592, Revision 1, NUREG-1433, TS 3.3.5.1 contains a Note 2 for proposed Required Action H.1 and a Note 2 for proposed Required Action H.2. These Notes are missing the word Pump after Core Spray/LPCI. Including Pump aligns with the applicable Functions identified in Note 1 for proposed Required Action H.1 and Note 1 for proposed Required Action H.2. Provide correction to the traveler (Specs and Bases) as appropriate.

TSTF Response The TS, Bases, and justification have been revised as needed to consistently refer to the Functions as "pump discharge pressure" as titled in Table 3.3.5.1-1.

5. Traveler TSTF-592, Revision 1, NUREG-1434, TS 3.3.5.1 contains a Note 2 for proposed Required Action H.1 and a Note 2 for proposed Required Action H.2. These Notes are missing the word Pump after LPCS/LPCI. Including Pump aligns with the applicable Functions identified in Note 1 for proposed Required Action H.1 and Note 1 for proposed Required Action H.2. Provide correction to the traveler (Specs and Bases), as appropriate.

TSTF Response to NRC Questions on TSTF-592, Revision 0, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements" Page A-4 TSTF Response The TS, Bases, and justification have been revised as needed to consistently refer to the Functions as "pump discharge pressure" as titled in Table 3.3.5.1-1.

6. Provide correction to the traveler, as appropriate, for the following editorial related items:

a. Traveler Section 2.2, Current Technical Specification Requirements

i. BWR/4 Function 4.f is missing the word discharge (should read Low Pressure Coolant Injection Pump Discharge Pressure - High (emphasis added)).

ii. BWR/4 Function 4.h, 5.h and BWR/6 Function 4.h and 5.g incorrectly refer to Manual Actuation. The STS refer to Manual Initiation.

b. Traveler Section 2.4, Description of Proposed Change

i. BWR/4 proposed Condition H, Required Action H.1 Note 2 and Required Action H.2 Note 2, are missing the word Pump after Core Spray/LPCI.

ii. BWR/6 proposed Condition H, Required Action H.1 Note 2 and Required Action H.2 Note 2, are missing the word Pump after LPCS/LPCI.

c. Traveler Section 3, Technical Evaluation

i. BWR/4 Function 4.f and 5.f are missing the word discharge (should read Low Pressure Coolant Injection Pump Discharge Pressure - High (emphasis added)).

ii. BWR/4 Function 4.h, 5.h and BWR/6 Function 4.h and 5.g incorrectly refer to Manual Actuation. The STS refer to Manual Initiation.

TSTF Response These changes have been made.

7. Editorial wording differences between BWR/4 and BWR/6 new Action H that should be evaluated and addressed, for the following:

• Required Action H.1, Note 2 The BWR/4 RA H.1, Note 2 states in part:... when both ADS Trip Systems are inoperable due to...

TSTF Response to NRC Questions on TSTF-592, Revision 0, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements" Page A-5 The BWR/6 RA H.1, Note 2 states in part: when ADS Trip Systems A and B lose initiation capability due to Is there a rationale for the different wording? If not, when responding to the RAIs, kindly make them read the same, as appropriate. BWR/4 and BWR/6 wording both appear to be sufficient, but the BWR/6 wording is preferable.

• Required Action H.2, Note 2 The BWR/4 RA H.2, Note 2 states in part: when one ADS trip system is inoperable due to The BWR/6 RA H.2, Note 2 states in part: when one ADS trip system loses initiation capability due to Is there a rationale for the different wording? If not, when responding to the RAIs, kindly make them read the same, as appropriate. BWR/4 and BWR/6 wording both appear to be sufficient, but the BWR/6 wording is preferable.

BWR/4 and BWR/6 wording both appear to be sufficient, but the BWR/6 wording is preferable.

• Completion Time associated with Required Action H.2 The BWR/4 RA H.2 Completion Time associated with 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> states in part:

from discovery of a loss of ADS initiation capability in one trip system concurrent with The BWR/6 RA H.2 Completion Time associated with 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> states in part:

from discovery of inoperable channel concurrent with Is there a rationale for the difference? If not, when responding to the RAIs, kindly make them read the same, where appropriate. BWR/4 wording appears to be sufficient and is preferable. (BWR/6 does not appear to reflect R1 changes)

Note, any change to STS markups should be reflected in descriptions provided in Bases and Traveler Sections 2.4 and 3.

TSTF Response Required Action H.1, Note 2, is revised to state "when both ADS Trip Systems are inoperable" in both the BWR/4 and BWR/6 STS. Required Action H.2, Note 2, is revised to state, "when one ADS trip system is inoperable" in both the BWR/4 and BWR/6 STS. The BWR/4 and BWR/6 STS Required Action H.2 Completion Time is revised to refer to the "discovery of inoperable channels."

TSTF Response to NRC Questions on TSTF-592, Revision 0, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements" Page A-6 TS 3.3.5.1, Condition A, states, "One or more channels inoperable," and Required Action A.1 states, "Enter the Condition referenced in Table 3.3.5.1-1 for the channel." This Condition and Required Action direct entering Condition H. Therefore, it is more internally consistent to refer to the ADS trip systems and channels as inoperable instead of referring to the loss of initiation capability.

Enclosure TSTF-592, Revision 2, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements"

TSTF-592, Rev. 2 BWROG-147, Rev. 0 NUREGs Affected:

Revise Automatic Depressurization System (ADS) Instrumentation Requirements Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler 1430 1431 1432 1433 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement:

Improvement NRC Fee Status:

Not Exempt Benefit:

Avoids a Plant Shutdown Changes Marked on ISTS Rev 5.0 2194 PWROG RISD & PA (if applicable): None See attached.

Revision History OG Revision 0 Revision Status: Closed Original Issue Revision

Description:

Revision Proposed by:

BWROG Owners Group Review Information Date Originated by OG:

10-Mar-22 Owners Group Comments Original draft distributed on 1/20/2022. BWROG comments resulted in significant revision to the traveler.

Redistributed for BWROG review.

Date: 28-Mar-22 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

28-Jun-22 Date Distributed for Review 28-Jun-22 TSTF Comments:

(No Comments)

Date: 19-Jul-22 TSTF Resolution:

Approved NRC Review Information NRC Received Date:

19-Jul-22 NRC had only editorial comments on the draft. At the presubmittal meeting, NRC requested that submitted traveler discuss the origin of the current Actions and that information was incorporated.

The NRC provided draft comments on December 12, 2022.

NRC Comments:

13-Sep-23 Copyright(C) 2023, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-592, Rev. 2 BWROG-147, Rev. 0 TSTF Revision 1 Revision Status: Closed Revised to address NRC RAI.

1) Corrected additional Condition H references in the Bases to renumbered Condition I.

2) Revised the NUREG-1434 Condition H Bases to be consistent with the NUREG-1433 Condition H Bases.

3) Added example ADS logic diagrams as an attachment to the traveler.

4) Reassigned the bypass timer functions (NUREG-1433 Functions 4.g and 5.g, NUREG-1434 Functions 4.g and 5.f) from Condition H to Condition G.

5) Made other recommended Bases improvements.

6) Revised the model application to require licensees to describe the ADS initiation logic if it differs from the design described in the STS.

Revised to address NRC comments on the draft traveler.

Revised NUREG-1433 3.3.5.1 Actions and NUREG-1434 3.8.1 Action to correctly present a modified "Time Zero" Completion Time with the option to apply a Risk Informed Completion Time.

Revision

Description:

Revision Proposed by:

BWROG Owners Group Review Information Date Originated by OG:

03-May-23 Owners Group Comments (No Comments)

Date: 18-May-23 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

19-May-23 Date Distributed for Review 19-May-23 TSTF Comments:

(No Comments)

Date: 26-Jun-23 TSTF Resolution:

Approved NRC Review Information NRC Received Date:

27-Jun-23 NRC provided comments on August 10, 2023.

Superceded by Revision NRC Comments:

Final Resolution:

TSTF Revision 2 Revision Status: Active Traveler revised to address NRC comments and questions in August 10, 2023 letter. Changes were editorial and administrative to increase consistency and correct errors.

Revision

Description:

Revision Proposed by:

TSTF 13-Sep-23 Copyright(C) 2023, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-592, Rev. 2 BWROG-147, Rev. 0 Affected Technical Specifications TSTF Revision 2 Revision Status: Active Owners Group Review Information Date Originated by OG:

30-Aug-23 Owners Group Comments (No Comments)

Date: 13-Sep-23 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

30-Aug-23 Date Distributed for Review 30-Aug-23 TSTF Comments:

(No Comments)

Date: 13-Sep-23 TSTF Resolution:

Approved NRC Review Information NRC Received Date:

13-Sep-23 LCO 3.3.5.1 Table 3.3.5.1-1 Change

Description:

ECCS Instrumentation Action 3.3.5.1.B Bases ECCS Instrumentation Action 3.3.5.1.C Bases ECCS Instrumentation Action 3.3.5.1.D Bases ECCS Instrumentation Action 3.3.5.1.E Bases ECCS Instrumentation Action 3.3.5.1.F Bases ECCS Instrumentation Action 3.3.5.1.G ECCS Instrumentation Action 3.3.5.1.G Bases ECCS Instrumentation Action 3.3.5.1.H New Action Change

Description:

ECCS Instrumentation Action 3.3.5.1.H Bases New Action Change

Description:

ECCS Instrumentation 13-Sep-23 Copyright(C) 2023, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-592, Rev. 2 BWROG-147, Rev. 0 Action 3.3.5.1.I Action H renamed Action I Change

Description:

ECCS Instrumentation Action 3.3.5.1.I Bases Action H renamed Action I Change

Description:

ECCS Instrumentation Action 3.3.5.1.F NUREG(s)- 1433 Only ECCS Instrumentation Bkgnd 3.3.5.1 Bases NUREG(s)- 1434 Only ECCS Instrumentation Action 3.8.1 NUREG(s)- 1434 Only AC Sources - Operating 13-Sep-23 Copyright(C) 2023, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-592, Rev. 2 Page 1

1.

