JAFP-01-0133, ITS: 3.3.4.1 Anticipated Transient Without Scram Recirulation Pump Trip (ATWS-RPT) Instrumentation

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ITS: 3.3.4.1 Anticipated Transient Without Scram Recirulation Pump Trip (ATWS-RPT) Instrumentation
ML011640036
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 04/07/1995
From:
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
-RFPFR, JAFP-01-0133
Download: ML011640036 (129)


Text

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

DISCUSSION OF CHANGES (DOCs) TO THE CTS NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC)

FOR LESS RESTRICTIVE CHANGES MARKUP OF NUREG-1433, REVISION 1, SPECIFICATION JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION 1 MARKUP OF NUREG-1433, REVISION 1, BASES JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION 1, BASES RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

3/4s \<3-1,L I JAFNPP Qiýý,

E. Dy ~ eeto 2intrumentaion sh be calibrated ed as indicati"*

The limiting conditions for opWeton for the instrumentation that monitos drywel alok detection wre given in Table 3.2-5. Tsdbe 4.2-. --

... -I ... .. . ý T SThe "lmtinlgconditions for Ope~ratio 1w th instrumnttionl Instrumentation shl be tested aind calibrated as indicated i OWha provides a feeldwate pump turbine aind mein turbine trip Tiable 4.2-6. - ,..

amgiven in Tablde 3.2-1.

The limiting conditions for operation for the instrumentation D"'14,12]. Instrumentation " be functionally tested end calibrated as

[L ,0il.

31ý that trlpla) the recirculation pumps *n a means of limiting the 33

, . Idndicated hin_ - ...

consequences of a failure to aran during an anticipated 33

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transient we given in Oiý ýsO.3 i,.SJ System logic hael be functionally tested as indicated in Table

/ The limiting conditionsl for' operation for the instrumentation Insrumtenntation " b~e dermonstraetd opeal ys ES Sthat provides accident monitoring wre given In Table 3.2-8. performance of a channiel check, channel calibration and ! )-- *

. . .... . . *  :: lin*!te ItIsindcaedin Table 4.2-8, as applicable. 33

. 4kv Emmerencv ott Luauidoltvea Trio .- Not Used The limiting conditions for operation for the instrumentation ITS " 3.3,3e that prevents damage to electrical equipment or circuits as a result of either a degraded or losa-of-voltage condition on the emergency electrical buses awe given In Table 3.2-2.

Amendment No. 8, 2446,1121, 225 53 V? qe,-IS(

JAFNPP Minimum Number of Operable Inslriment N Channel Per Trip System (Notes I &2) Applicable Modes tfo 1.3.41.0J 2 Reactor Pressure - High 5 Upsg. or Run r9t.oov CE.

o3.3-4.1-ul 2 Reactor Water Level - Low Low '105.4 in. Run rtr1Vi

/-j Amendment No. 22,L287, 264 76a 24CF REVzIO REVISION F

AL JAFHPP . D NOTES FOR TABLE 3.2-7 &

1 \

.341" 1. There shell be two operable or tripped trip systems for each Trip unction, except as provided for below:

a sone less cwFunctionieftwith For each Trip ,* Idthesvl~e NjjjthJ mnimuqi ruiredn thle rable Instrum c.onlilloof within tdppednumber place the-nereactor nnels, place n*lermlse, in Me slan Inoperable INF a-4 . Isioen ly sufficient Instrument channels remain ope ible or tdpped to maintain trip capablity In I Trip Function. and

1) Witin one hour, the Inoperable Instrument channel(s) In trip system ardor tat tip systenl In the red conlon, and
2) Within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, D If any of these three conditions cannot be satisfied, place the reactor in the start- standby mode within the next 6 hou., .,

ro standby mode within the next 6 eart-upIhot , ,,.--

1nSv.jr A 4r

- - "L

, to oirin the s atest number ol Inopen Instlument . both syst mIfssh the same) ve__ /t

  • This action applies lhat ttdpsystem wilhthe
t. j L" 2. When.a channel is placed in mn Inoperable status solely for pedomnance of reured surveillances, entry Into associated Umiting the associated Trip Function maintains ATWS Conditlons for Operation and required actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided Amendment No. 237 76b P";, '~~

REVISION F

c

.9 Al

  • lg lSO.

I ~ l II- .. .. -- i--I_

The ATWS Reactor Pressure HI1 r6 f 3, 5.qr,q3 3. 4 The selpoint shall be s Amendmenll No. 237 76c P,2-7'- 4t " -(-- 6 REVISION F

4f cAA'%3.`-4.

JAFNPP I '"

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Ott 0 MMM M- "-*=nwdl Ziiim-- m Avidw --

Alrum MEN -Fý FUNCTION *CHANNEL CHANNEL TRIP UNIT CAUBRATION CHANNEL CALIBRATION CHECK FUNCTIONAL C51L3 ýlilfl -TEST)

I Reactor PmssufrsHI Reacor Waler Level-Low Low Amendmen No. Ap. A6,$.. )Ai, 227 85 5a(

S Q (0

I I 6.

I

.5 z

A VN..

Am 7-3 7

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation DISCUSSION OF CHANGES (DOCs) TO THE CTS

DISCUSSION OF CHANGES ITS SECTION 3.3.4.1: ATWS-RPT INSTRUMENTATION ADMINISTRATIVE CHANGES Al In the conversion of the James A. FitzPatrick Nuclear Power Plant (JAFNPP) Current Technical Specification (CTS) to the proposed plant specific Improved Technical Specifications (ITS) certain wording preferences or conventions are adopted which do not result in technical changes. Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the conventions in NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4",

Revision 1 (i.e., Improved Standard Technical Specifications (ISTS)).

