RS-23-002, Application to Adopt TSTF-332, ECCS Response Time Testing

Application to Adopt TSTF-332, ECCS Response Time Testing

ML23013A180
Person / Time
Site:	Clinton
Issue date:	01/13/2023
From:	Simpson P Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-23-002
Download: ML23013A180 (1)

Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office

10 CFR 50.90 RS-23-002 January 13, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Application to Adopt TSTF-332, "ECCS Response Time Testing"

References:

1. TSTF-332, Revision 1, "ECCS Response Time Testing," dated September 25, 2000 (ADAMS Accession No. ML003751434)

2. Letter from D.V. Pickett (U.S. NRC) to R.F. Phares (Clinton Power Station),

Issuance of Amendment No. 98 to Facility Operating License No. NPF Clinton Power Station, Unit 1 (TAC No. M91387), dated March 9, 1995 (ADAMS Accession No. 9503160321)

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Facility Operating License No. NPF-62 for Clinton Power Station (CPS) to adopt of TSTF-332, "ECCS Response Time Testing," Revision 1 (Reference 1), an approved change to the Improved Standard Technical Specifications (ISTS).

CPS previously received approval via Reference 2 to eliminate certain sensor response time testing requirements as described in the Boiling Water Reactor Owners' Group topical report, NEDO-32291, "System Analyses for Elimination of Selected Response Time Testing Requirements." The proposed change would revise TS definitions for ECCS RESPONSE TIME, ISOLATION SYSTEM RESPONSE TIME, and RPS RESPONSE TIME to incorporate standardized wording that was developed after the initial CPS amendment was received. The proposed change also moves Notes that were added by Reference 2 to the Bases, consistent with the current standard technical specifications and TSTF-332. By revising the definitions for response time testing and the associated implementing SR Bases, the details of which channel sensors are measured, and which are allowed to be assumed can be clearly delineated without needing to retain the individual Surveillance Requirement (SR) notes. This change is primarily

January 13, 2023 U.S. Nuclear Regulatory Commission Page 2 administrative in naturing to bring the CPS TS in alignment with the standard TS. No additional response time tests are eliminated by the proposed change.

provides a description and assessment of the proposed changes. Attachment 2 provides the existing TS pages marked-up to show the proposed TS changes. Attachment 3 provides TS Bases pages marked up to show the associated TS Bases changes and is provided for information only.

The proposed change has been reviewed by the CPS Plant Operations Review Committees, in accordance with the requirements of the CEG Quality Assurance Program.

CEG requests approval of the proposed license amendment by January 12, 2024. Once approved, the amendment shall be implemented within 60 days of the approval date.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), a copy of this application, with attachments, is being provided to the designated State Officials.

There are no regulatory commitments contained in this submittal. Should you have any questions concerning this submittal, please contact Ms. Rebecca L. Steinman at (630) 657-2831.

I declare under penalty of perjury that the foregoing is true and correct. This statement was executed on the 13th day of January 2023.

Respectfully, Patrick R. Simpson Sr. Manager Licensing Constellation Energy Generation, LLC Attachments:

1. Evaluation of Proposed Changes

2. Mark-up of Technical Specifications Pages

3. Mark-up of Technical Specifications Bases Pages - For Information Only cc:

NRC Regional Administrator, Region III NRC Senior Resident Inspector, Clinton Power Station NRC Project Manager, Clinton Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1 Evaluation of Proposed Changes

Subject:

Application to Adopt TSTF-332, Revision 1, "ECCS Response Time Testing" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Applicability 2.2 Variations 2.3 Detailed Description of Proposed Change

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration 4.3 Precedent 4.4 Conclusion

6.0 REFERENCES

ATTACHMENT 1 Evaluation of Proposed Changes

1.0

SUMMARY

DESCRIPTION Boiling Water Reactor Owners' Group (BWROG) topical report, NEDO-32291-A, "System Analyses for Elimination of Selected Response Time Testing Requirements," October 1995 (Reference 6.3), and NEDO-32291-A, Supplement 1, October 1999 (Reference 6.4) provide analyses that support the elimination of certain sensor response time tests by demonstrating that other Technical Specification testing requirements and actions taken in response to NRC Bulletin 90-01, Supplement 1 are sufficient to identify failure modes or degradation in instrument response times and assure operation of the analyzed instrument loops within acceptable limits.