SUMMARY

DESCRIPTION The proposed change revises the Technical Specification (TS) 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," Actions related to the Automatic Depressurization System (ADS) initiation instrumentation to correct several overly restrictive requirements, and to treat less significant channel inoperabilities consistently. The proposed change modifies NUREG-1433, "Standard Technical Specifications - General Electric BWR/4 Plants," and NUREG-1434, "Standard Technical Specifications, General Electric BWR/6 Plants" (the STS).1

2. DETAILED DESCRIPTION 2.1. System Descriptions The ECCS is designed to cool the reactor core following a loss of coolant accident (LOCA). The typical BWR ECCS has low-pressure and high-pressure subsystems. The low pressure ECCS subsystems are designed to mitigate a large break LOCA where reactor vessel pressure rapidly decreases to the point at which the low-pressure ECCS pumps can inject water. There are two redundant divisions for each of the low-pressure ECCS subsystems. For example, BWR/4 plants typically have two Low Pressure Coolant Injection (LPCI) subsystems and two Core Spray (CS) subsystems. BWR/6 plants typically have one Low Pressure Core Spray (LPCS) subsystem and three Low Pressure Coolant Injection subsystems.

There is a single high-pressure ECCS subsystem. For example, BWR/4 plants have High Pressure Coolant Injection (HPCI), and BWR/6 plants have High Pressure Core Spray (HPCS).

The high-pressure ECCS subsystem is designed to mitigate small break LOCAs during which reactor vessel pressure remains higher than the ability of the low-pressure ECCS pumps to inject water.

The ADS provides redundancy for the single high-pressure ECCS subsystem. In the event of a failure of the high-pressure ECCS subsystem, the ADS valves open to release reactor vessel pressure to the suppression pool, rapidly reducing the pressure to the point at which a low-pressure ECCS subsystem can inject water.

The ADS valves will not open unless at least one low-pressure ECCS pump is operating to provide a source of coolant once the reactor vessel has been depressurized. Any one of the six BWR/4 low pressure pumps or four BWR/6 low pressure pumps is sufficient to permit automatic depressurization. The ADS instrumentation monitors reactor vessel water level and drywell pressure to initiate ADS. These parameters may indicate a failure of the high-pressure ECCS subsystem if reactor vessel water level does not recover following ECCS initiation.

1 NUREG-1433 is based on the boiling water reactor (BWR)/4 plant design, but is also representative of the BWR/2, BWR/3, and, in some cases, BWR/5 designs. NUREG-1434 is based on the BWR/6 plant design, and is representative in some cases of the BWR/5 design.

TSTF-592, Rev. 2 Page 2 ADS timers provide sufficient time for a high-pressure ECCS subsystem to recover reactor vessel water level before opening the ADS valves. There are two ADS initiation timers, one in each of the two ADS trip systems.

There are two ADS trip systems, designated as ADS Trip Systems A and B, with one trip system associated with each division of the low-pressure ECCS subsystems. Either trip system can open all the ADS valves if drywell pressure and reactor vessel water level conditions are satisfied, the ADS initiation timer has completed, and one low-pressure ECCS pump associated with the trip system is operating as indicated by pump discharge pressure.

The NUREG-1433 and NUREG-1434 Bases describe the ECCS low pressure pump discharge pressure permissives input to the ADS logic for the reference plant designs. Two channels of pump discharge pressure monitoring instrumentation are associated with each low-pressure ECCS pump, and both of a pump's associated channels must actuate to satisfy the ADS trip system logic that indicates pump operation. The BWR/4 Core Spray Pump A and LPCI Pumps A and D, and the BWR/6 LPCS pump and LPCI Pump A channels input to the ADS Trip System A logic. The BWR/4 Core Spray Pump B and LPCI Pumps B and C, and the BWR/6 LPCI Pumps B and C channels input to the ADS Trip System B logic. Only a single low pressure ECCS pump with two operable channels is required for the associated ADS trip system to respond to design basis events. Generic logic diagrams for the BWR/4 and BWR/6 ADS low pressure permissive logic are provided in Attachments 1 and 2. Note - These logic diagrams do not necessarily fully represent the ADS logic of the STS reference plant.

One of the signals required for ADS initiation is Drywell Pressure - High. However, if an event requiring ADS initiation occurs outside the drywell (e.g., main steam line break outside containment), a Drywell Pressure - High signal may not be present. In the BWR/4 design, the Automatic Depressurization System Low Water Level Actuation Timer is used to bypass the Drywell Pressure - High Function after a certain time period has elapsed. In the BWR/6 design, the ADS Bypass Timer (High Drywell Pressure) Function is used for the same purpose. There are four of these timers, two in each of the two ADS trip systems. Neither function is assumed in any accident analysis.

There are also ADS manual initiation push buttons which are not credited in any accident analysis.

2.2. Current Technical Specifications Requirements BWR/4 (NUREG 1433), TS 3.3.5.1, "Emergency Core Cooling System (ECCS)

Instrumentation," Table 3.3.5.1-1 provides the requirements for ADS Trip Systems A and B.

The following functions reference Action G:

4. ADS Trip System A

c. ADS Initiation Timer

e. Core Spray Pump Discharge Pressure - High

f. Low Pressure Coolant Injection Pump Discharge Pressure - High

g. ADS Low Water Level Actuation Timer

h. Manual Initiation

TSTF-592, Rev. 2 Page 3

5. ADS Trip System B

c. ADS Initiation Timer

e. Core Spray Pump Discharge Pressure - High

f. Low Pressure Coolant Injection Pump Discharge Pressure - High

g. ADS Low Water Level Actuation Timer

h. Manual Initiation BWR/6 (NUREG 1434), TS 3.3.5.1, "Emergency Core Cooling System (ECCS)

Instrumentation," Table 3.3.5.1-1 provides the requirements for ADS Trip Systems A and B. The following functions reference Action G:

4. ADS Trip System A

c. ADS Initiation Timer

e. LPCS Pump Discharge Pressure - High

f. LPCI Pump A Discharge Pressure - High

g. ADS Bypass Timer (High Drywell Pressure)

h. Manual Initiation

5. ADS Trip System B

c. ADS Initiation Timer

e. LPCI Pumps B & C Discharge Pressure - High

f. ADS Bypass Timer (High Drywell Pressure)

g. Manual Initiation These functions are required to be operable in Mode 1, and in Modes 2 and 3 with reactor steam dome pressure greater than [150] psig.

Condition G states, "As required by Required Action A.1 and referenced in Table 3.3.5.1-1."

Required Action G.1 states, "Declare ADS valves inoperable," with a Completion Time of "1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems."

In the BWR/4 TS, a Note to Required Action G.1 states that the Required Action only applies to Functions 4.c, 4.e, 4.f, 4.g, 5.c, 5.e, 5.f, and 5.g.

In the BWR/6 TS, a Note to Required Action G.1 states that the Required Action only applies to Functions 4.c, 4.e, 4.f, 4.g, 5.c, 5.e, and 5.f.

Required Action G.2 states, "Restore Channel to OPERABLE status." The Completion Time is 8 days unless either BWR/4 HPCI / BWR/6 HPCS, or the Reactor Core Isolation Cooling (RCIC) system are concurrently inoperable, in which case the Completion Time is halved to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> (4 days). Both Completion Times provide the option to use a Risk Informed Completion Time if that program has been implemented.

TSTF-592, Rev. 2 Page 4 If the affected channel is not restored to operable status within the specified Completion Time, Required Action H.1 requires immediately declaring the associated supported features (i.e., all ADS valves) inoperable. TS 3.5.1, "ECCS - Operating," Condition H, which addresses inoperability of two or more ADS valves would apply. The NUREG-1433 Actions require the plant to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and to reduce reactor steam pressure to [150] psig within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The NUREG-1434 Actions require entry into Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2.3. Reason for the Proposed Change Condition G is currently referenced from NUREG-1433 Functions 4.c, 4.e, 4.f, 4.g, 4.h, 5.c, 5.e, 5.f, 5.g, and 5.h, and NUREG-1434 Functions 4.c, 4.e, 4.f, 4.g, 4.h, 5.c, 5.e, 5.f, and 5.g.

Inoperability of a single channel ultimately, if not restored after a maximum of 8 days, results in entry into Condition H, the immediate declaration of the ADS valves as inoperable, and a plant shutdown. These actions are not entirely consistent with the design. With respect to the ECCS pump discharge pressure permissives, each ADS trip system requires only two pressure channels associated with one low-pressure ECCS pump to be operable to perform the safety function and a single inoperable channel cannot render the ADS initiation capability inoperable. Required Action G.1 requires a declaration of ADS valve inoperability one hour from discovery of loss of ADS initiation capability in both systems. The Bases are inaccurate in what results in a loss of ADS initiation capability in both trip systems. Required Action G.2 applies when any of the low pressure ECCS Pump Discharge Pressure - High channels are inoperable in either ADS trip system. The Completion Time is based on discovery of loss of ADS initiation capability for one trip system. For each of these Required Actions, there is not a loss of ADS initiation capability if there are at least two ECCS Pump Discharge Pressure - High channels for one low pressure ECCS pump operable in either ADS Trip System.

Additionally, Required Action G.2 is overly restrictive when applied to BWR/4 Functions 4.h and 5.h (Manual Initiation), and BWR/6 Functions 4.h and 5.g (Manual Initiation). The Manual Initiation function is not assumed in any accident or transient analysis. Therefore, there is not a loss of credited ADS initiation capability with this function inoperable, and it is overly restrictive to declare the ADS valves inoperable when this function is inoperable.

2.4. Description of the Proposed Change The proposed change revises the TS 3.3.5.1 Action G and adds a new Action H.

NUREG-1433:

• Table 3.3.5.1-1 is revised to reference Action H instead of Action G for Functions 4.e, 4.f, 4.h, 5.e, 5.f, and 5.h.

• TS 3.3.5.1, Required Action G.1, is revised to delete the Note.

• TS 3.3.5.1 is revised to add a new Condition H.

The Condition states, "As required by Required Action A.1 and referenced in Table 3.3.5.1-1."

Required Action H.1states, "Declare ADS valves inoperable, and is modified by two Notes. The first Note limits the Required Action applicability to Functions 4.e, 4.f, 5.e, and 5.f. The second Note limits the Required Action applicability to when both ADS Trip Systems are inoperable due to Core Spray/LPCI Pump Discharge Pressure

TSTF-592, Rev. 2 Page 5

- High channels inoperable." The Completion Time is "1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems."

Required Action H.2 states, "Restore affected channels to Operable status. It is modified by two Notes. The first Note limits the Required Action applicability to Functions 4.e, 4.f, 5.e, and 5.f. The second Note limits the Required Action applicability to when one ADS Trip System is inoperable due to Core Spray/LPCI Pump Discharge Pressure - High channels inoperable. The Completion Time is 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from discovery of inoperable channels concurrent with HPCI or RCIC inoperable and 8 days from discovery of inoperable channels in one trip system.