A2 This change proposes to add a Note to CTS Table 3.2-7 which allows separate Condition entry for each channel. The Note is reflected in ITS 3.3.4.1 ACTIONS Table ("Separate Condition entry is allowed for each channel."). This change provides more explicit instructions for proper application of the Actions for Technical Specification compliance. In conjunction with the proposed Specification 1.3 "Completion Times." this Note provides direction consistent with the intent of the current Required Actions for inoperable ATWS-RPT channels, functions or recirculation pump breakers. It is intended that each Required Action be applied regardless of it having been applied previously for other inoperable ATWS-RPT channels, functions or recirculation pump breakers.

A3 Not Used.

A4 Not Used.

A5 Not Used.

A6 CTS Table 3.2-7 Footnote (**) provides guidance in applying the Required Actions of CTS Table 3.2-7 Note 1.b. This Footnote is not retained in the ITS. ITS LCO 3.3.4.1 and the proposed ACTIONS will provide proper guidance in the appropriate actions to take when one or more channels are inoperable. Therefore this explicit clarification is not retained in the ITS, and this change is considered administrative since no technical requirements are affected. This change is consistent with NUREG-1433, Revision 1.

A7 CTS Table 3.2-7 includes a "Trip Level Setting" column. The settings for the Reactor Pressure-High and Reactor Water Level Low Low Functions are included in this column. In ITS SR 3.3.4.1.4, the "Allowable Values" are specified.

The CTS "trip level settings" are considered the "Allowable Values" as described in the ITS since the instrumentation is considered inoperable if the value is exceeded when either the CTS or the ITS is applicable.

JAFNPP Page 1 of 8 Revision F

DISCUSSION OF CHANGES ITS SECTION 3.3.4.1: ATWS-RPT INSTRUMENTATION ADMINISTRATIVE CHANGES A7 (continued)

A detailed explanation of trip setpoints, allowable values and analytical limits as they relate to instrumentation uncertainties is provided below. Trip setpoints are those predetermined values of output at which an action is expected to take place. The setpoints are compared to the actual process parameter and when the measured output value of the process parameter exceeds the setpoint in either the increasing or decreasing direction, the associated device (e.g., trip unit) changes state.

The trip setpoints are specified in the setpoint calculations, are derived from the analytical limits, and account for all worst case applicable instrumentation uncertainties (e.g., drift, process effects, calibration uncertainties, and severe environmental effects as appropriate). The trip setpoints derived in this manner provide adequate protection because all expected uncertainties are accounted for in the setpoint calculations.

The setpoints specified in the setpoint calculations are selected to ensure that the actual field trip setpoints do not exceed the ITS Allowable Values (i.e., the CTS "trip level settings") between successive CHANNEL CALIBRATIONS. The CTS "trip settings" and the "ITS Allowable Values" are both the TS limit values that are placed on the actual field setpoints. The Allowable Values are derived from the trip setpoints by accounting for normal effects that would be seen during periodic surveillance or calibration. These effects are instrumentation uncertainties observed during normal operation (e.g., drift and calibration uncertainties). Accordingly, the ITS Allowable Values include all applicable instrument channel and measurement uncertainties.

A channel is inoperable if its actual field trip setpoint is not within its required ITS Allowable Value.

The analytical limits are derived from the limiting values of the process parameters obtained from the safety analysis or other appropriate documents.

These "Trip Level Settings" or "Allowable Values" have been established consistent with the NYPA Engineering Standards Manual, IES-3A, "Instrument Loop Accuracy and Setpoint Calculation Methodology." The methodology used to determine the "Allowable Values" are consistent with the methodology discussed in ISA-$67.04-1994, Part II, "Methodologies JAFNPP Page 2 of 8 Revision F

DISCUSSION OF CHANGES ITS SECTION 3.3.4.1: ATWS-RPT INSTRUMENTATION ADMINISTRATIVE CHANGES A7 (continued) for the Determination of Setpoints for Nuclear Safety-Related Instrumentation." This change revises the terminology used in the CTS from "Trip Level Setting" to "Allowable Value". Since the instrumentation will be declared inoperable at the same numerical value, this change is considered administrative. This change is consistent with NUREG-1433, Revision 1.

A8 CTS 3.2.G makes reference to the limiting conditions for operations for the instrumentation that trip(s) the recirculation pumps in CTS Table 3.2-7. CTS 4.2.G requires the Recirculation Pump Trip instrumentation to be functional tested, calibrated and to test the associated logic as indicated in Table 4.2-7. This cross-reference to the Tables has been deleted since ITS 3.3.4.1 does not include a Table. All of the technical requirements of CTS Tables 3.2-7 and 4.2-7 are included in the ITS 3.3.4.1 LCO, Applicability, and Surveillances. Since this change simply deletes this cross-reference, this change is considered administrative. This change is consistent with NUREG-1433, Revision 1.

A9 The ATWS Reactor Pressure - High Setpoint is modified by Note 3 to CTS Table 3.2-7 according to the number of SRVs that are out of service.

Similarily, the corresponding ITS SR 3.3.4.1.4 also modifies the setpoint according to the number of SRVs that are out of service. The presentations are technically equivalent between the CTS and the ITS; however, the CTS presentation has been slightly reworded to provide a revised presentation in translating these requirements from the CTS to the ITS perspective. Specifically, since the JAFNPP design includes 11 SRVs, the CTS wording of "zero or one SRVs are out of service" is equivalent to the proposed ITS wording of "Ž 10 SRVs are OPERABLE" and the CTS wording of "two or more SRVs are out of service" is equivalent to the proposed ITS wording of "< 10 SRVs OPERABLE." Accordingly, this change is considered administrative.