Clinton Power Station (CPS) previously received approval via a license amendment (No. 98, Reference 6.5) to eliminate certain sensor response time testing requirements as allowed by NEDO-32291. The current proposed change would revise TS definitions for ECCS RESPONSE TIME, ISOLATION SYSTEM RESPONSE TIME, and RPS RESPONSE TIME to incorporate standardized wording that was adopted into the standard TS after CPS Amendment No. 98 was received. The proposed change also moves Notes that were added by Amendment No. 98 to the Bases, consistent with the current standard technical specifications and TSTF-332 (Reference 6.6). By revising the definitions for response time testing and the associated implementing SR Bases, the details of which channel sensors are measured, and which are allowed to be assumed can be delineated in a manner similar to the standard TS.

2.0 DETAILED DESCRIPTION 2.1 Applicability The NRC did not separately document their approval of TSTF-332-A, Revision 1 (Reference 6.6) with a model Safety Evaluation. However, the TS changes associated with this Traveler were incorporated into NUREG-1434 Revision 2. CPS has reviewed TSTF-332-A, Revision 1 and has determined that the proposed change and associated justification are applicable to CPS Unit 1 and justify this amendment for the incorporation of the change to the CPS TS.

2.2 Variations TSTF-332 proposes mark-ups for the three TS 1.0 Definitions as well as the Bases for Surveillance Requirements (SRs) 3.3.1.1.17 (RPS Instrumentation), 3.3.5.1.7 (ECCS Instrumentation), 3.3.6.1.7 (Primary Containment Isolation Instrumentation), 3.3.6.2.6 (Secondary Containment Instrumentation), and 3.6.4.1.4 (Secondary Containment).

Amendment No. 98 moved the requirements of SR 3.3.5.1.6 (numbered 3.3.5.1.7 in the Traveler) to the ECCS-Operating TS as SR 3.5.1.8. CPS TS 3.3.6.1 is titled Primary Containment and Drywell Isolation Instrumentation. CPS TS 3.3.6.2 does not contain a response time related SR, so that Traveler change is not applicable to CPS. And the Bases for SR 3.6.4.1.4 already reflect the Traveler proposed wording. These variations are administrative in nature and do not impact the applicability of the Traveler to CPS.

ATTACHMENT 1 Evaluation of Proposed Changes

Page 3 2.3 Detailed Description of Change The proposed change would revise TS 1.1 Definitions for ECCS RESPONSE TIME, ISOLATION SYSTEM RESPONSE TIME, and RPS RESPONSE TIME adding the following clarifying sentence to the end of the existing definition text.

In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

Additionally, the notes added to Surveillance Requirements (SRs) 3.3.1.1.17, 3.3.6.1.7, and 3.5.1.8 by Reference 6.5 are being deleted with the relevant information regarding the exclusions being reflected in the Bases instead of the TS, which is in accordance with the approved Traveler. CPS will make the supporting changes to the TS Bases in accordance with TS 5.5.10, "Technical Specifications (TS) Bases Control Program."

contains a marked-up version of the TS showing the proposed changes. provides the marked-up TS Bases pages. The TS Bases mark-up pages are being submitted for information only.

3.0 TECHNICAL EVALUATION

CPS Amendment No. 98 referenced the January 1994 version of NEDO-32291 and the associated NRC Safety Evaluation (SE) dated December 28, 1994 (Reference 6.5).

Reference 6.2 was approved based on the conclusion in Reference 6.1 that there is a bounding time beyond which response time degradation can be detected during the performance of calibrations and other currently required surveillance tests. Reference 6.1 states that appropriate alternatives to Response Time Testing (RTT) were provided in accordance with Regulatory Guide 1. 118, Revision 2, and IEEE 338-1977. CPS Amendment No. 98 eliminated RTT for selected instrument channels based on the analyses in a previous version of Reference 6.1 (see ADAMS Accession No. 9401180019) but is consistent with the NRC approved version of NEDO-32291. Therefore, the wording changes in TSTF-332 that complement the previously approved RTT eliminations are appropriate and applicable to the CPS TS. Since no new RTT eliminations are proposed this request is considered administrative in nature with the primary intent of bringing the CPS TS wording into alignment with both the STS and other sites within the CEG fleet.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed change does not affect conformance with any General Design Criteria (GDC) differently than described in the Clinton Power Station Updated Final Safety Analysis Report (UFSAR). Applicable regulatory requirements will continue to be met, adequate defense-in-depth will be maintained, and sufficient safety margins will be maintained.