The option of including a Risk Informed Completion Time (RICT) alternative is included. If the licensee currently has an NRC-approved RICT for the existing Required Action G.2, then a RICT may be retained for the revised Required Action G.2, and for the new Required Action H.2. For plants that have not been approved for a RICT for Required Action G.2, it is outside the scope of this traveler to add it.

Required Action H.3 states, "Restore channel to OPERABLE status," with a Completion Time of "30 days."

• Current Action H is renamed Action I, and is modified to include the revised Condition H.

NUREG-1434:

• Table 3.3.5.1-1 is revised to reference Action H instead of Action G for Functions 4.e, 4.f, 4.h, 5.e, and 5.g.

• TS 3.3.5.1, Required Action G.1, is revised to delete the Note.

• TS 3.3.5.1 is revised to add a new Condition H.

The Condition states, "As required by Required Action A.1 and referenced in Table 3.3.5.1-1."

Required Action H.1states, "Declare ADS valves inoperable, and is modified by two Notes. The first Note limits the Required Action applicability to Functions 4.e, 4.f, and 5.e. The second Note limits the Required Action applicability to when both ADS Trip Systems are inoperable due to LPCS/LPCI Pump Discharge Pressure -

High channels inoperable." The Completion Time is "1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems."

Required Action H.2 states, "Restore affected channels to OPERABLE status." It is triggered by two Notes. The first Note limits the Required Action applicability to Functions 4.e, 4.f, and 5.e. The second Note limits the Required Action applicability to when one ADS Trip System is inoperable due to LPCS/LPCI Pump Discharge Pressure - High channels inoperable. The Completion Time is 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from discovery of inoperable channels concurrent with HPCS or RCIC inoperable and 8 days from discovery of inoperable channels in one trip system. The option of including an RICT alternative is included. If the licensee currently has an NRC-approved RICT for the existing Required Action G.2, then a RICT may be retained for the revised Required Action G.2, and for the new Required Action H.2. For plants that have not been approved for a RICT for Required Action G.2, it is outside the scope of this traveler to add it.

Required Action H.3 states, "Restore channel to OPERABLE status," with a Completion Time of "30 days."

TSTF-592, Rev. 2 Page 6

• Current Action H is renamed Action I, and is modified to include the revised Condition H.

An inconsistency was discovered in the presentation of RICTs applicable to Completion Times that state from discovery. The existing NUREG-1433 and NUREG-1434 Completion Time presentations in TS 3.3.5.1 are different, and the NUREG-1434 Completion Time presentations in TS 3.3.5.1 and TS 3.8.1 are different. The Completion Times are revised to provide consistency and clarity, without changing the intent of the TS.

The TS Bases are revised to reflect these changes, and in particular to define when ADS trip system initiation capability is lost relative to the ECCS Pump Discharge Pressure - High functions. An additional Bases change is made to correct error in G.1 and G.2 Bases. The third paragraph describes allowing time for restoration or tripping of channels. Tripping channels is not an option for Condition G, so this is deleted from the Bases. The regulation at Title 10 of the Code of Federal Regulations (10 CFR), Part 50.36, states, "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 technical specifications." A licensee may make changes to the TS Bases without prior NRC review and approval in accordance with the Technical Specifications Bases Control Program. The proposed TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 22, 1993 (58 FR 39132).

Therefore, the Bases changes are provided for information and approval of the Bases is not requested.

A model application is attached. The model may be used by licensees desiring to adopt the traveler following NRC approval.

3. TECHNICAL EVALUATION The ADS provides redundancy for the single high-pressure ECCS subsystem. In the event of failure of the high-pressure ECCS subsystem, the ADS valves open to rapidly reduce the reactor vessel pressure to the point at which a low-pressure ECCS pump can inject water. One low-pressure ECCS subsystem is needed as a source of coolant once ADS has depressurized the reactor vessel.

There are two ADS trip systems, designated as ADS Trip Systems A and B. A single ADS trip system can initiate opening of the ADS valves constituting "ADS initiation capability." Thus, "ADS initiation capability" is only lost when both trip systems are unable to initiate opening of the ADS valves. Either trip system can open the ADS relief valves if drywell pressure and reactor vessel water level conditions are satisfied, the ADS initiation timers have completed, and one low-pressure ECCS pump is operating as indicated by pump discharge pressure. Indication that one low-pressure ECCS pump is operating is achieved by two operable channels of pump discharge pressure. Both channels must indicate the necessary discharge pressure for the pump to be recognized as operating. Therefore, ADS initiation capability is only lost if one or more pump discharge pressure sensors are inoperable in all low-pressure ECCS pumps in both ADS trip systems.

TSTF-592, Rev. 2 Page 7 There are a few BWR/4 plants with an ADS initiation design that varies from the design assumed in the STS. For example, at some plants the two pressure switches for each of the two Core Spray pumps and the four LPCI pumps provide an input to both ADS Trip Systems. This results in Functions 4.e and 5.e requiring four channels per Function rather than two, and Functions 4.f and 5.f requiring eight channels per Function rather than four. Another variation is for plants with two 50% capacity Core Spray pumps in each Core Spray loop with one pressure switch per Core Spray pump that provides input into both ADS Trip Systems. This also results in Functions 4.e and 5.e requiring four channels per Function rather than two. However, these variations have no effect on the applicability of the traveler since new Condition H is written broadly enough to accommodate plant-specific design differences. Required Action H.1 will be applicable to ADS low pressure channel inoperabilities that are sufficient to result in inoperability of both ADS trip systems. Required Action H.2 will be applicable to ADS low pressure channel inoperabilities that are sufficient to result in inoperability of only one ADS trip system. No changes to the TS markups are needed for these design differences. Any necessary Bases changes will be incorporated by the licensee. A review of the fleet BWR/5 and BWR/6 TS did not reveal any variations from STS.

The BWR standard TS do not reflect the diversity and redundancy of the ADS initiation logic.

NUREG-0123, "Standard Technical Specifications for General Electric Boiling Water Reactors,"

draft Revision 4 (which was the basis for development of the modern BWR standard TS),

utilized the same Actions for inoperable ADS, Core Spray System, and Low Pressure Coolant Injection instrumentation channels. NEDC-31681, "Improved BWR Technical Specifications,"

April 1989, provided the proposed BWROG improved TS. The topical report provided 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to place any inoperable ADS instrumentation channel in trip or to ensure each channel per function in one ADS trip system was operable or tripped. The Bases stated that one ADS trip system is capable of initiating ADS, implying that all channels supporting one trip system must be operable. This does not reflect the ADS initiation design. The issued standard TS (NUREG-1433 and NUREG-1434) Actions have not changed between Revision 0 and Revision 5, other than the addition of Risk Informed Completion Times.

Table 3.3.5.1-1 is revised such that Action G is only referenced from Functions 4.c, 4g, 5.c and 5.g (ADS Initiation Timer and ADS Low Water Level Actuation Timer) for NUREG-1433, and Functions 4.c, 4.g, 5.c, and 5.f (ADS Initiation Timer and ADS Bypass Timer [High Drywell pressure]) for NUREG-1434. If these Functions are inoperable, the ADS automatic initiation function is unavailable. Therefore, the ADS valves must be declared inoperable if both ADS initiation timers and ADS low water level actuation timers/ADS high drywell pressure bypass timers are inoperable. If only one ADS initiation timer or one ADS low water level actuation timer/ADS high drywell pressure bypass timer is inoperable, the existing Required Action and Completion Time for restoring the inoperable Function is unchanged. With the changes to Table 3.3.5.1-1, the existing Required Action G.1 Note is no longer needed, and the Note is deleted.

The bypass timer functions are not credited in the accident analysis. With a timer function inoperable, manual ADS initiation would still be possible. However, because the manual initiation functions are assigned to Condition H, it would be possible for both the bypass timer functions and the manual initiation functions to be inoperable if the bypass timer functions were

TSTF-592, Rev. 2 Page 8 also assigned to Condition H, resulting in an inability to initiate ADS. Therefore, the bypass timer functions remain assigned to Condition G.

NUREG-1433 Table 3.3.5.1-1 is revised to reference Condition H from Functions:

4.

ADS Trip System A

e.

Core Spray Pump Discharge Pressure - High

f.

Low Pressure Coolant Injection Pump Discharge Pressure - High

h.

Manual Initiation

5.

ADS Trip System B

e.

Core Spray Pump Discharge Pressure - High

f.

Low Pressure Coolant Injection Pump Discharge Pressure - High

h.

Manual Initiation NUREG-1434 Table 3.3.5.1-1 is revised to reference Condition H from Functions:

4.

ADS Trip System A

e.

LPCS Pump Discharge Pressure - High

f.

LPCI Pump A Discharge Pressure - High

h.

Manual Initiation

5.

ADS Trip System B

e.

LPCI Pumps B & C Discharge Pressure - High

g.

Manual Initiation Required Action H.1 is applicable to NUREG-1433 Functions 4.e, 4.f, 5.e, and 5.f, and NUREG-1434 Functions 4.e, 4.f, and 5.e, which are the low pressure ECCS pump high discharge pressure signals. These signals indicate that the associated low pressure pump is operating. Any one low pressure pump with two operable pump high discharge pressure signals can initiate ADS. Accordingly, Required Action H.1 states, Declare ADS valves inoperable. Required Action H.1 is modified by a Note. In the BWR/4 STS, the Note states, Only applicable when both ADS trip systems are inoperable due to Core Spray/LPCI Pump Discharge Pressure - High channels inoperable. In the BWR/6 STS, the Note states, "Only applicable when both ADS trip systems are inoperable due to LPCS/LPCI Pump Discharge Pressure - High channels inoperable." The Completion Time is "1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems." Therefore, if there are no low pressure ECCS pumps with two operable Pump Discharge Pressure - High channels, an ADS initiation signal cannot be provided from Trip System A or B and the ADS valves must be declared inoperable.

Required Action H.2 is also applicable to NUREG-1433 Functions 4.e, 4.f, 5.e, and 5.f, and NUREG-1434 Functions 4.e, 4.f, and 5.e, the low pressure pump high discharge pressure signals.

Required Action H.2 is applicable since the loss of ADS initiation capability is limited to a single trip system and requires restoring all inoperable low pressure ECCS Pump Discharge Pressure -

High channels to operable status within 8 days if HPCI or RCIC is operable, or 4 days if they are not operable. Both Completion Times have the option to apply a Risk Informed Completion Time if approved for the plant. These Completion Times are the same as current Required Action G.2.