TECHNICAL CHANGES - MORE RESTRICTIVE M1 CTS Table 4.2-7 requires a daily performance of an ATWS-RPT Channel Check. ITS SR 3.3.4.1 will require this test to be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The purpose of the Channel Check is to ensure that a gross failure of instrumentation has not occurred. Thus, performance of the channel check helps to ensure that an undetected outright channel failure is limited to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This change is consistent with NUREG 1433, Revision 1.

JAFN1PP Page 3 of 8 Revision F

DISCUSSION OF CHANGES ITS SECTION 3.3.4.1: ATWS-RPT INSTRUMENTATION TECHNICAL CHANGES MORE RESTRICTIVE (continued)

M2 This change replaces the setpoints or Allowable Values (A7) in CTS Table 3.2-7, Reactor Pressure - High r 1120 psig and : 1155 psig with : 1118 psig and < 1153 psig, respectively (ITS SR 3.3.4.1.4, Reactor Pressure High). The Allowable Values (to be included in the Technical Specifications) and the Trip Setpoints (to be included in plant procedures) have been established consistent with the NYPA Engineering Standards Manual, IES-3A, "Instrument Loop Accuracy and Setpoint Calculation Methodology." The methodology used to determine the "Allowable Values" are consistent with the methodology discussed in ISA S67.04-1994, Part II, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation." The proposed value will ensure the most limiting requirement is met. All design limits, applied in the methodologies, were confirmed as ensuring that applicable design requirements of the associated system is maintained.

M3 A NOTE (ITS 3.3.4.1 Required Action A.2 Note) has been added to CTS Table 3.2-7 Note l.a which specifies that the action to place a channel in trip is not applicable if the inoperable channel is a result of an inoperable breaker. If a breaker is inoperable for opening, ATWS-RPT trip capability is not maintained for the associated operating recirculation pump, therefore placing the channel in trip would not be an appropriate action to take since tripping the channel would not cause the inoperable breaker to trip. In this condition, the action should be taken according to CTS Table 3.2-7 Note 1; however, the CTS does not explicitly prohibit placing a channel in a tripped condition for this situation. Therefore, a NOTE, as described above, has been added to the CTS Table 3.2-7 Note l.a. Accordingly, the addition of this NOTE to the CTS is considered a more restrictive change. This change is consistent with NUREG-1433, Revision 1.

TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC)

LA1 The detail in CTS Table 3.2-7 that the Trip Level Setting of the Reactor Water Level - Low Low Trip Function is referenced from the Top of Active Fuel (TAF) is proposed to be relocated to the Bases. CTS 1.0.Z definition specifies that the Top of Active Fuel, corresponding to the top of the enriched fuel column of each fuel bundle, is located 352.5 inches above vessel zero, which is the lowest point in the inside bottom of the reactor pressure vessel. (See General Electric drawing No.

919D690BD). These details are also proposed to be relocated to the Bases. The requirement in ITS LCO 3.3.4.1 that the ATWS instrumentation for each Function in Table 3.3.4.1-1 shall be OPERABLE, the requirements in the Table including the Allowable Value, the definition of Operability, the proposed Actions, and Surveillance Requirements are JAFNPP Page 4 of 8 Revision F

DISCUSSION OF CHANGES ITS SECTION 3.3.4.1: ATWS-RPT INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC)

LA1 (continued) adequate to ensure the instrumentation is properly maintained. In addition, the Bases includes a statement that the Allowable Value is referenced from a level of water 352.56 inches above the lowest point in the inside bottom of the reactor pressure vessel and also corresponds to the top of a 144 inch fuel column. As such, these details are not required to be in the ITS to provide adequate protection of public health and safety. Changes to the Bases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the ITS.

LA2 The details in CTS Table 3.2-7 foot note(*), relating to placing channels in trip, are proposed to be relocated to the Bases. The ACTIONS of ITS 3.3.4.1 ensure inoperable channels are placed in trip or the unit is placed in a non-applicable MODE or condition, as appropriate. In addition, the Bases for Required Actions A.1 and A.2 indicate that the channels are not required to be placed in the trip condition, and directs entry into the appropriate Condition. As a result, these relocated details are not necessary for ensuring the appropriate actions are taken in the event of inoperable ATWS-RPT Instrumentation channels. As such, these relocated details are not required to be in the ITS to provide adequate protection of the public health and safety. Changes to the Bases will be controlled by the provisions of the proposed Bases Control Program described in Chapter 5 of the ITS.

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li CTS Table 3.2-7 Note l.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to place an inoperable instrument channel in trip if one channel is inoperable for one or more Trip Functions. ITS 3.3.4.1 ACTION A will allow 14 days to restore channel to operable status or to to place the associated channel in trip. The JAFNPP ATWS-RPT logic consists of two trip systems to complete the "Reactor Low Level" trip function and two trip systems to complete the "Reactor High Pressure" trip function. Each trip function consists of two trip systems in series. The actuation of both trip systems in either the reactor low level logic, or the reactor high pressure logic will result in a trip of both recirculation pumps. Each trip system consists of two instrument channels in a parallel configuration. With a one-out-of-two-taken-twice trip logic arrangement M for each trip function, a situation with a single channel being inoperable in one or both trip systems for either or both trip functions will not inhibit a recirculation pump trip during an ATWS event.

JAFNPP Page 5 of 8 Revision F "'

DISCUSSION OF CHANGES ITS SECTION 3.3.4.1: ATWS-RPT INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li (continued)

Accordingly, the ATWS-RPT trip capability is maintained during this situation. Because of the diversity of sensors available to provide trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low probability of an event requiring the initiation of ATWS-RPT, 14 days is provided to restore (ITS 3.3.4.1 Required Action A.1) or place the inoperable channel in trip (ITS 3.3.4.1 Required Action A.2). The allowance to restore the channels to OPERABLE status is consistent with CTS 3.0.B (In the event the LCO is restored prior to expiration of the time interval, completion of the ACTION statement is not required) and proposed ITS LCO 3.0.3, therefore this portion of the change is considered administrative. This change is consistent with the Completion Times used in an analysis (GENE-770-06-1-A) to extend certain out of service times for test and repair and is consistent with NUREG-1433, Revision 1 (see DOC L2 for the bases for concluding that this analysis is acceptable for use at the JAFNPP). The JAFNPP logic design is similar to the BWR-4 design used in the analysis therefore this change is acceptable.

