Text

Transmittal of Revision 19 to the Clinton Power Station Technical Specification Bases
	ML18002A358
Person / Time
Site:	Clinton
Issue date:	12/22/2017
From:	Stoner T; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	U-604396
	Download: ML18002A358 (38)
	v • d • e

Clinton Power Station 1 ;d 8401 Power Road ~

Clinton, IL 61727

~ Exelon Generation U-604396 10CFR 50.36 December 22, 2017 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRG Docket No. 50-461

Subject:

Transmittal of Revision 19 to the Clinton Power Station Technical Specification Bases In accordance with Clinton Power Station (CPS) Technical Specification 5.5.11, "Technical Specifications (TS) Bases Control Program," Exelon Generating Company (EGG), LLC is transmitting the revised pages constituting Revision 19 to the CPS TS Bases. The changes associated with TS 5.5.11 require updates to the TS Bases to be submitted to the NRG at a frequency consistent with 10 CFR 50.71, "Maintenance of records, making of reports,'

paragraph (e).

There are no regulatory commitments in this letter.

Should you have any questions concerning this report, please contact Mr. Dale Shelton, Regulatory Assurance Manager, at (217) 937-2800.

Respectfully, Theodore R. Stoner Site Vice President Clinton Power Station KP/cas - Revision 19 Bases Page Listing - Revision 19 Bases Pages cc: NRG Regional Administrator - Region Ill NRG Senior Resident Inspector - Clinton Power Station NRG Project Manager, NRR - Clinton Power Station

U-604396 Attachment 1 Revision 19 Bases Page Listing B 3.0-1 B 3.0-3 B 3.0-4 B 3.0-5 B 3.0-6 B 3.0-7 B 3.0-8 B 3.0-9 B 3.0-10 B 3.0-11 B 3.0-12 B 3.0-13 B 3.0-14 B 3.0-15 83.0-16 B 3.0-17 B3.0-18 B 3.1-42 B 3.3-154 B 3.4-20 B 3.4-32 B 3.5-11 B 3.6-5 B 3.6-17 B 3.6-18 B 3.6-25 B 3.6-26 B 3.6-42 B 3.6-58b B 3.6-120 B 3.10-1 B 3.10-2 B 3.10-3 B 3.10-4 B 3.10-5

U-604396 Attachment 2 Revision 19 Bases Pages

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.l through LCO 3.0.7 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

LCO 3.0.l LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, unless otherwise specified. I The Required Actions establish those remedial measures that must be taken within spec.i..f:i.ed Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Comp.i.etion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the (continued)

CLINTON B 3.0-1 Revision No. 19-5

LCO Applicability B 3.0 BASES (continued)

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a. An associated Required Action and Completion Time is not met and no other Condition applies; or

b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition o:f the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to enter lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capab:i.1.i.t:i.es of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

(continued)

CLINTON B 3.0-3 Revision No. 19-5

LCO Applicability B 3.0 BASES LCO 3.0;3 A unit shutdown required in accordance with LCO 3.0.3 may be (continued) terminated and LCO 3.0.3 exited if any of the following occurs:

a. The LCO is now met.

b. The LCO is no longer applicable.

c.. A Condition exists for which the Required Actions have now been performed.

d. ACTIONS exist that do not have expired Completion Times. These Completion Times a:re applicable from the point in time that the Condition ls initially entered and not from the time LCO 3.0.3 is exited.

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 4 when a shutdown is required during MODE 1 operation. If the unit is in a 1ower MODE of operation when a shutdown is requiredr the time limit for entering the next lower MODE applies. If a lower MODE is entered in less time than allowed, however, the total allowable t:i.me to enter MODE 4, or other applicable MODE, is not reduced. For example, if MODE 2 is entered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for entering MODE 3 is the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , because the total time for entering MODE 3 is not reduced from the allowable limit of 13 hour1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months s~ Therefore~ if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enter a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of: LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability {unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Exceptions to LCO 3.0.3 are provided in instances where requiring a un:it shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.7, nFuel Pool Water Level.n LCO 3.7.7 has an Applicability of "During movement of irradiated fuel (continued}

CLINTON B 3.0-4 Revision No. 19-5

LCO Applicability B 3.0 BASES LCO 3.0.3 assemblies in the associated fuel storage pool." Therefore, (continued) this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.7 are not met while~~

MODE 1, 2, or 3, ~there is no safety benefit to be gained by placing the unit :i.n a shutdown condition. The Required Action of LCO 3.7.7 of "Suspend movement of irradiated fuel assemblies in the associated fuel storage pool(s)tt is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Appl:i.cability with the LCO not met when the associated ACTIONS to be entered following entry into the MODE or other specified condition in the Applicability will.

perm:i.t continued operation within the MODE or the other specified condition for an unlimited period of time.

Compliance with ACTIONS that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicabi..U.ty may be made and the Required Actions followed after entry into the Applicability.