TSTF-592, Rev. 2 Page 9 Required Action H.3 is applicable to all Functions that reference Condition H, and is the only Required Action applicable to NUREG-1433 Functions 4.h and 5.h, "Manual Initiation," and to NUREG-1434 Functions 4.h and 5.g, "Manual Initiation." This function is not credited in any accident analysis, and so a 30-day Completion Time is justified. Additionally, the 30-day Completion Time of Required Action H.3 is acceptable, based on operating experience, considering the multiple channels available for meeting the low pressure ECCS pump discharge pressure permissive, and the availability of automatic ADS initiation.

Renumbering the default Condition H as Condition I is an administrative change to reflect the addition of new Condition H, as is the inclusion of new Condition H in the scope of Condition I.

The Bases to RAs B, C, D, E, F, G, and H reference new Condition I.

With the proposed changes, the Actions are such that Functions applicable to Required Action G.2 are now applicable to Required Actions G.2 and H.2. If the licensee currently has an NRC-approved RICT for the existing Required Action G.2, then a RICT may be retained for the revised Required Action G.2, and for the new Required Action H.2. For plants that have not been approved for a RICT for Required Action G.2, it is outside the scope of this traveler to add it. A RICT is not applicable to new Required Action H.3 because it has a 30-day Completion Time.

Correction of Inconsistency Regarding the Presentation of Risk Informed Completion Times Existing NUREG-1433, TS 3.3.5.1, Required Action F.2, has multiple Completion Times:

96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from discovery of inoperable channel concurrent with HPCI or reactor core isolation cooling (RCIC) inoperable

[OR In accordance with the Risk Informed Completion Time Program]

AND 8 days

[OR In accordance with the Risk Informed Completion Time Program]

However, in NUREG-1434, the Required Action F.2 Completion Time states:

96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channel concurrent with HPCS or reactor core isolation cooling (RCIC) inoperable AND

TSTF-592, Rev. 2 Page 10 8 days

[OR In accordance with the Risk Informed Completion Time Program]

The only instances in the BWR and PWR STS of a modified "time zero" Completion Time with the option to apply a RICT are in NUREG-1433 and NUREG-1434 TS 3.3.5.1, Required Actions F.2 and G.2, and NUREG-1434, TS 3.8.1, Required Action A.3. These presentations are inconsistent. This inconsistency was introduced in TSTF-505, "Provide Risk-Informed Extended Completion Times," which was incorporated into Revision 5 of the STS.

Section 1.3 of the STS describes modified "time zero" Completion Times:

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery..."

Based on this discussion, the appropriate presentation for a Completion Time with a modified "time zero" and a RICT option is as used in the NUREG-1434 TS 3.3.5.1, Required Action F.2, "96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channel concurrent with HPCS or reactor core isolation cooling (RCIC) inoperable." This presentation makes clear that the RICT begins "from discovery" and not when the Actions Condition is entered. Stating the RICT option as a separate Completion Time from the modified "time zero" would require the RICT to begin on entry into the Actions Condition, which is not the intent. As stated in the Required Action F.1 and F.2 Bases, "If

TSTF-592, Rev. 2 Page 11 either HPCS or RCIC is inoperable, the time is shortened to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If the status of HPCS or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> begins upon discovery of HPCS or RCIC inoperability."

For consistency and clarity, the NUREG-1433, TS 3.3.5.1, Required Action F.2 and G.2 Completion Times, and the NUREG-1434, TS 3.8.1, Required Action A.3 Completion Time are revised to include the RICT option in the modified "time zero" Completion Time.

4.

REGULATORY EVALUATION The regulation at Title 10 of the CFR Section 50.36(b) requires:

Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 ["Contents of applications; technical information"]. The Commission may include such additional technical specifications as the Commission finds appropriate.

Per 10 CFR 50.90, whenever a holder of a 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.

Per 10 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.

Section IV, "The Commission Policy," of the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58 FR 39132), dated July 22, 1993, states in part that improved STS have been developed and will be maintained for each NSSS owners group. The Commission Policy encourages licensees to use the improved STS as the basis for plant-specific Technical Specifications." The industry's proposal of travelers and the NRC's approval of travelers is the method used to maintain the improved STS as described in the Commission's Policy. Following NRC approval, licensees adopt travelers into their plant-specific technical specifications following the requirements of 10 CFR 50.90. Therefore, the traveler process facilitates the Commission's policy while satisfying the requirements of the applicable regulations.

The regulation at 10 CFR 50.36(a)(1) also requires the application to include a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3)

TSTF-592, Rev. 2 Page 12 the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

5. REFERENCES None

TSTF-592, Rev. 2 Page 13 Typical BWR/4 ADS Logic Diagram

Reference:

General Electric BWR/4 Systems Technology Manual, Chapter 10.2, "Automatic Depressurization System," (NRC Agencywide Documents Access and Management System (ADAMS) Accession No. ML11258A366)

TSTF-592, Rev. 2 Page 14 The ADS logic has two divisions. Figure 10.2-4 shows ADS Division I. ADS Division II is similar. Either of the ADS divisions can initiate ADS. Each ADS division has two subchannels.

ADS Division I includes Subchannels A & C and ADS Division II includes Subchannels B & D.

When all of the following conditions are met, the ADS logic circuits will energize the ADS solenoid pilot valves to open the ADS Safety/Relief Valves:

Reactor Water Level 1, Reactor Water Level 3 (Confirmation of low level condition),

Discharge pressure sensed at one LPCI pump or at one CS pump, and 105 second time delay as determined by an ADS timer.

The pump discharge condition is required to ensure that there is low pressure injection available before depressurization. The ADS channels will not initiate depressurization until there is indication that at least one CS or one LPCI pump is running.

Note: The logic diagram does not necessarily fully represent the ADS logic of the STS reference plant.

TSTF-592, Rev. 2 Page 15 Example BWR/6 ADS Logic Diagram

TSTF-592, Rev. 2 Page 16

Reference:

General Electric BWR/6 Systems Technology Manual, Chapter 63, "Automatic Depressurization System"

TSTF-592, Rev. 2 Page 17 Figures 2 and 3 depict ADS logic channel A and logic channel B, respectively. The automatic depressurization signal can be generated by either ADS logic channel. Logic channel A is divided into Subchannels A and E. Logic channel B is divided into Subchannels B and F. All the logic requirements of both subchannels must be satisfied for the corresponding logic channel to generate an initiation signal.

Confirmation of at least one low pressure ECCS pump in operation is necessary to complete the ADS logic initiation signal. An ECCS pump operating signal is generated by two pairs of pressure transmitters from two of the low pressure ECCS pumps. Subchannel A of the ADS logic receives inputs from the LPCS pump and RHR pump A, while Subchannel B receives inputs from RHR pumps B and C. One pair of pressure instruments inputs signals (one from each pump monitored by a particular channel) to each logic subchannel, and a signal from either pumps pressure transmitter is sufficient for a permissive signal from that subchannel.

Note: The logic diagram does not necessarily fully represent the ADS logic of the STS reference plant.

TSTF-592, Rev. 2 Model Application

TSTF-592, Rev. 2 Page 1

[DATE]

10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 DOCKET NO. PLANT NAME 50-[xxx]

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-592, "Revise Automatic Depressurization System (ADS)

Instrumentation Requirements" Pursuant to 10 CFR 50.90, [LICENSEE] is submitting a request for an amendment to the Technical Specifications (TS) for [PLANT NAME, UNIT NOS.].

[LICENSEE] requests adoption of TSTF-592, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements." The Technical Specifications (TS) 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," Actions are revised to reflect the plant design and the safety significance of inoperable ADS monitoring channels.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. Attachment 2 provides revised (clean) TS pages. Attachment 3 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

((LICENSEE] requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP).] Approval of the proposed amendment is requested within 6 months of acceptance. Once approved, the amendment shall be implemented within [ ] days.

There are no regulatory commitments made in this submittal.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated [STATE] Official.

[In accordance with 10 CFR 50.30(b), a license amendment request must be executed in a signed original under oath or affirmation. This can be accomplished by attaching a notarized affidavit confirming the signature authority of the signatory, or by including the following statement in the cover letter: "I declare under penalty of perjury that the foregoing is true and correct.

Executed on (date)." The alternative statement is pursuant to 28 USC 1746. It does not require notarization.]

TSTF-592, Rev. 2 Page 2 If you should have any questions regarding this submittal, please contact [NAME, TELEPHONE NUMBER].

Sincerely,

[Name, Title]

Enclosure:

Description and Assessment Attachments: 1.

Proposed Technical Specification Changes (Mark-Up)

2.

Revised Technical Specification Pages

3.

Proposed Technical Specification Bases Changes (Mark-Up) - For Information Only

[The attachments are to be provided by the licensee and are not included in the model application.]

cc:

NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact

TSTF-592, Rev. 2 Page 3 ENCLOSURE DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

[LICENSEE] requests adoption of TSTF-592, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements." The Technical Specifications (TS) 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," Actions are revised to reflect the plant design and the safety significance of inoperable ADS monitoring channels.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation

[LICENSEE] has reviewed the safety evaluation for TSTF-592 provided to the Technical Specifications Task Force in a letter dated [DATE]. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-592. [LICENSEE] has concluded that the justifications presented in TSTF-592 and the safety evaluation prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this amendment for the incorporation of the changes to the [PLANT] TS.

[Discuss differences, if any, between the plant design and the plant design assumed in the Standard Technical Specifications that are related to the proposed change and why those differences do not affect the applicability of the TSTF-592 safety evaluation to the plant.]

2.2 Optional Changes and Variations

[LICENSEE is not proposing any variations from the TS changes described in TSTF-592 or the applicable parts of the NRC staffs safety evaluation dated [DATE].] [LICENSEE is proposing the following variations from the TS changes described in TSTF-592 or the applicable parts of the NRC staffs safety evaluation: describe the variations]

[The [PLANT] TS utilize different [numbering][and][titles] than the Standard Technical Specifications on which TSTF-592 was based. Specifically, [describe differences between the plant-specific TS numbering and/or titles and the TSTF-592 numbering and titles.] These differences are administrative and do not affect the applicability of TSTF-592 to the [PLANT]

TS.]

[The [PLANT] TS contain requirements that differ from the Standard Technical Specifications on which TSTF-592 was based but are encompassed in the TSTF-592 justification. Describe differences and why TSTF-592 is still applicable.]