L2 CTS Table 3.2-7 Note 1.b provides the Required Actions when two or more channels are inoperable for one or more Functions. CTS Table 3.2-7 Note 1.b.2) requires that the instrument channel(s) in one trip system and/or that trip system be in the tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. CTS Table 3.2-7 Note 1.b.3) requires the remaining channel in the other trip system to be restored to Operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In addition, Note 1.b.1) will allow only one hour to restore trip capability for each Function. ITS 3.3.4.1 Required Action B.1 will require the restoration of ATWS-RPT trip capability in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, if one Functions trip capability is not maintained. In addition, ITS 3.3.4.1 Required Action C.1 will require the restoration of ATWS-RPT trip capability within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, if both Functions have lost trip capability. If two channels are inoperable for the same Function and trip capability is maintained, ITS 3.3.4.1 ACTION A applies and 14 days is allowed to restore (Required Action A.1) or trip (Required Action A.2) the channel.

This change is clearly less restrictive for several reasons. The ITS will allow 14 days to restore or place a channel in trip if trip capability is maintained and if one or more channels are inoperable for the same Function, while the CTS allows only 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to place a channel in trip. ITS ACTION B will allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore ATWS-RPT trip capability if one Function is inoperable, while the CTS will only allow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. ITS ACTION C allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to restore ATWS-RPT trip capability JAFNPP Page 6 of 8 Revi si on F

DISCUSSION OF CHANGES ITS SECTION 3.3.4.1: ATWS-RPT INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 (continued) for one Function when both Functions are not maintaining ATWS-RPT trip capability, while CTS will require entry into CTS 3.0.C.

These changes are acceptable for the following reasons:

1) Because of the diversity of sensors available to provide trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low probability of an event requiring the initiation of ATWS-RPT, the 14 days is provided to restore or place a channel in the trip condition with one or more channels inoperable as long as trip capability is maintained for each Function.
2) The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is sufficient for the operator to take corrective action and takes into account the likelihood of an event requiring actuation of the ATWS-RPT instrumentation during this period and that one Function is still maintaining ATWS-RPT trip capability.
3) The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is sufficient for the operator to take corrective action and takes into account the likelihood of an event requiring actuation of the ATWS-RPT instrumentation during this period.

These changes are consistent with the Completion Times used in an analysis (GENE-770-06-1-A) to extend certain out of service times for test and repair and is consistent with NUREG-1433, Revision 1. The JAFNPP logic design is similar to the BWR-4 design used in the analysis therefore this change is acceptable. The NRC, in their letter dated July 21, 1992, from Charles E. Rossi, Division of Operational Events Assessment to R. D. Binz IV, Chairman of the BWR Owner's Group, approved the above referenced General Electric Topical Report GENE-770-06-1. In the NRC's letter, the Staff concluded that the analyses presented in the Topical Report was acceptable for supporting Licensee's proposed Technical Specification changes subject to the conditions noted in their letter. These conditions were:

1. Confirmation of the applicability of the generic analysis to the plant.
2. Confirmation that any increase in instrument drift due to the extended surveillance test intervals is properly accounted for in the setpoint calculation methodology.

JAFNPP Page 7 of 8 Revision F

DISCUSSION OF CHANGES ITS SECTION 3.3.4.1: ATWS-RPT INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 (continued)

A review of this matter has been completed. The Licensee has concluded that the generic analysis is applicable to the JAFNPP and that the setpoint calculation methodology properly accounts for the effects of increased instrument drift associated with the extended surveillance test intervals. Accordingly, use of the Topical Report to support these Technical Specification changes is acceptable.

L3 CTS Table 3.2-7 Note l.a, and Note 1.b requires that the reactor be placed in startup/hot shutdown mode within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if the associated Required Actions are not met. ITS 3.3.4.1 Required Action D.2 (Be in MODE 2) provides the same requirement as the CTS but an alternative Required Action has been added to the CTS. ITS 3.3.4.1 Required Action D.1 will allow the affected recirculation pump be removed from service.

This action will accomplish the Safety Function of the ATWS-RPT instrumentation and enables continued operation. This change is acceptable since JAFNPP has been analyzed to operate in single loop operation as allowed by CTS 3.5.K, Single-Loop Operation, and proposed ITS 3.4.1, Recirculation Loops Operating. Therefore, this action can only be taken if the inoperability is associated with one RPT breaker.

If the inoperability is associated with the instrumentation, then the only alternative is to be in MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. For clarity a NOTE (ITS 3.3.4.1 Required Action D.1 Note) has been added which specifies that the action to remove the affected recirculation pump from service is only applicable if the inoperable channel is the result of an inoperable RPT breaker. This note prevents the operator from removing both recirculation pumps from service under the most likely scenario where ATWS-RPT Instrumentation trip capability is not maintained for one or more functions as a consequehce of inoperable instrumentation. This change is consistent with NUREG-1433, Revision 1 as modified by TSTF 297 RI.

TECHNICAL CHANGES - RELOCATIONS None JAFNPP Page 8 of 8 Revi si on F

j JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC) FOR LESS RESTRICTIVE CHANGES

-d NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.4.1 - ATWS-RPT INSTRUMENTATION TECHNICAL CHANGE - LESS RESTRICTIVE (SPECIFIC)

Li CHANGE New York Power Authority has evaluated the proposed Technical Specification change identified as "Technical Changes - Less Restrictive" and has determined that it does not involve a significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The bases for the determination that the proposed change does not involve a significant hazards consideration are discussed below.