For example, LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time. Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION ("Required Action and associated Completion Time not met") allows the OPER.Z\BLE tra:i.n to be placed in operation, use of LCO 3.0.4.a is acceptable because the subsequent ACTIONS to be entered folJ.owing entry (continued)

CLINTON B 3.0-5 Revision No. 19-5

LCO Applicability B 3.0 BASES LCO 3.0.4 into the MODE include ACTIONS (place the OPERABLE train in (continued) operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability; and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or.

blended approachesi and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a) (4), which requires that risk impacts of maintenance activities be assessed and managed; 'rhe risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a) (4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.n Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelihes for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, act:i.ons to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of muJ.tiple systems and components.

(continued)

CLINTON B 3.0-6 Revision No. 19-5

LCO ApplicabLLi. ty B 3.0 BASES LCO 3.0.4 The results of the risk assessment shall be considered in (continued) determining the acceptability of entering the MODE or other specified condition i.n the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicabili.ty of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as .long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b i.s not applicable.

LCO 3.0.4.c allows entry into a MODE or other specified condition in the Appl.i.cabil.ity with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or .to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g. 4 reactor coolant system specific activity),

and may be applied to other Specifications based on NRC plant-specific approval.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the App.l.icabili.ty.

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the p:r.ovisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit (continued)

CLINTON B 3.0-7 Revision No. 19-5

LCO Applicability B 3.0 BASES LCO 3.0.4 shutdown is defined as a change in MODE or other specified (continued) condition in the Applicability associated with transitioning from MODE 1 to MODE 2 or 3, MODE 2 to MODE 3, and HODE 3 to MODE 4.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits); as permitted by SR 3.0.L Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However., SRs must be met to ensure OPF.RABILI'l'Y prior to decl.aring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO ..

LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of SRs to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs. This Specification does not provide time to perform any other preventive or corrective maintenance. LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other. specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.

(continued)

CLINTON B 3.0-8 Revision No. 19-5

LCO Applicability B 3.0 BASES LCO 3.0.5 An example of demonstrating equipment is OPERABLE with the (continued) Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel. o:r trip system out of a tripped condition that was d:i.rected by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service :i.s taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel.

Examples of demonstrating the OPERABILITY of other equipment are taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of an SR on another channel in the other trip system, or 2) to permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the same trip system.

The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Techn:i.ca1 Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with AC'l'IONS.

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system's LCO be entered solely due to the .inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support systems' Lco~s Required Actions. These Required Actions may include entering the supported system's Conditions and Required Act:i.ons or may specify other Required Actions.

(continued)

CLINTON B 3.0-9 Revision No. 19-5

LCO Applicability B 3.0 BASES LCO 3.0.6 When a support system is inoperable and there is an LCO (continued) specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result o:f the support system inoperability.

However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCO's Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition :i.n the support system's Required Actions.

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

Specification 5.5~10, >>safety Function Determination Program" (SFDP), ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actionsr or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. 'l'he SFDP implements the requirements of LCO 3.0.6.

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

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

LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit.

(continued)

CLIN'J.'ON B 3.0-10 Revision No. 19-5

LCO Applicability B 3.0 BASES LCO 3.0.7 These special tests and operations are necessary to (continued) demonstrate select unit performance characteristics, to perform special maintenance act:i.vities, and to perform special evolutions. Special Operations LCOs in Section 3.10 allow specified TS requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.

Tbe Applicability of a Special Operations LCO represents a condition not necessarily in compliance with the normal requirements of the TS. Compliance with Special Operations LCOs is optional. A special operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed. When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCO's Applicability (i.e., should tbe requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO). However, there are instances where the Special Operations LCO's ACTIONS may direct the other LCO's ACTIONS be met. The Surveillances of the other LCO are not required to be met, unless specified in the Special Operations LCO. If conditions exist such that the Applicability of any other LCO is met, all the other LCO's requirements (ACTIONS and SRs) are required to be met concurrent with the requirements of the Special Operations LCO.

CLINTON B 3.0-11 Revision No. 19-5

SR Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES

--===~*-===~~~-~====-=*-=.:mioanc:x::w::=*-=--*=~==----~===*=*********==::--:;uu::*=**= ~ = ~

SRs SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated. SR 3.0.2 and SR 3.0.3 apply in Chapter 5 only when invoked by a Chapter 5 Specification.

SR 3.0.1 SR 3.0.1 establishes the requirement that SRs must be met during the MODES or other specified conditions in the Applicabi1:Lty for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Survei.l.1ances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a Surveillance within the specified Frequency, in accordance with SR 3.0.2, constitutes a failure to meet an LCO.

Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, altho~gh still meeting the SRs; or b.. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.

Surveillances do not have to be performed when the unit is in a MODE or other specified condition for which the requirements of the associated LCO are not applicable, unless otherwise specified. The SRs associated with a Special Operations LCO are only applicable when the Special Operations LCO is used as an allowable exception to the requirements of a Specification.

Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply.

Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.