[The [PLANT] ADS initiation logic design differs from the design described in the BWR/4 STS.

[Describe the design differences.] This has no effect on the traveler technical justification. No changes to the proposed TS markups are required. The [PLANT] design is reflected in the proposed TS Bases. Therefore, this difference does not affect the applicability of the traveler to

[PLANT].]

TSTF-592, Rev. 2 Page 4

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis

[LICENSEE] requests adoption of TSTF-592, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements." The Technical Specifications (TS) 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," Actions are revised to reflect the plant design and the safety significance of inoperable ADS monitoring channels.

[LICENSEE] has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Response: No The proposed change revises the TS Actions applicable when one or more ADS monitoring channels are inoperable to be consistent with the plant design and the safety significance of the condition. The actions taken when an ADS monitoring channel is inoperable are not an initiator of any accident previously evaluated. The proposed actions implement the appropriate actions to be taken if automatic initiation of ADS is not available (i.e., declaring the ADS valves inoperable), which ensures the equipment assumed to be available to mitigate the consequences of accidents previously evaluated is available or the plant is placed in a safe condition.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

Response: No The proposed change revises the TS Actions applicable when one or more ADS monitoring channels are inoperable to be consistent with the plant design and the safety significance of the condition. The proposed change does not affect the design function or operation of the ADS or the ADS initiation instrumentation. The proposed change does not create a new or different type of failure for the ADS or the ADS initiation instrumentation due to credible new failure mechanisms, malfunctions, or accident initiators not currently considered in the design and licensing bases.

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

TSTF-592, Rev. 2 Page 5

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change revises the TS Actions applicable when one or more ADS monitoring channels are inoperable to be consistent with the plant design and the safety significance of the condition. The proposed change does not affect any controlling values of parameters established in the design or licensing basis, and does not alter any design basis or safety limit.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL EVALUATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

TSTF-592, Rev. 2 Technical Specifications and Bases Changes

ECCS Instrumentation 3.3.5.1 General Electric BWR/4 STS 3.3.5.1-5 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.2 Place channel in trip.

96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channel concurrent with HPCI or reactor core isolation cooling (RCIC) inoperable

[OR In accordance with the Risk Informed Completion Time Program]

AND 8 days

[OR In accordance with the Risk Informed Completion Time Program]

G. As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

G.1

---

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

Only applicable for Functions 4.c, 4.e, 4.f, 4.g, 5.c, 5.e, 5.f, and 5.g.

Declare ADS valves inoperable.

AND 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems TSTF-592, Rev. 2

ECCS Instrumentation 3.3.5.1 General Electric BWR/4 STS 3.3.5.1-6 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G.2 Restore channel to OPERABLE status.

96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channel concurrent with HPCI or RCIC inoperable

[OR In accordance with the Risk Informed Completion Time Program]

AND 8 days

[OR In accordance with the Risk Informed Completion Time Program]

H. As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

H.1

---

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

1 Only applicable for Functions 4.e, 4.f, 5.e, and 5.f.

2. Only applicable when both ADS trip systems are inoperable due to Core Spray/LPCI Pump Discharge Pressure -

High channels inoperable.

Declare ADS valves inoperable.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation TSTF-592, Rev. 2

ECCS Instrumentation 3.3.5.1 General Electric BWR/4 STS 3.3.5.1-7 Rev. 5.0 AND H.2

---

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

1. Only applicable for Functions 4.e, 4.f, 5.e, and 5.f.

2. Only applicable when one ADS trip system is inoperable due to Core Spray/LPCI Pump Discharge Pressure -

High channels inoperable.

Restore affected channels to OPERABLE status.

AND H.3 Restore channel to OPERABLE status.

capability in both trip systems 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channels concurrent with HPCI or RCIC inoperable AND 8 days [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channels in one trip system 30 days TSTF-592, Rev. 2

ECCS Instrumentation 3.3.5.1 General Electric BWR/4 STS 3.3.5.1-8 Rev. 5.0 IH. Required Action and associated Completion Time of Condition B, C, D, E, F, G, or GH not met.

IH.1 Declare associated supported feature(s) inoperable.

Immediately TSTF-592, Rev. 2

ECCS Instrumentation 3.3.5.1 General Electric BWR/4 STS 3.3.5.1-17 Rev. 5.0 Table 3.3.5.1-1 (page 6 of 8)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

4. ADS Trip System A

c.

Automatic Depressurization System Initiation Timer 1, 2(e), 3(e)

[1]

G

[SR 3.3.5.1.5]

SR 3.3.5.1.6

[120] seconds

d.

Reactor Vessel Water Level - Low, Level 3 (Confirmatory) 1, 2(e), 3(e)

[1]

F SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6

[10] inches

e.

Core Spray Pump Discharge Pressure

- High 1, 2(e), 3(e)

[2]

HG SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3]

SR 3.3.5.1.5 SR 3.3.5.1.6

[137] psig and

[ ] psig

f.

Low Pressure Coolant Injection Pump Discharge Pressure - High 1, 2(e), 3(e)

[4]

HG SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3]

SR 3.3.5.1.5 SR 3.3.5.1.6

[112] psig and

[ ] psig

g.

Automatic Depressurization System Low Water Level Actuation Timer 1, 2(e), 3(e)

[2]

G

[SR 3.3.5.1.5]

SR 3.3.5.1.6

[13] minutes

[ h. Manual Initiation 1, 2(e), 3(e)

[2]

HG SR 3.3.5.1.6 N/A ]

(b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (Nominal Trip Setpoint) to confirm channel performance. The LTSP and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].

(e)

With reactor steam dome pressure > [150] psig.

TSTF-592, Rev. 2

ECCS Instrumentation 3.3.5.1 General Electric BWR/4 STS 3.3.5.1-18 Rev. 5.0 Table 3.3.5.1-1 (page 7 of 8)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

5. ADS Trip System B

a.

Reactor Vessel Water Level - Low Low Low, Level 1 1, 2(e), 3(e)

[2]

F SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6

[-113] inches

b.

Drywell Pressure -

High 1, 2(e), 3(e)

[2]

F SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6

[1.92] psig

c.

Automatic Depressurization System Initiation Timer 1, 2(e), 3(e)

[1]

G

[SR 3.3.5.1.5]

SR 3.3.5.1.6

[120] seconds

d.

Reactor Vessel Water Level - Low, Level 3 (Confirmatory) 1, 2(e), 3(e)

[1]

F SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6

[10] inches

e.

Core Spray Pump Discharge Pressure

- High 1, 2(e), 3(e)

[2]

HG SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3]

SR 3.3.5.1.5 SR 3.3.5.1.6

[137] psig and

[ ] psig (b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (Nominal Trip Setpoint) to confirm channel performance. The LTSP and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].

(e)

With reactor steam dome pressure > [150] psig.

TSTF-592, Rev. 2

ECCS Instrumentation 3.3.5.1 General Electric BWR/4 STS 3.3.5.1-19 Rev. 5.0 Table 3.3.5.1-1 (page 8 of 8)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

5. ADS Trip System B

f.

Low Pressure Coolant Injection Pump Discharge Pressure - High 1, 2(e), 3(e)

[4]

HG SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3]

SR 3.3.5.1.5 SR 3.3.5.1.6

[112] psig and [ ] psig

g.

Automatic Depressurization System Low Water Level Actuation Timer 1, 2(e), 3(e)

[2]

G

[SR 3.3.5.1.5]

SR 3.3.5.1.6

[13] minutes

[ h. Manual Initiation 1, 2(e), 3(e)

[2]

HG SR 3.3.5.1.6 NA ]

(e)

With reactor steam dome pressure > [150] psig.

TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/4 STS B 3.3.5.1-25 Rev. 5.0 BASES ACTIONS (continued)

Notes are also provided (the Note to Required Action B.1 and the Note to Required Action B.2) to delineate which Required Action is applicable for each Function that requires entry into Condition B if an associated channel is inoperable. This ensures that the proper loss of initiation capability check is performed. Required Action B.1 (the Required Action for certain inoperable channels in the low pressure ECCS subsystems) is not applicable to Function 2.e, since this Function provides backup to administrative controls ensuring that operators do not divert LPCI flow from injecting into the core when needed. Thus, a total loss of Function 2.e capability for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed, since the LPCI subsystems remain capable of performing their intended function.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action B.1, the Completion Time only begins upon discovery that a redundant feature in the same system (e.g., both CS subsystems) cannot be automatically initiated due to inoperable, untripped channels within the same Function as described in the paragraph above. For Required Action B.2, the Completion Time only begins upon discovery that the HPCI System cannot be automatically initiated due to two inoperable, untripped channels for the associated Function in the same trip system. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been shown to be acceptable (Ref. 6) to permit restoration of any inoperable channel to OPERABLE status.

[Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action B.3. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue.

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

TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/4 STS B 3.3.5.1-27 Rev. 5.0 BASES ACTIONS (continued)

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action C.1, the Completion Time only begins upon discovery that the same feature in both subsystems (e.g., both CS subsystems) cannot be automatically initiated due to inoperable channels within the same Function as described in the paragraph above. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been shown to be acceptable (Ref. 6) to permit restoration of any inoperable channel to OPERABLE status.

[Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition IH must be entered and its Required Action taken.

The Required Actions do not allow placing the channel in trip since this action would either cause the initiation or it would not necessarily result in a safe state for the channel in all events.

D.1, D.2.1, and D.2.2 Required Action D.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same Function result in a complete loss of automatic component initiation capability for the HPCI System. Automatic component initiation capability is lost if two Function 3.d channels or two Function 3.e channels are inoperable and untripped. In this situation (loss of automatic suction swap), the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance of Required Actions D.2.1 and D.2.2 is not appropriate and the HPCI System must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of HPCI initiation capability. As noted, Required Action D.1 is only applicable if the HPCI pump suction is not aligned to the suppression pool, since, if aligned, the Function is already performed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action D.1, the Completion Time only begins upon discovery that the HPCI System cannot be automatically aligned to the suppression pool due to two inoperable, TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/4 STS B 3.3.5.1-28 Rev. 5.0 BASES ACTIONS (continued) untripped channels in the same Function. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been shown to be acceptable (Ref. 6) to permit restoration of any inoperable channel to OPERABLE status.

[Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action D.2.1 or the suction source must be aligned to the suppression pool within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per Required Action D.2.2. Placing the inoperable channel in trip performs the intended function of the channel (shifting the suction source to the suppression pool). Performance of either of these two Required Actions will allow operation to continue. If Required Action D.2.1 or D.2.2 is performed, measures should be taken to ensure that the HPCI System piping remains filled with water.