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

This change extends the Completion Time for one inoperable channel in one or more Functions from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days. The ATWS-RPT instrumentation is not assumed to be an initiator of any analyzed event.

Therefore, this change does not significantly increase the probability of a previously analyzed accident. With one channel inoperable, ATWS RPT continues to maintain its trip capability. The ATWS-RPT Instrumentation's functions is to mitigate the consequences of an ATWS event by tripping the reactor recirculation pumps. Therefore the need for this Function is only required if the Reactor Protection System fails to perform its safety function. The proposed Completion Time is acceptable because of the diversity of sensors available to provide trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low probability of an event requiring the initiation of ATWS-RPT. This change is consistent with the Completion Times used in an analysis (GENE-770-06-1-A) to extend certain out of service times for test and repair and is consistent with NUREG-1433, Revision 1. The JAFNPP logic design is similar to the BWR-4 design used in the analysis therefore this change is acceptable. The consequences of an ATWS event occurring during the proposed Completion Time is the same as the consequences of an event occurring during the current 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowance, therefore this change does not significantly increase the consequences of an accident previously analyzed.

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

The proposed change introduces no new mode of plant operation and it does not involve physical modification to the plant. Therefore, it does not create the possibility of a new or different kind of accident from any accident previously evaluated.

JAFNPP Page 1 of 7 Revision A

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.4.1 - ATWS-RPT INSTRUMENTATION TECHNICAL CHANGE - LESS RESTRICTIVE (SPECIFIC)

Li CHANGE

3. Does this change involve a significant reduction in a margin of safety?

This change extends the Completion Time for one inoperable channel in one or more Functions from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days. With one channel inoperable, ATWS-RPT continues to maintain its trip capability. The ATWS-RPT Instrumentation's functions is to mitigate the consequences of an ATWS event by tripping the reactor recirculation pumps. Therefore the need for this Function is only required if the Reactor Protection System fails to perform its safety function. The proposed Completion Time is acceptable because of the diversity of sensors available to provide trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low probability of an event requiring the initiation of ATWS-RPT. This change is consistent with the Completion Times used in an analysis (GENE-770-06-1 A) to extend certain out of service times for test and repair and is consistent with NUREG-1433, Revision 1. The JAFNPP logic design is similar to the BWR-4 design used in the analysis therefore this change is acceptable. The consequences of an ATWS event occurring during the proposed Completion Time is the same as the consequences of an event occurring during the current 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowance, therefore this change does not significantly reduce the margin of safety.

JAFNPP Page 2 of 7 Revision A

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.4.1 - ATWS-RPT INSTRUMENTATION TECHNICAL CHANGE LESS RESTRICTIVE (SPECIFIC)

L2 CHANGE New York Power Authority has evaluated the proposed Technical Specification change identified as "Technical Changes - Less Restrictive" and has determined that it does not involve a significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The bases for the determination that the proposed change does not involve a significant hazards consideration are discussed below.

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

The proposed change extends the time to restore or place a channel in trip from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 14 days (when more than one channel for one or two Functions are inoperable) as long as Trip capability is maintained. In addition, the proposed change extends the Completion Time from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, if trip capability is not maintained for one trip Function and allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to restore trip capability for one trip function when both functions have lost trip capability. The ATWS-RPT instrumentation is not assumed to be an initiator of any analyzed event. Therefore, this change does not significantly increase the probability of a previously analyzed accident. The ATWS-RPT Instrumentation's functions is to mitigate the consequences of an ATS event by tripping the reactor recirculation pumps. Therefore the need for this Function is only required if the Reactor Protection System fails to perform its safety function. These changes are acceptable for the following reasons: 1)

Because of the diversity of sensors available to provide trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low probability of an event requiring the initiation of ATWS-RPT, the 14 days is provided to restore or place a channel in the trip condition with one or more channels as long as trip capability is maintained for each Function: 2) The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is sufficient for the operator to take corrective action and takes into account the likelihood of an event requiring actuation of the ATWS RPT instrumentation during this period and that one Function is still maintaining ATWS-RPT trip capability; 3) The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is sufficient for the operator to take corrective action and takes into account the likelihood of an event requiring actuation of the ATWS-RPT instrumentation during this period.

These changes are consistent with the Completion Times used in an analysis (GENE-770-06-1-A) to extend certain out of service times for test and repair and is consistent with NUREG-1433, Revision 1. The JAFNPP logic design is similar to the BWR-4 design used in the analysis.

The consequences of an ATWS event occurring during the proposed JAFNPP Page 3 of 7 Revi sion A

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NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.4.1 - ATWS-RPT INSTRUMENTATION TECHNICAL CHANGE - LESS RESTRICTIVE (SPECIFIC)

L2 CHANGE

1. (continued)

Completion Times is bounded by the consequences for the same conditions in the current Specifications, therefore this change does not significantly increase the consequences of an accident previously analyzed.

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

The proposed change introduces no new mode of plant operation and it does not involve physical modification to the plant. Therefore, it does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

The proposed change extends the time to restore or place a channel in trip from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 14 days (when more than one channel for one or two Functions are inoperable) as long as Trip capability is maintained. In addition, the proposed change extends the Completion Time from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, if trip capability is not maintained for one trip Function and allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to restore trip capability for one trip Function when both functions have lost trip capability. The ATWS-RPT Instrumentation's function is to mitigate the consequences of an ATWS event by tripping the reactor recirculation pumps. Therefore the need for this Function is only required if the Reactor Protection System fails to perform its safety function. These changes are acceptable for the following reasons: 1) Because of the diversity of sensors available to provide trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse functions, and the low probability of an event requiring the initiation of ATWS-RPT the 14 days is provided to restore or place a channel in the trip condition with one or more channels as long as trip capability is maintained for each Function; 2)

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is sufficient for the operator to take corrective action and takes into account the likelihood of an event requiring actuation of the ATWS-RPT instrumentation during this period and that one Function is still maintaining ATWS-RPT trip capability; 3)

The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is sufficient for the operator to take corrective action and takes into account the likelihood of an event requiring actuation of the ATWS-RPT instrumentation during this period.