(continued)

CLINTON B 3.0-12 Revision No. 19-5

SR Applicability B 3.0 BASES SR 3.0.1 Upon completion of maintenance, appropriate post maintenance (continued) testing is :required to declare equipment OPERl\BLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed. Some examples of this process are:

a. Control rod drive maintenance during refueling that requires scram testing at~ 950 psig. However, if other appropriate testing is satisfactorily completed and the scram time testing of SR 3.1.4.3 is satisfied, the control rod can be considered OPERABLE. This allows startup to proceed to reach 950 psig to perform other necessary testing.

b. Reactor Core Isolation Cooling (RCIC) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with RCIC considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per ... "

interval.

SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g.,

transient conditions or other ongoing Surveillance or maintenance activities).

(continued)

CLINTON B 3.0-13 Revision No. 19-5

SR Applicability B 3.0 BASES SR 3.0.2 The 25% extension does not significantly degrade the (continued) reliability that results from performing the Survei1lance at its specLfied Frequency. This is based on the recogn.i.tion that the most probable result of any particular Surve.i..l.lance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply. These exceptions are stated in the .individual Specifications. The requirements of regulations take precedence over the TS. Therefore, when a test interval is specified in the regulations, the test interval cannot be extended by the TS, and the TS will then include a Note stating, "SR 3.0.2 is not applicable." An example of an exception when the test interval is not specified in the regulations is the Note in the Primary Containment Leakage Rate Testing Program, "SR 3.0.2 is not applicable." This exception is provided because the program already includes extension of test intervals.

As stated in SR 3 .. 0.2, the 251 extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ... " basis. The 25%

extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25%

extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been performed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3. 0. 2, and not at the'

( continued)

CLINTON B 3. 0-14 Revision No. 19-5

SR Applicability B 3.0 BASES SR 3.0.3 time that the specified Frequency was not met. This delay (continued) period provides adequate time to perform Surveillances that have been missed. 'l'his delay period permits the performance of a Surveillance before complying with Required Jl.ctions or other .r.emedia.J. measures that might preclude performance of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specif:i.ed Frequency to perform the surveillance.

However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity. SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

SR 3.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed. Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment (continued)

CLINTON B 3.0-15 Revision No. 19-5

SR Applicability B 3.0 BASES SR 3.0.3 from the performance of similar equipment. The rigor of (continued) determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed. For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented :i.n sufficient detail to allow a knowledgeable individual to understand the basis for. the determination.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedly to extend Surveillance intervals. While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to ~erform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant r.:i.sk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a) (4) and its implementation guidance,. NRC Regulatory Guide 1. 182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management actions up to an including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance o.f: the component.

Missed Surve:LLLances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation shouJ.d be used to determine the safest course of action. All missed Surveillances will be placed in the Clinton Power Station Corrective Action Program.

(continued) .

CLINTON B 3.0-16 Revision No. 19-5

SR Applicability B 3.0 BASES SR 3.0.3 If a Surveillance is not completed within the allowed delay (continued) period, then the equipment is considered inoperable or the variable then is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within tbe delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specitication ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3. 0,. 4.

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perfor~ the Surveillance(s) within the specified Frequency does n6t result in an SR 3.0.4 restriction to changing MODES (continued)

CLINTON B 3.0-17 Revision No. 19-5

SR Applicab.U.i.ty B 3.0 BASES SR 3.0.4 or other specified conditions of the Applicability.

(continued) However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes.

SR 3,0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2 or 3, MODE 2 to MODE 3, and MODE 3 to MODE 4.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

CLINTON B 3.0-18 Revision No. 19-5

SLC System B3.l.7 BASES SURVEILLANCE SR 3.1.7.5 REQUIREMENTS (continued) This Surveillance requires an examination of the sodium pentaborate solution by using chemical analysis to ensure the proper concentration of boron exists in the storage tank. SR 3.1.7.5 must be performed anytime boron or water is added to the storage tank solution to establish that the boron solution concentration is within the specified li~its.

This Surveillance must be performed anytime the solution temperature is restored to~ 70°F, to ensure no significant boron precipitation occurred. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

With regard to boron concentration values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 6).

SR 3.1.7.7 Demonstrating each SLC System pump develops a flow rate

> 41.2 gpm at a discharge pressure> 1220 psig ensures that pump performance has not degraded during the fuel cycle.

This minimum pump flow rate requirement ensures that; when combined with the sodium pentaborate solution concentration requirements, the rate of negative reactivity insertion from the SLC System will adequately compensate for the positive reactivity effects encountered during power reduction, cooldown of the moderator, and xenon decay. This test confirms one point on the pump design curve, and is indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this Surveillance is in accordance with the INSERVICE TESTING PROGRAM.

Values obtained for flow rate and discharge pressure pursuant to this SR, as read from plant indication instrumentation, are considered to be nominal values and therefore do not require compensat1.on for instrument indication uncertainties (Ref. 7).