Alternately, if it is not desired to perform Required Actions D.2.1 and D.2.2 (e.g., as in the case where shifting the suction source could drain down the HPCI suction piping), Condition IH must be entered and its Required Action taken.

E.1 and E.2 Required Action E.1 is intended to ensure that appropriate actions are taken if multiple, inoperable channels within the Core Spray and Low Pressure Coolant Injection Pump Discharge Flow - Low Bypass Functions result in redundant automatic initiation capability being lost for the feature(s). For Required Action E.1, the features would be those that are initiated by Functions 1.d and 2.g (e.g., low pressure ECCS). Redundant automatic initiation capability is lost if (a) two Function 1.d channels are inoperable or (b) one or more Function 2.g channels associated with pumps in LPCI subsystem A and one or more Function 2.g channels associated with pumps in LPCI subsystem B are inoperable. Since each inoperable channel would have Required Action E.1 applied separately (refer to ACTIONS Note), each inoperable channel would only require the affected low pressure ECCS pump to be declared inoperable. However, since channels for more than one low pressure ECCS pump are inoperable, and the Completion Times started concurrently for the channels of the low pressure ECCS pumps, this results in the affected low pressure ECCS pumps being concurrently declared inoperable.

TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/4 STS B 3.3.5.1-30 Rev. 5.0 BASES ACTIONS (continued) in the ECCS design, and the low probability of a DBA occurring during the allowed out of service time. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition IH must be entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events.

F.1 and F.2 Required Action F.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within similar ADS trip system A and B Functions result in redundant automatic initiation capability being lost for the ADS. Redundant automatic initiation capability is lost if either (a) one Function 4.a channel and one Function 5.a channel are inoperable and untripped, (b) one Function 4.b channel and one Function 5.b channel are inoperable and untripped, or (c) one Function 4.d channel and one Function 5.d channel are inoperable and untripped.

In this situation (loss of automatic initiation capability), the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 day allowance, as applicable, of Required Action F.2 is not appropriate and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of ADS initiation capability.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action F.1, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable, untripped channels within similar ADS trip system Functions as described in the paragraph above. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 8 days has been shown to be acceptable (Ref. 6) to permit restoration of any inoperable channel to OPERABLE status if both HPCI and RCIC are OPERABLE. [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If either HPCI or RCIC is inoperable, the time is shortened to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. If the status of HPCI or RCIC changes such that the Completion Time changes TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/4 STS B 3.3.5.1-31 Rev. 5.0 BASES ACTIONS (continued) from 8 days to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program], the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> begins upon discovery of HPCI or RCIC inoperability. However, the total time for an inoperable, untripped channel cannot exceed 8 days. If the status of HPCI or RCIC changes such that the Completion Time changes from 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable, untripped channel. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action F.2. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue.

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

G.1 and G.2 Required Action G.1 is intended to ensure that appropriate actions are taken if multiple, inoperable channels within similar ADS trip system Functions result in automatic initiation capability being lost for the ADS.

Automatic initiation capability is lost if either (a) one Function 4.c channel and one Function 5.c channel are inoperable, (b) a combination of Function 4.e, 4.f, 5.e, and 5.f channels are inoperable such that channels associated with five or more low pressure ECCS pumps are inoperable, or (bc) one or more Function 4.g channels and one or more Function 5.g channels are inoperable.

In this situation (loss of automatic initiation capability), the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 day allowance, as applicable, of Required Action G.2 is not appropriate, and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of ADS initiation capability in both trip systems. The Note to Required Action G.1 states that Required Action G.1 is only applicable for Functions 4.c, 4.e, 4.f, 4.g, 5.c, 5.e, 5.f, and 5.g. Required Action G.1 is not applicable to Functions 4.h and 5.h (which also require entry into this Condition if a channel in these Functions is inoperable),

since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of manual initiation capability for 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 days (as allowed by Required Action G.2) is allowed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action G.1, the Completion TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/4 STS B 3.3.5.1-32 Rev. 5.0 Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable channels within similar ADS trip system Functions as described in the paragraph above. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 8 days has been shown to be acceptable (Ref. 6) to permit restoration of any inoperable channel to OPERABLE status if both HPCI and RCIC are OPERABLE (Required Action G.2). [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If either HPCI or RCIC is inoperable, the time shortens to BASES ACTIONS (continued) 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program]. If the status of HPCI or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> begins upon discovery of HPCI or RCIC inoperability. However, the total time for an inoperable channel cannot exceed 8 days. If the status of HPCI or RCIC changes such that the Completion Time changes from 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable channel. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition IH must be entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events.

H.1, H.2, and H.3 Required Action H.1 requires that the ADS valves be declared inoperable when a combination of Functions 4.e, 4.f, 5.e, and 5.f channels are inoperable such that neither ADS Trip System A or B has two OPERABLE Pump Discharge Pressure - High channels associated with one low pressure ECCS pump.

In this situation (loss of automatic initiation capability), the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 day allowance, as applicable, of Required Action H.2 is not appropriate, and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of ADS initiation capability in both trip systems. The Notes to Required Action H.1 state that Required Action H.1 is only applicable for Functions 4.e, 4.f, 5.e, and 5.f, and that it is only applicable when both ADS trip systems are inoperable due to Core Spray/LPCI Pump Discharge Pressure - High functions being inoperable. Required Action H.1 is not applicable to Functions 4.h and 5.h (which also require entry into this Condition if a channel in these Functions is inoperable), since they are Manual TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/4 STS B 3.3.5.1-33 Rev. 5.0 Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of these functions for 30 days (as allowed by Required Action H.3) is allowed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action H.1, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable channels within similar ADS trip system Functions as described in the paragraph above. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration of channels. If the inoperable channels cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.

BASES ACTIONS (continued)

Required Action H.2 is intended to ensure that appropriate actions are taken if there are not two OPERABLE Pump Discharge Pressure

- High channels associated with one low pressure ECCS pump within one ADS trip system, which results in automatic initiation capability being lost for that ADS trip system. Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, a Completion Time of 8 days has been shown to be acceptable (Ref. 6) to permit restoration of two inoperable Pump Discharge Pressure - High channels associated with one low pressure ECCS Pump to OPERABLE status if both HPCI and RCIC are OPERABLE (Required Action H.2).

[Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If either HPCI or RCIC is inoperable, the Completion Time shortens to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program]. If the status of HPCI or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> begins upon discovery of HPCI or RCIC inoperability. However, the total time to restore the required inoperable channels to OPERABLE status cannot exceed 8 days. If the status of HPCI or RCIC changes such that the Completion Time changes from 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable channel. If the minimum required inoperable channels cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken. The Required Actions do not allow placing the TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/4 STS B 3.3.5.1-34 Rev. 5.0 channel in trip since this action would not necessarily result in a safe state for the channel in all events. The Notes to Required Action H.2 state that Required Action H.2 is only applicable for Functions 4.e, 4.f., 5.e, and 5.f, and that it is only applicable when one ADS trip system is inoperable due to Core Spray/LPCI Pump Discharge Pressure - High functions being inoperable. Required Action H.2 is not applicable to Functions 4.h and 5.h (which also require entry into this Condition if a channel in these Functions is inoperable), since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of these functions for 30 days (as allowed by Required Action H.3) is allowed.

Required Action H.3 is intended to ensure that appropriate actions are taken if inoperable channels within one ADS trip system do not result in loss of automatic initiation capability to respond to a design basis event, but require restoration per Table 3.3.5.1-1. This applies to Functions 4.e, 4.f, 4.h, 5.e, 5.f, and 5.h. The 30 day Completion Time of Required Action H.3 is acceptable, based on operating experience, considering the multiple channels available for meeting the low pressure ECCS pump discharge pressure permissive, and the availability of automatic ADS initiation. If the inoperable channel cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.

BASES ACTIONS (continued)

IH.1 With any Required Action and associated Completion Time not met, the associated feature(s) may be incapable of performing the intended function, and the supported feature(s) (Core Spray, LPCI, HPCI, or ADS) associated with inoperable untripped channels must be declared inoperable immediately.

SURVEILLANCE

---

REVIEWERS NOTE-----------------------------------

REQUIREMENTS Certain Frequencies are based on approved topical reports. In order for a licensee to use these Frequencies, the licensee must justify the Frequencies as required by the staff SER for the topical report.

---

REVIEWERS NOTE-----------------------------------

Notes b and c are applied to the setpoint verification Surveillances for each ECCS Instrumentation Functions in Table 3.3.5.1-1 unless one or more of the following exclusions apply:

TSTF-592, Rev. 2

ECCS Instrumentation 3.3.5.1 General Electric BWR/6 STS 3.3.5.1-5 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.2 Place channel in trip.

96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channel concurrent with HPCS or reactor core isolation cooling (RCIC) inoperable AND 8 days

[OR In accordance with the Risk Informed Completion Time Program]

G. As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

G.1

---

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

Only applicable for Functions 4.c, 4.e, 4.f, 4.g, 5.c, 5.e, and 5.f.

Declare ADS valves inoperable.

AND 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems TSTF-592, Rev. 2

ECCS Instrumentation 3.3.5.1 General Electric BWR/6 STS 3.3.5.1-6 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G.2 Restore channel to OPERABLE status.

96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channel concurrent with HPCS or RCIC inoperable AND 8 days

[OR In accordance with the Risk Informed Completion Time Program]

H. As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

H.1

---

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

1. Only applicable for Functions 4.e, 4.f, and 5.e.

2. Only applicable when both ADS trip systems are inoperable due to LPCS/LPCI Pump Discharge Pressure -

High channels inoperable.

Declare ADS valves inoperable.

AND 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems TSTF-592, Rev. 2

ECCS Instrumentation 3.3.5.1 General Electric BWR/6 STS 3.3.5.1-7 Rev. 5.0 H.2

---

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

1. Only applicable for Functions 4.e, 4.f, and 5.e.

2. Only applicable when one ADS trip system is inoperable due to LPCS/LPCI Pump Discharge Pressure -

High channels inoperable.

Restore affected channels to OPERABLE status.

AND H.3 Restore channel to OPERABLE status.

96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channels concurrent with HPCS or RCIC inoperable AND 8 days [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channels in one trip system 30 days IH. Required Action and associated Completion Time of Condition B, C, D, E, F, G or GH not met.

IH.1 Declare associated supported feature(s) inoperable.