These changes are consistent with the Completion Times used in an JAFNPP Page 4 of 7 Revision A

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NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.4.1 - ATWS-RPT INSTRUMENTATION TECHNICAL CHANGE LESS RESTRICTIVE (SPECIFIC)

L2 CHANGE

3. (continued) analysis (GENE-770-06-1-A) to extend certain out of service times for test and repair and is consistent with NUREG-1433, Revision 1. The JAFNPP logic design is similar to the BWR-4 design used in the analysis.

Therefore, the calculated reactor shutdown failure frequency for the proposed Specification is now consistent with the values in the GENE 770-06-1-A analysis and with other BWRs. As such, any reduction in a margin of safety will be insignificant and offset by the benefits obtained from reducing the potential for plant shutdown transients and increasing the flexibility to ensure ATWS-RPT Instrumentation's high reliability is maintained.

JAFNPP Page 5 of 7 Revi si on A

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.4.1 - ATWS-RPT INSTRUMENTATION TECHNICAL CHANGE - LESS RESTRICTIVE (SPECIFIC)

L3 CHANGE New York Power Authority has evaluated the proposed Technical Specification change identified as "Technical Changes - Less Restrictive" and has determined that it does not involve a significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.02. The bases for the determination that the proposed change does not involve a significant hazards consideration are discussed below.

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

This change will allow a recirculation pump to be removed from service to satisfy the Required Actions and allow continued operation instead of placing the reactor in MODE 2. In order to reduce power, reactor recirculation flow will be reduced and control rods will be inserted to achieve MODE 2 conditions in accordance with plant procedures. If it were decided to remove one reactor recirculation pump from service similar actions would have to be taken but the major power or flow reduction will be induced by slowly lowering flow on one recirculation pump in accordance with plant procedures. The Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is sufficient to minimize the transient on the reactor and safely bring the plant to the new operating condition. Since these operations are similar to the Required Actions of a normal cooldown, this change does not significantly increase the probability of an accident previously analyzed. Removing the recirculation pump from service provides the required safety function. In addition, the plant has been analyzed to operate in single loop operation provided certain limitations are applied. ITS 3.4.1, Recirculation Loops Operating, will be applicable and certain additional actions must be taken to operate in these conditions. These actions include ensuring the Thermal Limits have been adjusted for single loop operation. In addition the Reactor Protection System (RPS) Neutron Flux-High (Flow Biased) and Rod Block Monitor-Upscale Allowable Values must be reset for single loop operation. Since the plant is analyzed for single loop operation and since the appropriate regulatory controls for this operation are included in the proposed Specifications this change is acceptable.

Therefore, this change does not significantly increase the consequences of a previously analyzed accident.

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

The proposed change introduces no new mode of plant operation and it does not involve physical modification to the plant. Therefore, it does JAFNPP Page 6 of 7 Revision A

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.4.1 - ATWS-RPT INSTRUMENTATION TECHNICAL CHANGE - LESS RESTRICTIVE (SPECIFIC)

L3 CHANGE

2. (continued) not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. Does this change involve a significant reduction in a margin of safety?

This change will allow a recirculation pump to be removed from service to satisfy the Required Actions and allow continued operation instead of placing the reactor in MODE 2. Since the plant is analyzed for single loop operation and since the appropriate regulatory controls for this operation are included in the proposed Specifications this change is acceptable. This change does not involve a significant reduction in a margin of safety since the safety function continues to be satisfied and since JAFNPP has been analyzed for single loop operation.

JAFNPP Page 7 of 7 Revision A

/

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation MARKUP OF NUREG-1433, REVISION 1 SPECIFICATION

ATWS-RPT Instrumentation

.3.3 4 3.3 INSTRUMENTATION 3.3.4CZ Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation 1.4 Two channels per trip system for each ATWS-RPT I 61 LCO instrumentation Function listed below shall be OPERABLE: '4.'

a. Reactor Vessel Water Level--Low Lowv Level *; and
b. Reactor Pressure-High.*

ITe ']* APPLICABILITY: MODE 1.

ACTIONS

'nuI TE-------------------------------

Separate Condition entry is allowed each channel.

[AZ] ------------------------------------------------------------------

CONDITION REQUIRED ACTION COMPLETION TIME A One or more channels A. I Restore channel to 14 days inoperable. OPERABLE status.

OR La- l.a.

A.2 NOTE------ -------

Not applicable if inoperable channel is K

It/ia-- the result of an inoperable breaker.

Place channel in 14 days trip.

_____________________ I -

(continued)

REVISION F 3.3-33 Rev o, 07-,95 PC

ATWS-RPT Instrumentation 3.3.4 .0 07 ngimr1 ACTIONS n"atil COMPLETION TIME CONDITION CONDITION REQUIRED ACTION B.1 Restore ATWS-RPT trip 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

.f . - B. One Function with capability.

ATWS-RPT trip capability not maintained.

C.1 Restore ATWS-RPT trip 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with capability for one 10,e 1. jC. Both Functions ATWS-RPT trip Function.

"L capability not maintained.

I I ROz 1k I

Required Action and D.1 Remove the 4{i pump D. recircul ation associated Completion from service.

Time not met.