(continued)

CLINTON B 3.1-42 Revision No. 19-4

Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 BASES APPLICABLE 4. Reactor Water Cleanup System Isolation SAFETY ANALYSES, LCO, and 4.a. Differential Flow-High APPLICABILITY (continued) The high differential flow signal is provided to detect a break in the RWCU System. This will detect leaks in the RWCU System when area or differential temperature would not provide detection (i.e., a cold leg break). Should the reactor coolant continue to flow out of the break, offsite dose limits may be exceeded. Therefore, isolation of the RWCU System is initiated when high differential flow is sensed to prevent exceeding offsite doses. A time delay is provided to prevent spurious trips during most RWCU operational transients. This Function is assumed to mitigate breaks in the RWCU piping inside containment to preclude subcompartment overpressurization which could lead to containment failure (Ref. 1). This Function is not assumed in any USAR transient or accident analysis for pipe breaks outside containment, since bounding analyses are performed for large breaks such as MSLBs.

The high differential flow signals are initiated from two transmitters that are connected to the inlet (from the reactor vessel) and four transmitters from the outlets (to condenser and feedwater) of the RWCU System. The outputs of the transmitters are compared (in two different summers) and the outputs are sent to two high flow trip units. If the difference between the inlet and outlet flow is too large, each trip unit generates an isolation signal. Two channels of Differential Flow-High Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function.

The Reactor Water Cleanup Differential Flow-High Allowable Value ensures that the break of the RWCU piping is detected.

4.b. Differential Flow-Timer The Differential Flow-Timer is provided to avoid RWCU System isolations due to operational transients (such as pump starts and mode changes). During these transients the inlet and return flows become unbalanced for short time periods and Differential Flow-High will be sensed without an RWCU System break being present. This function is assumed to mitigate breaks in the RWCU piping inside containment to preclude subcompartment overpressurization which could lead to containment failure (Ref. 1). Credit for this Function is not assumed in the USAR accident or transient analysis for pipe breaks outside containment, since bounding analyses are performed for large breaks such as MSLBs.

(continued)-

CLINTON B 3.3-154 Revision No. 19-1

S/RVs B 3.4.4 BASES ACTIONS A.1 and A.2 (continued) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.4.1 REQUIREMENTS This Surveillance demonstrates that the required S/RVs will open at the pressures assumed in the safety analysis of Reference 4. The demonstration of the S/RV safety function lift settings must be performed during shutdown, since th.:l.s is a bench test, and in accordance with the INSERVICE TESTING PROGRAM. The lift setting pressure shall correspond to ambient conditions of the valves at nominal operating temperatures and pressures. The S/RV setpoint is +/- 3t; for OPERABILITY; however, the valves are reset to+/- 1% during the Surveillance to allow for drift.

The Frequency was selected because this Surveillance must be performed during shutdown conditions and is based on the time between refuelings.

With regard to pressure values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 5).

SR 3.4.4.2 The required relief function S/RVs are required to actuate automatically upon receipt of specific initiation signals.

A system functional test is performed to verify the mechanical portions (i.e., solenoids) of the automatic relief fupction operate as designed when initiated either by an actual or simulated initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.5.4 overlaps this SR to provide complete testing of the safety function.

(continued)

CLINTON B 3.4-20 Revision No. 19-4

RCS PIV Leakage B 3.4.6 BASES (continued)

SURVEILLANCE SR 3.4.6.1 REQUIREMENTS Performance of leakage testing on each RCS PIV is required to. verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum.

applies to each valve. Leakage testing requires a stable pressure condition. For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.

The Frequency required by the INSERVICE TESTING PROGRAM is within the ASME Code Frequency requirement and is based on the need to perform this surveillance under the conditions that apply during an outage and the potential for an unplanned transient if the surveillance were performed with the reactor at power.

Therefore, this SR is modified by a Note that states the leakage Surveillance is not required to be performed in MODE 3. Entry into MODE 3 is permitted for leakage testing at high differential pressures with stable conditions not possible in the lower MODES.

With regard to leakage values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 9).

(continued)

CLINTON B 3.4-32 Revision No. 19-4

ECCS-Dperating B 3.5.1.

BASES SURVEILLANCE SR 3. 5.1. 3 REQUIREMENTS (continued) Verification that ADS accumulator supply pressure is;:,:: 140 psig assures adequate air pressure for reliable ADS operation. The accumulator on each ADS valve provides pneumatic pressure for valve actuation. The designed pneumatic supply pressure requ.i:r.ements for the accumulator are such that, following a failure of the pneumatic supply to the accumulator, at least two valve actuations can occur with the drywall at 70% of design pressure (Ref. 15}. The ECCS safety analysis assumes only one actuation to achieve the depressu:r.::i.zation required for operation of the low pressure ECCS. This minimum required pressure of 140 psig is provided by the Instrument Air System. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

With regard to ADS accumulator supply pressure values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is not considered to be a nominal value with respect to instrument uncertainties.