Immediately TSTF-592, Rev. 2

ECCS Instrumentation 3.3.5.1 General Electric BWR/6 STS 3.3.5.1-16 Rev. 5.0 Table 3.3.5.1-1 (page 6 of 8)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

3. HPCS System

[ h. Manual Initiation 1, 2, 3

[1]

C SR 3.3.5.1.6 NA ]

4. ADS Trip System A

a.

Reactor Vessel Water Level - Low Low Low, Level 1 1, 2(e), 3(e)

[2]

F SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6

[-152.5]

inches

b.

Drywell Pressure -

High 1, 2(e), 3(e)

[2]

F SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6

[1.44] psig

c.

ADS Initiation Timer 1, 2(e), 3(e)

[1]

G SR 3.3.5.1.2

[SR 3.3.5.1.4]

SR 3.3.5.1.6

[117]

seconds

d.

Reactor Vessel Water Level - Low, Level 3 (Confirmatory) 1, 2(e), 3(e)

[1]

F SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6

[10.8] inches

e.

LPCS Pump Discharge Pressure

- High 1, 2(e), 3(e)

[2]

HG SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6

[125] psig and

[165] psig (b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures [Nominal Trip Setpoint] to confirm channel performance. The LTSP and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].

(e)

With reactor steam dome pressure > [150] psig.

TSTF-592, Rev. 2

ECCS Instrumentation 3.3.5.1 General Electric BWR/6 STS 3.3.5.1-17 Rev. 5.0 Table 3.3.5.1-1 (page 7 of 8)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

4. ADS Trip System A

f.

LPCI Pump A Discharge Pressure

- High 1, 2(e), 3(e)

[2]

HG SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3]

SR 3.3.5.1.5 SR 3.3.5.1.6

[115] psig and

[135] psig

g.

[ ADS Bypass Timer (High Drywell Pressure) ]

1, 2(e), 3(e)

[2]

G SR 3.3.5.1.2

[SR 3.3.5.1.4]

SR 3.3.5.1.6

[9.4] minutes

[ h. Manual Initiation 1, 2(e), 3(e)

[2]

HG SR 3.3.5.1.6 NA ]

5. ADS Trip System B

a.

Reactor Vessel Water Level - Low Low Low, Level 1 1, 2(e), 3(e)

[2]

F SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6

[-152.5]

inches

b.

Drywell Pressure -

High 1, 2(e), 3(e)

[2]

F SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6

[1.44] psig

c.

ADS Initiation Timer 1, 2(e), 3(e)

[1]

G SR 3.3.5.1.2

[SR 3.3.5.1.4]

SR 3.3.5.1.6

[117]

seconds (b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures [Nominal Trip Setpoint] to confirm channel performance. The LTSP and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].

(e)

With reactor steam dome pressure > [150] psig.

TSTF-592, Rev. 2

ECCS Instrumentation 3.3.5.1 General Electric BWR/6 STS 3.3.5.1-18 Rev. 5.0 Table 3.3.5.1-1 (page 8 of 8)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

5. ADS Trip System B

d.

Reactor Vessel Water Level -

Low, Level 3 (Confirmatory) 1, 2(e), 3(e)

[1]

F SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6

[10.8] inches

e.

LPCI Pumps B & C Discharge Pressure

- High 1, 2(e), 3(e)

[4]

[2 per pump]

HG SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3]

SR 3.3.5.1.5 SR 3.3.5.1.6

[115] psig and

[135] psig

f.

[ADS Bypass Timer (High Drywell Pressure)]

1, 2(e), 3(e)

[2]

G SR 3.3.5.1.2

[SR 3.3.5.1.4]

SR 3.3.5.1.6

[9.4] minutes

[ g. Manual Initiation 1, 2(e), 3(e)

[2]

HG SR 3.3.5.1.6 NA ]

(b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures [Nominal Trip Setpoint] to confirm channel performance. The LTSP and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].

(e)

With reactor steam dome pressure > [150] psig.

TSTF-592, Rev. 2

AC Sources - Operating 3.8.1 General Electric BWR/6 STS 3.8.1-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2 Declare required feature(s) with no offsite power available inoperable when the redundant required feature(s) are inoperable.

AND A.3 Restore [required] offsite circuit to OPERABLE status.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of no offsite power to one division concurrent with inoperability of redundant required feature(s) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

[OR In accordance with the Risk Informed Completion Time Program]

AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> [or in accordance with the Risk Informed Completion Time Program] from discovery of two divisions with no offsite power

[OR In accordance with the Risk Informed Completion Time Program]

B. One [required] DG inoperable.

B.1 Perform SR 3.8.1.1 for OPERABLE [required]

offsite circuit(s).

AND 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/6 STS B 3.3.5.1-7 Rev. 5.0 BASES BACKGROUND (continued)

Each ADS trip system (trip system A and trip system B) includes a time delay between satisfying the initiation logic and the actuation of the ADS valves. The time delay chosen is long enough that the HPCS has time to operate to recover to a level above Level 1, yet not so long that the LPCI and LPCS systems are unable to adequately cool the fuel if the HPCS fails to maintain level. An alarm in the control room is annunciated when either of the timers is running. Resetting the ADS initiation signals resets the ADS Initiation Timers.

The ADS also monitors the discharge pressures of the three LPCI pumps and the LPCS pump. Each ADS trip system includes two discharge pressure permissive transmitters from each of the two low pressure ECCS pumps in the associated Division (i.e., Division 1 ECCS inputs to ADS trip system A and Division 2 ECCS inputs to ADS trip system B).

The signals are used as a permissive for ADS actuation, indicating that there is a source of core coolant available once the ADS has depressurized the vessel. Any one of the four low pressure pumps provides sufficient core coolant flow to permit automatic depressurization.

The ADS logic in each trip system is arranged in two strings. One string has a contact from each of the following variables: Reactor Vessel Water Level - Low Low Low, Level 1; Drywell Pressure - High or ADS Bypass Timer; Reactor Vessel Water Level - Low, Level 3; ADS Initiation Timer; and two low pressure ECCS Pump Discharge Pressure - High contacts.

The other string has a contact from each of the following variables:

Reactor Vessel Water Level - Low Low Low, Level 1; Drywell Pressure -

High; ADS Bypass Timer; and two low pressure ECCS Pump Discharge Pressure - High contacts. To initiate an ADS trip system, the following applicable contacts must close in the associated string: Reactor Vessel Water Level - Low Low Low, Level 1; Drywell Pressure - High or ADS Bypass Timer; Reactor Vessel Water Level - Low, Level 3; ADS Initiation Timer; and one of the two low pressure ECCS Pump Discharge Pressure

- High contacts. Either ADS trip system A or trip system B will cause all the ADS relief valves to open. Once the Drywell Pressure - High or ADS initiation signals are present, they are individually sealed in until manually reset.

Manual initiation is accomplished by operating the control switch for each safety/relief valve (S/RV) associated with the ADS. Manual inhibit switches are provided in the control room for ADS; however, their function is not required for ADS OPERABILITY (provided ADS is not inhibited when required to be OPERABLE).

TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/6 STS B 3.3.5.1-25 Rev. 5.0 BASES ACTIONS (continued)

Divisions (e.g., any Division 1 ECCS and Division 2 ECCS) cannot be automatically initiated due to inoperable, untripped channels within the same variable as described in the paragraph above. For Required Action B.2, the Completion Time only begins upon discovery that the HPCS System cannot be automatically initiated due to two inoperable, untripped channels for the associated Function in the same trip system.

The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been shown to be acceptable (Ref. 5) to permit restoration of any inoperable channel to OPERABLE status.

[Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action B.3. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue.

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

C.1 and C.2 Required Action C.1 is intended to ensure that appropriate actions are taken if multiple, inoperable channels within the same Function (or in some cases, within the same variable) result in redundant automatic initiation capability being lost for the feature(s). Required Action C.1 features would be those that are initiated by Functions 1.c, 1.d, 2.c, and 2.d (i.e., low pressure ECCS). For Functions 1.c and 2.c, redundant automatic initiation capability is lost if the Function 1.c and Function 2.c channels are inoperable. For Functions 1.d and 2.d, redundant automatic initiation capability is lost if two Function 1.d channels in the same trip system and two Function 2.d channels in the same trip system (but not necessarily the same trip system as the Function 1.d channels) are inoperable. Since each inoperable channel would have Required Action C.1 applied separately (refer to ACTIONS Note), each inoperable channel would only require the affected portion of the associated Division to be declared inoperable. However, since channels in both Divisions are inoperable, and the Completion Times started concurrently for the channels in both Divisions, this results in the affected portions in both Divisions being concurrently declared inoperable. For Functions 1.c TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/6 STS B 3.3.5.1-27 Rev. 5.0 BASES ACTIONS (continued) cannot be restored to OPERABLE status within the allowable out of service time, Condition IH must be entered and its Required Action taken.

The Required Actions do not allow placing the channel in trip since this action would either cause the initiation or would not necessarily result in a safe state for the channel in all events.

D.1, D.2.1, and D.2.2 Required Action D.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same Function result in a complete loss of automatic component initiation capability for the HPCS System. Automatic component initiation capability is lost if two Function 3.d channels or two Function 3.e channels are inoperable and untripped. In this situation (loss of automatic suction swap), the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance of Required Actions D.2.1 and D.2.2 is not appropriate and the HPCS System must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of HPCS initiation capability. As noted, the Required Action is only applicable if the HPCS pump suction is not aligned to the suppression pool, since, if aligned, the Function is already performed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action D.1, the Completion Time only begins upon discovery that the HPCS System cannot be automatically aligned to the suppression pool due to two inoperable, untripped channels in the same Function. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been shown to be acceptable (Ref. 5) to permit restoration of any inoperable channel to OPERABLE status.

[Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action D.2.1 or the suction source must be aligned to the suppression pool within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per Required Action D.2.2. Placing the inoperable channel in trip performs the intended function of the channel (shifting the suction source to the suppression pool). Performance of either of these two Required Actions will allow operation to continue. If Required Action D.2.1 or Required Action D.2.2 is performed, measures should be taken to ensure that the HPCS System piping remains filled TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/6 STS B 3.3.5.1-28 Rev. 5.0 BASES ACTIONS (continued) with water. Alternately, if it is not desired to perform Required Actions D.2.1 and D.2.2 (e.g., as in the case where shifting the suction source could drain down the HPCS suction piping), Condition IH must be entered and its Required Action taken.