0110-f OR D.2 Be in MODE 2.

1FF -

SURVEILLANCE REQUIREMENTS


NOTE When a channel is placed in an inoperable status solely for performance of 6(t~4 Conditions and Required Actions required Surveillances, entry into associated associated Function maintains may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the ATWS-RPT trip capability. ---------------------

oSURVEILLANCE FREQUENCY I ISR3.3.4.)ýJ Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> I) 6ý-- &

tvw 4'2ý rm1-(continued) 3.3-34 Rev 1, 04/07/95 BWR/4 STS REVISION F

)

ATWS-RPT Instrumentation 3.3.4.0 0-SURVEILLANCE REQUIREMENTS (continued)

PA' SURVEILLANCE FREQUENCY 2-61 SR 3.3.4. 2 Perform CHANNEL FUNCTIONAL TEST. 492)-faiys EDZ

ýt , q.t -7) rCL6 tu .&ý Calibrate the trip units. [?days iiS3.3.4j.3 16ý I

SR 3.3.41 *4 Perform CHANNEL CALIBRATION. The 1months Allowable Values shall be:

or" W, a. Reactor Vessel WateIrLevel-Low Lowp ) mt MIX ý7-77 Levelt 2: R(3jinchPes; andi:

b.

Reacto Pressur~e-High:

b. Riiqtr-$'gg __________

KILA{

  • L.

uY) SR 3.3.4 5 Perform LOGIC SYSTEM FUNCTIONAL TEST including breaker actuation.

U.I4mi v-i]

I-I

%ARkN0 AVE or

~~r~6~)VPIA6Er tN - L](X BWR/4 STS 3.3-35 Rev 1, 04/07/95 REVISION F

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS: 3.3.4.1 - ATWS-RPT INSTRUMENTATION RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 The brackets have been removed from the Frequency of ITS SR 3.3.4.1.2 and the 92 day Frequency retained consistent with CTS Table 4.2-7 and with the reliability analysis of GENE-770-06-1-A.

CLB2 The brackets have been removed from the Frequency of ITS SR 3.3.4.1.3 and the Frequency extended from 92 days to 184 days consistent with CTS Table 4.2-7.

CLB3 The brackets have been removed from the Frequency of ITS 3.3.4.1.5 (LSFT) and the Frequency has been extended from 18 months to 24 months consistent with CTS Table 4.2-7. This Frequency is consistent with the JAFNPP fuel cycle.

PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl The JAFNPP design does not include the EOC-RPT Trip System. Therefore ISTS 3.3.4.1 is being deleted, and the ATWS-RPT Specification (ISTS 3.3.4.2) is being renumbered as ITS 3.3.4.1.

PA2 Changes have been made to reflect the plant specific terminology.

PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB1 Not Used.

DB2 The brackets have been removed from SR 3.3.4.1.1 and the SR is being retained which is consistent with CTS Table 4.2-7. The JAFNPP design is provided with the appropriate indications to perform this SR.

DB3 The brackets have been removed from the Frequency of ITS SR 3.3.4.1.4 and the Frequency has been extended from 18 months to 24 months consistent with CTS Table 4.2-7 and the setpoint calculation methodology.

DB4 The brackets have been removed and the proper plant specific "Allowable Value" has been included consistent with the current value in CTS Table 3.2-7, and the JAFNPP plant specific setpoints methodology.

DIFFERENCE BASED ON AN APPROVED TRAVELER (TA)

TA1 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler number 297, Revision 1 have been incorporated into the revised Improved Technical Specifications.

I JAFNPP Page 1 of 2 Revision F

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433. REVISION 1 ITS: 3.3.4.1 - ATWS-RPT INSTRUMENTATION DIFFERENCE BASED ON A SUBMITTED. BUT PENDING TRAVELER (TP)

None DIFFERENCE FOR ANY REASON OTHER THAN THE ABOVE (X)

None JAFNPP Page 2 of 2 Revi si on F

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation MARKUP OF NUREG-1433, REVISION 1, BASES

ATWS-RPT Instrumentation B 3.3.4.6

.0 B 3.3 INSTRUMENTATION B 3.3.4.t Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation BACKGROUND The ATWS-RPT System initiates an RPT, adding negative reactivity, following events in which a scram does not (but should) occur, to lessen the effects of an ATWS event.

Tripping the recirculation pumps adds negative reactivity T-;, I from the increase in steam voiding in the core area as Lows core Reactor Vessel Water Level--Low IoR flow decreases. When setpoint is ......

e t.

,evel or Reactor 2iý D ý_ Pressure-High reached, the recirculatio pump drive motor breakers trip.

The ATWS-RPT System (Ref. 1) includes sensors, relays, $-&iI-i-'/

(bypass eava i circut NIEFF13 and switches that are necessary to cause initiation of an RPT. The channels include electronic equipment (e.g., trip units) that compares measured input signals with pre-established setpoints. When the setpoint is exceeded, the channel output relay actuates,.which then outputs an ATWS-RPT signal to the trip logic.

The ATWS-RPT consi s of two independen trip systems,/ith two channels of R actor Steam Dome Pre sure-High and two channels of React r Vessel Water LeveT-Low Low, Lev 1 2 in f d each trip system Each ATWS-RPT tri system is a

-1 "ltwo-out-of-two 1 gic for each Functi n. Thus, eit r two Reactor Water L el-Low Low, Level or two React r Pressure-High ignals are needed t trip a trip ystem.

outputs of either trip in he channels syste ip system a t will are ombined iný trip bot SaThelogic so th*

  • he respectivae/drive tr

'N \r~ecirculation/pums (by tri oina N kbreakers).'*

There is one drive motor breaker provided for each of the N (W* recirculation p for a total of two breakers. The ((23 output of ac r is provided to both recirculation pump breakers.

rAv okC1 l 1Ar40 (continued)

Rev 1 4/0 SB3.3-91 REVISION F

Q INSERT BKGD The ATWS-RPT logic consists of two trip systems for the Reactor Vessel Water Level-Low Low (Level 2) trip function and two trip systems for the Reactor Pressure High-trip function. Each trip system associated with the Reactor Vessel Water Level -Low Low (Level 2) Function includes two reactor water level channels while each trip system associated with the Reactor Pressure-High Function includes two reactor pressure channels. Each ATWS trip system is a one-out-of-two logic and both trip systems associated with the same function must trip for the ATWS trip logic to actuate. Therefore, the ATWS trip system logic for each Function is one-out-of-two taken twice.