This requires additional mar.gin to be added to the limit to compensate for instrument uncertainties, for implementation in the associated plant procedures (Ref. 17).

SR 3. 5 .1. 4 The performance requirements of the ECCS pumps are determined through application of the 10 CFR 50, Appendix K, criteria (Ref. 8). This periodic Surveillance is performed (in accordance with the ASME Code requirements for the ECCS pumps) to verify that the ECCS pumps will develop the flow rates required by the respective analyses. 'l'he ECCS pump flow rates ensure that adequate core cooling is provided to satisfy the acceptance criteria of 10 CFR 50.46 (Ref. 10).

The pump :flow rates are verified with a pump differential pressure that is sufficient to overcome the RPV pressure expected during a LOCA. The pump outlet pressure is adequate to overcome the elevation head pressure between the pump suction and the vessel discharge, the piping friction losses, and RPV pressure present during LOCAs. These values may be established during pre-operational testing. The Frequency for this Surveillance is in accordance with the INSERVICE TESTING PROGRAM requirements.

(continued)

CLINTON B 3.5-11 Revision No. 19-4

Primary Containment B 3.6.1.1 BASES SURVEILLANCE SR 3.6.1.1.1 (continued)

REQUIREMENTS (continued) With regard to leakage rate values obtained pursuant to this SR, as read from plant indication instrum~ntation, the specified limit is considered to be a nominal value and therefore does not require compensat.i.on for instrument indication uncertainties (Ref. 7).

SR 3. 6. 1. 1. 2 With respect to primary containment integrated leakage rate testing, the p.r.:i.ma:r:y containment hydrogen recombiners (located outside the primary containment) are considered extensions of the primary containment boundary. This requires the smaller of the leakage from the PCIVs that isolate the primary containment hydrogen recombiner, or from the piping boundary outside containment, to be included in the ILRT results. The Frequency is required by the Primary Containment Leakage Rate Testing Program.

With regard to leakage rate values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 7).

REFERENCES 1. USAR, Section 6.2.

2. USAR, Section 15.6.5.

3. 1.0 CFR 50, Appendix J, Option B.

4. USAR, Section 6.2.1.

5. NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J."

6. ANSI/ANS-56.8-2002, "American National Standard for Containment System Leakage Testing Requirement."

7. Calculation IP-0-0056.

8. NEI 94-01, Revision 2-A, "Industry Guideline for Implementing Performance-Based Option of 10 CE'R Part 50, Appendix J."

CLINTON B 3.6-5 Revision No. 19-5

PCIVs B 3.6.1.3 BA.SES LCO applicable, in the USAR (Ref. 5). Purge valves with (continued) resilient seals, secondary containment bypass isolation valves, MSIVs, and hydrostatically tested valves must meet other leakage rate requirements. Other PCIV leakage rates are addressed by LCO 3.6.1.1, ~Primary Containment," as Type B or C testing.

I This LCO provides assurance that the PCIVs will perform their designed safety functions to minimize the loss of reactor coolant inventory, and establish the primary containment boundary during accidents.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment. In MODES 4 ands, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, most PCIVs are not required to be OPERABLE in MODES 4 and 5. Cer.ta.in valves are required to be OPERABLE, however, to prevent inadvertent reactor vessel draindown and release of radioactive material during a postulated fuel handling accident. These valves are those that isolate the Residual Heat Removal (RHR} Shutdown Cooling supply and return lines and those PCIVs in lines which bypass secondary containment.

ACTIONS The ACTIONS are modified by a Note allowing penetration flow path(s) to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated individual at the controls of the valve, who is in continuous communication 1-1ith the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

A second Note has been added to provide clarification that, for the purpose of this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable PCIV.

Complying with the Required Actions may allow for continued operation, and subsequent inoperable PCIVs are governed by subsequent Condition entry and application of associated Required Actions.

The ACTIONS are modified by Notes 3 and 4. These Notes ensure appropriate remedial actions are taken, if necessary, if the affected system(s) are rendered inoperable by an inoperable PCIV (e.g., an Emergency Core Cooling System subsystem is inoperable due to a failed open test return (continued)

CLINTON B 3.6-17 Revision No. 19-3

PCIVs B 3.6.1.3 BASES ACTIONS valve, or when the primary containment l.eakage l:i.mits are (continued) exceeded). Pursuant to LCO 3.0.6, these ACTIONS are not required even when the associated LCO is not met.

Therefore, Notes 3 and 4 are added to require the proper actions to be taken.