E.1 and E.2 Required Action E.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the LPCS and LPCI Pump Discharge Flow - Low (Bypass) Functions result in redundant automatic initiation capability being lost for the feature(s). For Required Action E.1, the features would be those that are initiated by Functions 1.e, 1.f, and 2.e (e.g., low pressure ECCS). Redundant automatic initiation capability is lost if three of the four channels associated with Functions 1.e, 1.f, and 2.e are inoperable. Since each inoperable channel would have Required Action E.1 applied separately (refer to ACTIONS Note), each inoperable channel would only require the affected low pressure ECCS pump to be declared inoperable. However, since channels for more than one low pressure ECCS pump are inoperable, and the Completion Times started concurrently for the channels of the low pressure ECCS pumps, this results in the affected low pressure ECCS pumps being concurrently declared inoperable.

In this situation (loss of redundant automatic initiation capability), the 7 day allowance of Required Action E.2 is not appropriate and the feature(s) associated with each inoperable channel must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of initiation capability for feature(s) in both Divisions. A Note is also provided (the Note to Required Action E.1) to delineate that Required Action E.1 is only applicable to low pressure ECCS Functions. Required Action E.1 is not applicable to HPCS Functions 3.f and 3.g since the loss of one channel results in a loss of the Function (one-out-of-one logic). This loss was considered during the development of Reference 5 and considered acceptable for the 7 days allowed by Required Action E.2.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action E.1, the Completion Time only begins upon discovery that three channels of the variable TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/6 STS B 3.3.5.1-29 Rev. 5.0 BASES ACTIONS (continued)

(Pump Discharge Flow - Low) cannot be automatically initiated due to inoperable channels. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration of channels.

If the instrumentation that controls the pump minimum flow valve is inoperable such that the valve will not automatically open, extended pump operation with no injection path available could lead to pump overheating and failure. If there were a failure of the instrumentation such that the valve would not automatically close, a portion of the pump flow could be diverted from the reactor injection path, causing insufficient core cooling.

These consequences can be averted by the operator's manual control of the valve, which would be adequate to maintain ECCS pump protection and required flow. Furthermore, other ECCS pumps would be sufficient to complete the assumed safety function if no additional single failure were to occur. The 7 day Completion Time of Required Action E.2 to restore the inoperable channel to OPERABLE status is reasonable based on the remaining capability of the associated ECCS subsystems, the redundancy available in the ECCS design, and the low probability of a DBA occurring during the allowed out of service time. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition IH must be entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events. [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.]

F.1 and F.2 Required Action F.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within similar ADS trip system Functions result in automatic initiation capability being lost for the ADS. Automatic initiation capability is lost if either (a) more than one Function 4.a channel and one Function 5.a channel are inoperable and untripped, (b) one Function 4.b channel and one Function 5.b channel are inoperable and untripped, or (c) one Function 4.d channel and one Function 5.d channel are inoperable and untripped.

In this situation (loss of automatic initiation capability), the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 day allowance, as applicable, of Required Action F.2 is not appropriate, and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of ADS initiation capability in both trip systems.

TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/6 STS B 3.3.5.1-30 Rev. 5.0 BASES ACTIONS (continued)

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action F.1, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable, untripped channels within similar ADS trip system Functions as described in the paragraph above. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 8 days has been shown to be acceptable (Ref. 5) to permit restoration of any inoperable channel to OPERABLE status if both HPCS and RCIC are OPERABLE. [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If either HPCS or RCIC is inoperable, the time is shortened to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.

[Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If the status of HPCS or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> begins upon discovery of HPCS or RCIC inoperability. However, total time for an inoperable, untripped channel cannot exceed 8 days. If the status of HPCS or RCIC changes such that the Completion Time changes from 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable, untripped channel. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action F.2. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue. Alternately, if it is not desired to place the channel in trip (e.g., as in the case where placing the inoperable channel in trip would result in an initiation), Condition IH must be entered and its Required Action taken.

G.1 and G.2 Required Action G.1 is intended to ensure that appropriate actions are taken if multiple, inoperable channels within similar ADS trip system Functions result in automatic initiation capability being lost for the ADS.

Automatic initiation capability is lost if either (a) one Function 4.c channel and one Function 5.c channel are inoperable, (b) one or more channels Functions 4.e channels and one or more Function 5.e channels are TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/6 STS B 3.3.5.1-31 Rev. 5.0 BASES ACTIONS (continued) inoperable, (c) one or more Function 4.f channels and one or more Function 5.e channels are inoperable, or (bd) one or more Function 4.g channels and one or more Function 5.f channels are inoperable.

In this situation (loss of automatic initiation capability), the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 day allowance, as applicable, of Required Action G.2 is not appropriate, and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of ADS initiation capability in both trip systems. The Note to Required Action G.1 states that Required Action G.1 is only applicable for Functions 4.c, 4.e, 4.f, 4.g, 5.c, 5.e, and 5.f. Required Action G.1 is not applicable to Functions 4.h and 5.g (which also require entry into this Condition if a channel in these Functions is inoperable),

since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of manual initiation capability for 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 days (as allowed by Required Action G.2) is allowed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action G.1, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable channels within similar ADS trip system Functions, as described in the paragraph above. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 8 days has been shown to be acceptable (Ref. 5) to permit restoration to OPERABLE status if both HPCS and RCIC are OPERABLE (Required Action G.2). [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If either HPCS or RCIC is inoperable, the time is reduced to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.

[Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If the status of HCPS or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> begins upon discovery of HPCS or RCIC inoperability. However, total time for an inoperable channel cannot exceed 8 days. If the status of HPCS or RCIC changes such that the Completion Time changes from 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable channel. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition IH must be TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/6 STS B 3.3.5.1-32 Rev. 5.0 BASES ACTIONS (continued) entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events.

H.1, H.2, and H.3 Required Action H.1 requires that the ADS valves be declared inoperable when a combination of Functions 4.e, 4.f, and 5.e channels are inoperable such that neither ADS Trip System A or B has two OPERABLE Pump Discharge Pressure - High channels associated with one low pressure ECCS pump.

In this situation (loss of automatic initiation capability), the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 day allowance, as applicable, of Required Action H.2 is not appropriate, and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of ADS initiation capability in both trip systems. The Notes to Required Action H.1 state that Required Action H.1 is only applicable for Functions 4.e, 4.f, and 5.e, and that it is only applicable when both ADS trip systems are inoperable due to LPCS/LPCI Pump Discharge Pressure - High channels being inoperable. Required Action H.1 is not applicable to Functions 4.h and 5.g (which also require entry into this Condition if a channel in these Functions is inoperable), since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of these functions for 30 days (as allowed by Required Action H.3) is allowed.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action H.1, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable channels within similar ADS trip system Functions, as described in the paragraph above. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration of channels. If the inoperable channels cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.

Required Action H.2 is intended to ensure that appropriate actions are taken if there are not two OPERABLE Pump Discharge Pressure

- High channels associated with one low pressure ECCS pump within one ADS trip system, which results in automatic initiation TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/6 STS B 3.3.5.1-33 Rev. 5.0 capability being lost for that ADS trip system. Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, a Completion Time of 8 days has BASES ACTIONS (continued) been shown to be acceptable (Ref. 5) to permit restoration of two inoperable Pump Discharge Pressure - High channels associated with one low pressure ECCS Pump to OPERABLE status if both HPCS and RCIC are OPERABLE (Required Action H.2).

[Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If either HPCS or RCIC is inoperable, the Completion Time is reduced to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.

[Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If the status of HCPS or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> begins upon discovery of HPCS or RCIC inoperability. However, the total time to restore the required inoperable channels to OPERABLE status cannot exceed 8 days. If the status of HPCS or RCIC changes such that the Completion Time changes from 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable channel. If the minimum required inoperable channels cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.

The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events. The Notes to Required Action H.2 state that Required Action H.2 is only applicable for Functions 4.e, 4.f, and 5.e, and that it is only applicable when one ADS trip system is inoperable due to LPCS/LPCI Pump Discharge Pressure - High functions are inoperable. Required Action H.2 is not applicable to Functions 4.h and 5.g (which also require entry into this Condition if a channel in these Functions is inoperable), since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of these functions for 30 days (as allowed by Required Action H.3) is allowed.

Required Action H.3 is intended to ensure that appropriate actions are taken if inoperable channels within one ADS trip system do not result in loss of automatic initiation capability to respond to a design basis event, but require restoration per Table 3.3.5.1-1. This applies to Functions 4.e, 4.f, 4.h, 5.e, and 5.g. The 30 day Completion Time of Required Action H.3 is acceptable, based on operating experience, considering the multiple channels available for meeting the low pressure ECCS pump discharge pressure permissive, and the availability of automatic ADS initiation. If the inoperable channel TSTF-592, Rev. 2

ECCS Instrumentation B 3.3.5.1 General Electric BWR/6 STS B 3.3.5.1-34 Rev. 5.0 cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.

IH.1 With any Required Action and associated Completion Time not met, the associated feature(s) (LPCS, LPCI, HPCS, or ADS) may be incapable of performing the intended function and the supported feature(s) associated with the inoperable untripped channels must be declared inoperable immediately.

SURVEILLANCE

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REVIEWERS NOTE-----------------------------------

REQUIREMENTS Certain Frequencies are based on approved topical reports. In order for a licensee to use these Frequencies, the licensee must justify the Frequencies as required by the staff SER for the topical report.

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REVIEWERS NOTE-----------------------------------

Notes b and c are applied to the setpoint verification Surveillances for each ECCS Instrumentation Functions in Table 3.3.5.1-1 unless one or more of the following exclusions apply:

1. Manual actuation circuits, automatic actuation logic circuits or instrument functions that derive input from contacts which have no associated sensor or adjustable device, e.g., limit switches, breaker position switches, manual actuation switches, float switches, proximity detectors, etc. are excluded. In addition, those permissives and interlocks that derive input from a sensor or adjustable device that is tested as part of another TS function are excluded.

2. Settings associated with safety relief valves are excluded. The performance of these components is already controlled (i.e., trended with as-left and as-found limits) under the ASME Code for Operation and Maintenance of Nuclear Power Plants testing program.

3. Functions and Surveillance Requirements which test only digital components are normally excluded. There is no expected change in result between SR performances for these components. Where separate as-left and as-found tolerance is established for digital component SRs, the requirements would apply.

A generic evaluation of ECCS Instrumentation Functions resulted in Notes e and f being applied to the Functions shown in TS 3.3.5.1. Each licensee adopting this change must review the list of potential Functions to identify whether any of the identified functions meet any of the TSTF-592, Rev. 2