ATTACHMENT 1 Evaluation of Proposed Changes

Page 4 4.2 Precedents The NRC approved TSTF-332-A, Revision 1, on September 25, 2000 (Reference 6.6), two years after the approval of CPS Amendment No. 98. Although there is no precedent for adoption of TSTF-332 separate from the RTT elimination effort associated with the adoption of NEDO-32291, several of the RTT elimination amendments (see ADAMS Accession No. ML022490062 for Fermi 2 example) or ITS conversion amendments approved after 2000 reference TSTF-332 (See ADAMS Accession 011630058 for FitzPatrick example).

4.3 No Significant Hazards Consideration Overview CEG requests adoption ofTSTF-332, "ECCS Response Time Testing," Revision 1 (Reference 6.6), an approved change to the Improved Standard Technical Specifications (ISTS), into the CPS Unit 1Technical Specifications (TS). The proposed change would revise TS definitions for ECCS RESPONSE TIME, ISOLATION SYSTEM RESPONSE TIME, and RPS RESPONSE TIME to incorporate standardized wording that was developed after CPS Amendment No. 98 (eliminated certain response time testing requirements) was approved. The proposed change also moves Notes that were added by Amendment No. 98 to the Bases, consistent with the current standard technical specifications and TSTF-332.

CEG has evaluated the proposed change against the criteria of 10 CFR 50.92(c) to determine if the proposed changes result in any significant hazards. The following is the evaluation of each of the 10 CFR 50.92(c) criteria:

1.

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

Response

No The proposed administrative changes to the definitions and the Notes bring the CPS TS into alignment with the standard TS without altering the technical basis (i.e., the previously approved testing eliminations). This has no impact on the response time assumptions used in the accident analyses or the methodology current used for response time verification.

Since the proposed change will not result in the modification of any system interface that would increase the likelihood of an accident and will not change, degrade, or prevent actions, or alter any assumptions previously made in evaluating the radiological consequences of an accident, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

Response

No

ATTACHMENT 1 Evaluation of Proposed Changes

Page 5 The proposed action does not involve physical alteration of the station. No new equipment is being introduced, and installed equipment is not being operated in a new or different manner.

There is no change being made to the parameters within which Clinton is operated. There are no setpoints at which protective or mitigative actions are initiated that are affected by this proposed action. Additionally, the proposed change does not alter assumptions made in the safety analysis.

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

3.

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

Response

No The administrative changes to the TS have no impact on the plant and system response to an initiating event, which will remain in compliance with the assumptions of the safety analysis.

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

3.3 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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

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 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.

6.0 REFERENCES

6.1 NEDO-32291, "Systems Analyses for the Elimination of Selected Response Time Testing Requirements, dated January 1994 (ADAMS Accession No. 9401180019)

ATTACHMENT 1 Evaluation of Proposed Changes

Page 6 6.2 NRC Letter from B.A. Boger (U.S. NRC) to R.A. Pinelli (BWROG), "BWR Owners Group Licensing Topical Report NEDO-32291, 'System Analyses for Elimination of Selected response Time Testing Requirements,' January 1994," dated December 28, 1994 (ADAMS Accession No. 9504200180 [letter also available as ML20082K967] and 9501060219 XA [SE also available as ML20080D815])

6.3 NEDO-32291-A, "Systems Analyses for the Elimination of Selected Response Time Testing Requirements, dated October 1995 6.4 NEDO-32291-A, Supplement 1, " Systems Analyses for the Elimination of Selected Response Time Testing Requirements, dated October 1999 (ADAMS Accession No. ML993350325) 6.5 Letter from D.V. Pickett (U.S. NRC) to R.F. Phares (Clinton Power Station), Issuance of Amendment No. 98 to Facility Operating License No. NPF Clinton Power Station, Unit 1 (TAC No. M91387), dated March 9, 1995 (ADAMS Accession No. 9503160321) 6.6 TSTF-332, Revision 1, "ECCS Response Time Testing," dated September 25, 2000 (ADAMS Accession No. ML003751434)

ATTACHMENT 2 CLINTON POWER STATION UNIT 1 Docket No. 50-461 Facility Operating License No. NPF-62 MARK-UP OF CPS, UNIT 1 TECHNICAL SPECIFICATIONS PAGES 1.0-4 to 1.0-6 3.3-6 3.3-54 3.5-6

Definitions 1.1 CLINTON 1.0-4 Amendment No. 240 Definitions DRAIN TIME

1. Penetration flow paths connected to an (continued) intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation devices without offsite power.