A fifth note has been added to allow removal of the Inclined Fuel Transfer System {IFTS) blind flange when primary containment operability is required. This provides the option of operating the IFTS for testing, maintenance, or movement of new (non-irradiated) fuel to the upper containment pool when primary containment operability is required. Requiring the fuel building fuel transfer pool water to be~ el. 753 ft. ensures a sufficient depth of water over the highest point on the transfer tube outlet valve in the fuel building fuel transfer pool to pre~ent direct communication between the containment building atmosphere and the fuel building atmosphere via the inclined fuel transfer tube. Because excessive leakage of water from the upper containment pool through the open IFTS penetration would result in the inability to provide the required volume of 1-Jater to the suppression pool in an upper pool dump, an administrative control was required to ensure the upper pool volume meets the design requirements. In addition to the dedicated individual stationed at the IFTS controls, the required administrative controls involved the installation of the Steam Dryer Pool to Reactor Cavity Pool gate with the seal inflated and a backup air supply provided. Since the IFTS transfer tube drain line does not have the same water level as the transfer tube, and the motor-operated drain valve remains open when the carriage is in the lower pool, administrative controls are required to ensure the drain line flow path is quickly isolated in the event of a LOCA.

In this instance, administrative controls of the IFTS transfer tube drain line isolation valve{s) include stationing a dedicated individual, who is in continuous corrnnunication with the control room, at the IFTS control panel in the fuel building. This individual will initiate closure of the IFTS transfer tube drain line motor-operated isolation valve (1F42-F003), the IFTS transfer tube.drain line manual isolation valve (1F42-F301), and the IFTS.drain line test connection isolation valve (1F42-F305) if a .need for primary containment isolation is indicated. The pressure integrity of the IFTS transfei tube, the seal created by water depth of the fuel building transfer pool, and the administrative control of the drain line flow path create ~ri acceptable barrier to preveht the post-accident containment building atmosphere from leaking into the.fuel building.

The total time per operating cycle that the blind flange may be open in Modes 1, 2, and 3 without affecting pla~t .risk levei~.is 40 days. *

(continued)

CLINTON B 3.6-18 Revision No. 19-3

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.4 (continued)

REQUIREMENTS in a time period less than or equal to that assumed in the safety analysis. The isolation time and Frequency of this SR are in accordance with the INSERVICE TESTING PROGRAM.

With regard to isolation time values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 8).

SR 3.6.1.3.5 For primary containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of the Primary Containment Leakage Rate Testing Program is required to ensure OPERABILITY. The acceptance criterion for this test is :s; 0.02 La for each penetration when pressurized to Pa, 9.0 psig. Since cycling these valves may introduce additional seal degradation (beyond that which occurs to a valve that has not been opened), this SR must be performed within 92 days after opening the valve. However, operating experience has demonstrated that if a valve with a resilient seal is not stroked during an operating cycle, significant increased leakage through the valve is not observed. Based on this observation, a normal Frequency in accordance with the Primary Containment Leakage Rate Testing Program was established.

The SR is modified by a Note stating that the primary containment purge valves are only required to meet leakage rate testing requirements in MODES 1, 2, and 3. If a LOCA inside primary containment occurs in these MODES, purge valve leakage must be minimized to ensure offsite radiological relepse is within limits. At other times when the purge valves are required to be capable of closing (e.g., during handling of recently irradiated fuel),

pressurization concerns are not present and the purge valves are not required to meet any specific leakage criteria.

With regard to leakage rate values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 9).

Dose associated with leakage through the primary containment purge lines is considered to be in addition to that controlled as pa.r.t of the primary containment leakage rate limit, La, and the 0.08 La limit for the other secondary containment bypass leakage paths.

(continued)

CLINTON B 3.6-25 Revision No. 19-4

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3. 6. 1. 3. 6 REQUIREMENTS (continued) Verifying that the full closure isolation time of each MSIV is within the specified limits is required to demonstrate OPERABILITY. The full closure isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the DBA analyses. The Frequency of this SR is :i.n accordance with the INSERVICE TESTING PROGRAM.

With regard to isolation time values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 10).

SR 3.6.1.3.7 Automatic PCIVs close on a primary containment isolation signal to prevent leakage of radioactive material from primary containment following a OBA. This SR ensures that each automatic PCIV will actuate to its isolation position on a primary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.1.6 over.laps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.1.3.8 This SR ensures that the leakage rate of secondary containment bypass 1eakage paths is less than the specified leakage rate. This provides assurance that the assumptions in the radiological evaluations of References 1, 2, and 3 are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leakage (leakage through the worse of tbe two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed manua1 valve, or blind flange. In this case,. the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway (continued)

CLINTON B 3.6-26 Revision No. 19-4

RHR Containment Spray System B 3.6.l.7 BASES (continued)

SURVEILLANCE SR 3.6.1.7 . .1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR containment spray mode flow path provides assurance that the proper flow paths will exist for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position~ since these were verified to be in the correct position prior to locking, sealing, or securing. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to val.ves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is contro.lled under the Surveillance Frequency Control Program.

Two Notes have been added to this SR. The first Note allows RHR containment spray subsystems to be considered OPERABLE during alignment to and operation in the RHR shutdown cooling mode when below the RHR cut in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise i.noperable. At these low pressures and decay heat levels (the reactor is shut down in MODE 3), a reduced complement of subsystems should provide the required containment pressure mitigation function thereby allowing operation of an RHR shutdown cooling loop when necessary.

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

SR 3.6.1.7.2 Verifying each RHR pump deve1ops a :flow rate~ 3800 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that pump performance has not degraded below the required flow rate during the cycle. It is tested in the pool cooling mode to demonstrate pump OPERABILITY without spraying down equipment in primary containment. Although this SR is satisf:i.ed by running the pump in the suppression pool cooling mode, the test procedures that satisfy this SR include appropriate acceptance criteria to account for the higher pressure requirements resulting from aligning the RHR System in the containment spray mode. The Frequency of this SR is in accordance with the INSERVICE TESTING PROGRAM.

(cont:i.nued)

CLINTON B 3.6-42 Revision No, 19-4

RHR Suppression Pool Cooling B 3.6.2.3 BASES SURVEILLANCE SR 3.6.2.3.2 REQUIREMENTS (continued) Verifying each RHR pump develops a flow rate~ 4550 gpm, with flow through the associated heat exchanger to the suppression pool, ensures that pump performance has not degraded during the cycle. Flow is a normal test of centrifugal pump performance required by ASME (Ref. 3),

This test confirms one point on the pump design curve, and the results are indicative of overall. performance. Such inservice inspections confirm component OPERABILI'l'Y, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the INSERVICE TESTING PROGRAM.

With regard to RHR pump flow rate values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value with respect to instrument uncertainties. 'l'his requires additional margin to be c1dded to the limit to compensate for instrument uncertainties for implementation in the associated plant procedures. (Ref. 5).

SR 3.6.2.3.3 RHR Suppression Pool Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR suppression pool cooling subsystems and may also prevent wate.r. hammer and pump cavitation.

Selection of RHR Suppression Pool Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and

i.nstrumentat.i.on drawings,-isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Suppression Pool Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Suppression Pool Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be (continued)

CLINTON B 3.6-58b Revision No. 19-4

Drywell Isolation Valves B 3.6.5.3 BASES SURVEILLANCE SR 3.6.5.3.3 REQUIREMENTS

( continued) This SR requires verification that each drywell isolation manual valve and blind flange that is required to be closed during accident conditions is closed. The SR helps to ensure that drywell bypass leakage is maintained to a minimum. Due to the location of these devices, the Frequency specified as "prior to entering MODE 2 or 3 from MODE 4, if not performed in the previous 92 days~" is appropriate because of the inaccessibility of the devices and because these devices are operated under administrative controls and the probability of thei.r misalignment is low.

Two Notes are added to this SR. The first Note allows valves and blind flanges located in high radiation areas to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable s:i.nce access to these areas is typically restricted during MODES 1, 2, and 3. Therefore, the probability of misalignment of these devices, once they have been verified to be in their proper position, is low. A second Note is included to clarify that the drywell isolation valves that are open under administrative controls are not required to meet the SR during the time that the devices are open~

SR 3.6.5.3.4 Verifying that the isolation time of each power operated and each automatic drywell isolation ~alve is within limits :i.s required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis. The isolation time and Frequency of this SR are in accordance with the INSERVICE TESTING PROGRAM.

With regard to isolation time values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 3).

(continued)

CLINTON B 3.6-120 Revision No. 19-4

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.10 SPECIAL OPERATIONS B 3~10~1 Inservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LCO is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures> 200°F (normally corresponding to MODE 3) or to allow completing thesi reactor coolant pressure tests when the initial conditions do not require temperatures

> 200°F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 200°F when the control rod scram time testing is initiated in conjunction with an inservice leak or hydrostatic test.

These control rod scram time tests would be performed in accordance with LCO 3.10.4, "Single Control Rod Withdrawal-Cold Shutdown," during MODE 4 operation.

Inservice hydrostatic testing and system leakage pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. Recirculation pump operation and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits required by LCO 3.4.11, "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits." These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.

With increased reactor vessel fluence over time, the minimum allowable vessel temperature increases at a given pressure.

Periodic updates to the RCS P/T limit curves are performed as necessary, based on the results of analyses of irradiated surveillance specimens removed from the vessel. Hydrostatic and leak testing may eventually be required with minimum reactor coolant temperatures> 200°F. However, even with required minimum reactor coolant temperatures< 200°F, maintaining RCS temperatures within a small band during the

( continued)

CLINTON B 3.10-1 Revision No, 19-2

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES BACKGROUND test can be impractical. Removal of heat addition from (continued) recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.

The hydrostatic and/or RCS system leakage t.ests require increasing pressure to 1025 - 1040 psig. Scram time testing required by SR 3.1~4.1 and SR 3:1~4~4 requires reactor pressures ~ 950 psig.

Other testing may be performed in conjuction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests ..