c. The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;

d. No additional draining events occur; and

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

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

EMERGENCY CORE COOLING The ECCS RESPONSE TIME shall be that time interval SYSTEM (ECCS) RESPONSE from when the monitored parameter exceeds its ECCS TIME initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

(continued)

In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

Definitions 1.1 CLINTON 1.0-5 Amendment No. 242 1.1 Definitions (continued)

END OF CYCLE The EOC-RPT SYSTEM RESPONSE TIME shall be that RECIRCULATION PUMP TRIP time interval from initial movement of the (EOC-RPT) SYSTEM RESPONSE associated turbine stop valve or turbine TIME control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

ISOLATION SYSTEM The ISOLATION SYSTEM RESPONSE TIME shall be that RESPONSE TIME time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE

1. LEAKAGE into the drywell such as that from pump seals or valve packing, that is captured and conducted to a sump or collecting tank; or

2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems;

b. Unidentified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE;

c. Total LEAKAGE Sum of the identified and unidentified LEAKAGE; and

d. Pressure Boundary LEAKAGE LEAKAGE through a fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

(continued)

In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

Definitions 1.1 CLINTON 1.0-6 Amendment No. 229 1.1 Definitions (continued)

LINEAR HEAT GENERATION The LHGR shall be the heat generation rate per RATE (LHGR) unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.

LOGIC SYSTEM FUNCTIONAL A LOGIC SYSTEM FUNCTIONAL TEST shall be a test TEST of all logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

MINIMUM CRITICAL POWER The MCPR shall be the smallest critical power RATIO (MCPR) ratio (CPR) that exists in the core for each class of fuel. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.

MODE A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

OPERABLE OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of 3473 MWt.

REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval SYSTEM (RPS) RESPONSE from when the monitored parameter exceeds its RPS TIME trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

(continued)

In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

RPS Instrumentation 3.3.1.1 CLINTON 3.3-6 Amendment No. 192 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.16 Verify Turbine Stop Valve Closure and Turbine Control Valve Fast Closure Trip Oil Pressure-Low Functions are not bypassed when THERMAL POWER is > 33.3%

RTP.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.17

---

NOTES------------------

1.

Neutron detectors are excluded.

2.

For Functions 3, 4, and 5 in Table 3.3.1.1-1, the channel sensors are excluded.

Verify the RPS RESPONSE TIME is within limits.

In accordance with the Surveillance Frequency Control Program

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 CLINTON 3.3-54 Amendment No. 238 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.6.1.3 Calibrate the analog trip module.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.4 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.5 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.6 Perform LOGIC SYSTEM FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.7

---

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

Channel sensors are excluded.

Verify the ISOLATION SYSTEM RESPONSE TIME for the main steam isolation valves is within limits.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.8 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program

ECCS Operating 3.5.1 CLINTON 3.5-6 Amendment No. 244 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.5

---

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

Vessel injection/spray may be excluded.

Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.6

---

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

Valve actuation may be excluded.

Verify the ADS actuates on an actual or simulated automatic initiation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.7

---

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

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify each ADS valve actuator strokes when manually actuated.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.8

---

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

ECCS actuation instrumentation is excluded.

Verify the ECCS RESPONSE TIME for each ECCS injection/spray subsystem is within limits.

In accordance with the Surveillance Frequency Control Program

ATTACHMENT 3 CLINTON POWER STATION UNIT 1 Docket No. 50-461 Facility Operating License No. NPF-62 MARK-UP OF CPS, UNIT 1 TECHNICAL SPECIFICATIONS BASES PAGES (For Information Only)

B 3.3-29 and B 3.3-30 B 3.3-172 to B 3.3.-173 B 3.5-14 and B 3.5-15

RPS Instrumentation B 3.3.1.1 CLINTON B 3.3-29 Revision No. 14-2 BASES SURVEILLANCE SR 3.3.1.1.16 REQUIREMENTS (continued)

This SR ensures that scrams initiated from the Turbine Stop Valve Closure and Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Functions will not be inadvertently bypassed when THERMAL POWER is > 33.3% RTP. This involves calibration of the bypass channels. Adequate margins for the instrument setpoint methodology are incorporated into the actual setpoint.

If any bypass channel setpoint is nonconservative such that the Functions are bypassed at > 33.3% RTP (e.g., due to open main steam line drain(s), main turbine bypass valve(s) or other reasons), then the affected Turbine Stop Valve Closure and Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Functions are considered inoperable. Alternatively, the bypass channel can be placed in the conservative condition (nonbypass). If placed in the nonbypass condition, this SR is met and the channel is considered OPERABLE.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.1.17 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. The RPS RESPONSE TIME acceptance criteria are included in plant Surveillance procedures.