APPLICABLE Allowing the reactor to be considered in MODE 4 when the SAFETY ANALYSES reactor coolant temperature is > 200°F, durj,.ng '-* or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, effectively provides an exception to MODE 3 reqriiremen£s, including OPERABILITY of primary containment and the full complement of redundant Emergency Core Cooling Systems (ECCS). Since the tests are performed nearly water solid, at low decay heat values, and near MODE 4 conditions, the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel and a subsequent increase in coolant activity above the limits of LCO 3,4.8, "Reactor Coolant System (RCS) Specific Activity,~

are minim'ized. In addition, the secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment.

In the event of a large primary system lea~, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems t~ operate. The capability of the low pressure coolant injection and low pressure core spray subsystems, as required in MODE 4 by LCO 3.5.2,

~ECCS-Shutdown/" would be more than adequate to keep the core flooded under this low decay heat load condition.

Small system leaks would be detected by leakage inspections before significant inventory loss occurred.

(continued)

CLINTON B 3.10-2 Revision No. 19-2

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE For the purposes of this test, the protection provided by SAFETY ANALYSES normally required MODE 4 applicable LCOs, in addition to the (continued) secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal.hydrostatic test conditions and during postulated accident conditions. As part of ensuring the Standby Gas Treatment System filters fission products released from leakages during the test, the secondary containment bypass paths (the upper containment personnel air lock and valves which isolate other secondary containment bypass paths) are also required to meet their associated LCOs.

As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of the NRC Policy Statement apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.

LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. Operation at reactor coolant temperatures> 200°F, can be in accordance with Table 1.1-1 for MODE 3 operation without meeting this Special Operations LCO or its ACTIONS. This option may be required due to P/T limits, however, which require testing at temperatures

> 200°F, while the ASME inservice test itself requires the safety/relief valves to be gagged, preventing their OPERABILITY. Additionqlly, even with required minimum reactor coolant temperatures< 200°F, RCS temperatures may drift above 200°F during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak and hydrostatic testing.

While this Special Operations LCO is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections is not precluded.

If it is desired to perform these tests while complying with this Special Operations LCO, ,then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. This Special Operations LCO allows changing Table 1.1-1 temperature limits for MODE 4 to "NA" and suspending the requirements of LCO 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown." The additional requirements for secondary containment and secondary containment bypass path LCOs to be met will provide sufficient protection for operations at reactor coolant temperatures> 200°F for the purposes of performing an inservice leak or hydrostatic test, J (continued)

CLINTON B 3.10-3 Revision No. 19-2

Inservice Leak and Hydrostatic Testing Operation B 3 .10 *. 1 BASES LCO (continued) and for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test. I This LCO allows primary containment to be open for frequent unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable requirements.

APPLICABILITY The MODE 4 requirements may only be modified for the performance o(, or as a consequence of, inservice leak or hydrostatic tests, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, so that these operations can be considered as in MODE 4, even though the reactor coolant temperature is> 200°F"' The additional requirement for secondary containment OPERABILITY according to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur. Operations in all other MODES are unaffected by this LCO.

ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing oper-ation .*

Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components; or variables expressed in the Condition discovered to be inoperable Or not within limits, will not result in separate entry into the Condition~ Section 1,3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition.

However, the Required Actions for each requirement of the LCO not met provide appropriate compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO.

A.1 If an LCO specified in LCO 3 ..10 .1 is not met, the ACTIONS applicable to the stated requirements shall be entered immediately and complied with._ Required Action A.1 has been modified by a Note that clarifies the intent of another LCO's Required Action to be in MODE 4. This Required Action includes reducing the average reactor coolant temperature to

$ 200°F ..

(continued)

CLINTON B 3,;10-4 Revislon No;. 19-2

Inservice Leak and Hydrostatic Testing Operation B 3,,10.1 BASES ACTIONS A.2.1 and A.2.2 (continued)

Required Actions A.2.1 and A.2.2 are alternate Required Actions that can be taken instead of Required Action A.l to restore compliance with the normal MODE 4 requirements, and thereby exit this Special Operations LCO's Applicability.

Activities that could further increase reactor coolant temperature or pressure are suspended immediately, in accordance with Required Action A.2.1, and the reactor coolant temperature is reduced to establish normal MODE 4 requirements. The allowed Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Required Action A.2.2 is based on engineering judgment and provides sufficient time to reduce the average reactor coolant temperature from the highest expected value to

~ 200°F with normal cooldown procedures. The Completion Time is also consistent with the time provided in LCO 3.0.3 for reaching MODE 4 from MODE 3.

SURVEILLANCE SR 3 .10 .1.1 REQUIREMENTS The LCOs made applicable are required to have their Surveillances met to establish that this LCO is being met. A discussion of the applicable SRs is provided in their respective Bases~

REFERENCES 1. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section XI.

2. USAR, Section 15, 6; 4.

CLINTON B 3 i,10-5 Revision No. 19-2

U-604396, Transmittal of Revision 19 to the Clinton Power Station Technical Specification Bases

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U-604396, Transmittal of Revision 19 to the Clinton Power Station Technical Specification Bases

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