As noted, neutron detectors are excluded from RPS RESPONSE TIME testing because the principles of detector operation virtually ensure an instantaneous response time. In addition, for Functions 3, 4, and 5, the associated sensors are not required to be response time tested. For these Functions, response time testing for the remaining channel components, including the ATMs, is required. This allowance is supported by Reference 10.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

With regard to RPS RESPONSE 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. 12).

(continued)

RPS RESPONSE TIME may be verified by actual response time measurements in any series of sequential, overlapping, or total channel measurements.

if the conditions of Reference 10 are satisfied If these conditions are satisfied, sensor response time may be allocated based on either assumed design sensor response time or the manufacturer's stated design response time. When the requirements of Reference 10 are not satisfied, sensor response time must be measured.

Furthermore, measurement of the instrument loop response times for Functions 3, 4, and 5 is not required if the conditions of Reference 14 are satisfied.

RPS Instrumentation B 3.3.1.1 CLINTON B 3.3-30 Revision No. 14-2 BASES (continued)

REFERENCES

1.

USAR, Section 7.2.

2.

USAR, Section 5.2.2.

3.

USAR, Section 6.3.3.

4.

USAR, Chapter 15.

5.

USAR, Section 15.4.1.2.

6.

NEDO-23842, "Continuous Control Rod Withdrawal in the Startup Range," April 18, 1978.

7.

USAR, Section 15.4.9.

8.

Letter, P. Check (NRC) to G. Lainas (NRC), "BWR Scram Discharge System Safety Evaluation," December 1, 1980, as attached to NRC Generic Letter dated December 9, 1980.

9.

NEDO-30851-P-A, "Technical Specification Improvement Analyses for BWR Reactor Protection System,"

March 1988.

10.

NEDO-32291-A, "System Analyses for Elimination of Selected Response Time Testing Requirements," January 1994.

11.

Calculation IP-0-0002.

12.

Calculation IP-0-0024.

13.

Risk Management Document No. 1073, "Scram Discharge Volume Level Instrument Surveillance Interval Extension Risk Assessment," dated November 17, 2006.

October 1995

14. NEDO-32291-A, Supplement 1, "System Analyses for the Elimination of Selected Response Time Testing Requirements," October 1999.

Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 CLINTON B 3.3-172 Revision No. 14-2 BASES SURVEILLANCE SR 3.3.6.1.4, SR 3.3.6.1.5, and SR 3.3.6.1.8 (continued)

REQUIREMENTS responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.6.1.6 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel. The system functional testing performed on PCIVs in LCO 3.6.1.3 and on drywell isolation valves in LCO 3.6.5.3 overlaps this Surveillance to provide complete testing of the assumed safety function. (Likewise, system functional testing performed pursuant to LCO 3.7.1 overlaps this Surveillance to provide complete testing for verifying automatic actuation capability for the Division 1 and 2 SX subsystems.) The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Self Test System may be utilized to perform this testing for those components that it is designed to monitor.

SR 3.3.6.1.7 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. Testing is performed only on channels where the assumed response time does not correspond to the diesel generator (DG) start time. For channels assumed to respond within the DG start time, sufficient margin exists in the 12 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test. The instrument response times must be added to the MSIV closure times to obtain the ISOLATION SYSTEM RESPONSE TIME.

ISOLATION SYSTEM RESPONSE TIME acceptance criteria are included in applicable plant procedures.

(continued)

ISOLATION SYSTEM RESPONSE TIME may be verified by actual response time measurements in any series of sequential, overlapping, or total channel measurements.

Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 CLINTON B 3.3-173 Revision No. 14-2 BASES SURVEILLANCE SR 3.3.6.1.7 (continued)

REQUIREMENTS As noted, the associated sensors are not required to be response time tested. Response time testing for the remaining channel components, including the ATMs, is required. This is supported by Reference 7.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

With regard to ISOLATION SYSTEM RESPONSE 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).

REFERENCES

1.

USAR, Section 6.2.

2.

USAR, Chapter 15.

3.

NEDO-31466, "Technical Specification Screening Criteria Application and Risk Assessment," November 1987.

4.

USAR, Section 9.3.5.

5.

NEDC-31677-P-A, "Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation,"

June 1989.

6.

NEDC-30581-P-A, Supplement 2, "Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation," March 1989.

7.

NEDO-32291-A, "System Analyses for Elimination of Selected Response Time Testing Requirements," January 1994.

8.

Calculation IP-0-0028.

October 1995 However, the sensors for Functions 1.a, 1.b, and 1.c are allowed to be excluded from specific ISOLATION SYSTEM RESPONSE TIME measurement if the conditions of Reference 7 are satisfied.

If these conditions are satisfied, sensor response time may be allocated based on either assumed design sensor response time or the manufacturer's stated design response time. When the requirements of Reference 7 are not satisfied, sensor response time must be measured.

Furthermore, measurement of the instrument loop response time for Functions 1.a, 1.b, and 1.c is not required if the conditions of Reference 9 are satisfied. For all other Functions, the measurement of instrument loop response times may be excluded if the conditions of Reference 7 are satisfied.

9. NEDO-32291-A, Supplement 1, "System Analyses for The Elimination of Selected Response Time Testing Requirements,"

October 1999.

ECCS Operating B 3.5.1 CLINTON B 3.5-14 Revision No. 22-1 BASES SURVEILLANCE SR 3.5.1.7 (continued)

REQUIREMENTS of S/RVs provides reasonable assurance that all ADS valves will perform in a similar fashion. After the S/RVs are replaced, the relief-mode actuator of the newly-installed S/RVs will be uncoupled from the S/RV stem, and cycled to ensure that no damage has occurred to the S/RV during transportation and installation.

Following cycling, the relief-mode actuator is recoupled and the proper positioning of the stem nut is independently verified. This verifies that each replaced S/RV will properly perform its intended function.

SR 3.5.1.6 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.1.8 This SR ensures that the ECCS RESPONSE TIMES are within limits for each of the ECCS injection and spray subsystems.

The response time limits (i.e., <42 seconds for the LPCI subsystems, <41 seconds for the LPCS subsystem, and <27 seconds for the HPCS system) are specified in applicable surveillance test procedures. This SR is modified by a Note which identifies that the associated ECCS actuation instrumentation is not required to be response time tested.

This is supported by Reference 16.

Response time testing of the remaining subsystem components is required. However, of the remaining subsystem components, the time for each ECCS pump to reach rated speed is not directly measured in the response time tests. The time(s) for the ECCS pumps to reach rated speed is bounded, in all cases, by the time(s) for the ECCS injection valve(s) to reach the full-open position. Plant-specific calculations show that all ECCS motor start times at rated voltage are less than two seconds. In addition, these calculations show that under degraded voltage conditions, the time to rated speed is less than five seconds.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

With regard to ECCS RESPONSE 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. 21).

(continued)

ECCS RESPONSE TIME may be verified by actual response time measurements in any series of sequential, overlapping, or total channel measurements.

However, the measurement of instrument loop response times may be excluded if the conditions of Reference 16 are satisfied.

ECCS Operating B 3.5.1 CLINTON B 3.5-15 Revision No. 20-2 BASES (continued)

REFERENCES

1.

USAR, Section 6.3.2.2.3.

2.

USAR, Section 6.3.2.2.4.

3.

USAR, Section 6.3.2.2.1.

4.

USAR, Section 6.3.2.2.2.

5.

USAR, Section 15.2.8.

6.

USAR, Section 15.6.4.

7.

USAR, Section 15.6.5.

8.

10 CFR 50, Appendix K.

9.

USAR, Section 6.3.3.

10. 10 CFR 50.46.

11. USAR, Section 6.3.3.3.

12. Memorandum from R.L. Baer (NRC) to V. Stello, Jr.

(NRC), "Recommended Interim Revisions to LCO's for ECCS Components," December 1, 1975.

13. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

14. USAR, Table 6.3-8.

15. USAR, Section 7.3.1.1.1.4.

16. NEDO-32291-A, "System Analyses for Elimination of Selected Response Time Testing Requirements," January 1994.

17. Calculation IP-0-0044.

18. Calculations 01HP09/10/11/15, IP-C-0042.

19. Calculations 01LP08/11/14/16, IP-C-0043.

20. Calculations 01RH19/20/22/26, IP-C-0041.

21. Calculation IP-0-0024.

22.

ASME/ANSI OM-1987, Operation and Maintenance of Nuclear Power Plants, Part 1.

23.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

24.

NEDC-32945P, Clinton Power Station SAFER/GESTR-LOCA Analysis, June 2000.

October 1995