The two channels in each trip system are powered from a common power supply.

For each trip function, the two channels in one trip system are powered independently from the two the channels in the other trip system (Divisions 1 and 2). The logic associated with the two trip systems for the Reactor Vessel Water Level -Low Low (Level 2) trip function and the logic associated with the two trip systems for the Reactor High Pressure-High trip function are all powered from one common power supply.

Insert Page B 3.3-91 Revision F

ATWS-RPT Instrumentation B 3.3.4.t0 BASES (continued)I - - "

APPLICABLE The ATWS-RPT is not ass d in the safety analysis. The..

SAFETY ANALYSES, ATWS-RPT initiates an Tto aid in preserving the integrity LCO, and of the fuel cladding following events in which a scram does AT _

Rduc

~~~instr

'ICABILITY t not, but-ntation O o v should, s- rj 11 p lan t includedal r i(skrequired

, instmn how e vecton r 61th

, .the/ chlouae v occur. ta NR;olic 1" 6 )

o-***

  • The OPERABILITY of the ATWS-RPT is dependent on the 9P**FmBI Y of the individual instrumentationdchanel hnOPERABILITY .

Functions. Each Function must have a required numb OPERABLE channels in each trip system, with their/setpoints

  • () /within the specified Allowable Value of SR 3.3.4. .4. The

- r

>.actual setpoint is calibrated consistent with applicable setpoint methodology assumptions. Channel OPERABILITY als includes the associated recirculation pump drive motor M&-

- _I breakers. nAc nn is inopera le if its actual trip LL s_ ointis not within its required Allowable Value.

Allowable Values are specified for each ATWS-RPT Function specified in the LCO. Nominal trip setpoints are specified in the setpolnt calculations. The nominal *setpoints are selected to ensure that the setpoints do not exceed the Allowable Value between CHANNEL CALIBRATIONS. Operation with a trip setpoint less conservative than the nominal trip setpoint, but within its Allowable Value, is acceptable.

~compared Trip setpoints are those predetermined values of output at to the actual take place.

which an action should process parameter (e.g., reactor The setpoints are value of

%'Os vessel the process level), and water parameter when the exceeds setpoint, output the measured the associated device (e.g., trip unit) changes state. The analytic limits aaaeesotie rmt ;tr' analysis.* orAllow le*

are derived from the limiting values of the process a eues arege efrom te ana y I corrected r acalibr tion, p cess, and some of the ins rument errors AsA The t p setp *nts are then determined a ounting for e remai ing Ins rument errors (e.g., drift .The trip seemtpo nts de lved inthis manner provide adequate pro ction beca se inst umentation uncertainties, rocess effec call ration olerances, instrument drif , and severe env onment errors (for channels that st function n harsh env 1-tment- as defined by 10.C fr The individual Functions are required to be OPERABLE in MODE I to protect against common mode failures of the (continued)

BWR/4 STS B 3.3-92 Rev 1, 04/07/95 REVISION F

6 INSERT ASA The trip setpoints are derived from the analytic limits and account for all worst case instrumentation uncertainties as appropriate (e.g., drift, process effects, calibration uncertainties, and severe environmental errors (for channels that must function in harsh environments as defined by 10 CFR 50.49)). The trip setpoints derived in this manner provide adequate protection because all expected uncertainties are accounted for. The Allowable Values are than derived from the trip setpoints by accounting for normal effects that would be seen during periodic serveillance or calibration. t These effects are instrumentation uncertainties observed during normal operation (e.g., drift and calibration uncertainties).

Insert Page B 3.3-92

ATWS-RPT Instrumentation B 3.3.4.V BA PPLICABLE Reactor Protection System b~yproviding a diverse trip to AF*FEY ANALYSES, mitiga~trtPhe consequences of a stulated ATWS event. The L(CO, and Reactor e Pressure- - and Reactor Vessel Water A!PPLICABILITY Level-Low Lowevel1 2 unctions are required to be (continued) OPERABLE in MODE 1, since the reactor is producing significant power and the recirculation system could be at

( high flow. During this MODE, the potential exists for Shpressure increases or low water level, assuming an ATWS event. In MODE 2, the reactor is at low power and the recirculation system is at low flow; thus, the potential is low for a pressure increase or low water level, assuming an ATWS event. Therefore, the ATWS-RPT is not necessary. In MODES 3 and 4, the reactor is shut down with all control rods inserted; thus, an ATWS event is not significant and the possibility of a significant pressure increase or low water level is negligible. In MODE 5, the one rod out interlock ensures that the reactor remains subcritical; thus, an ATWS event is not significant. In addition, the reactor pressure vessel (RPV) head is not fully tensioned and no pressure transient threat to the reactor coolant pressure boundary (RCPB) exists.

The specific Applicable Safety Analyses and LCO discussions are listed below on a Function by Function basis.

Reactor Vessel Water Level--Low Low AUevel T a.

ow V water level indicates the capability to cool the fuel may be threatened. Should RPV water level c~s,' 4 o decrease too far, fuel damage couldinitiated result. L*_+ .

is at Level 2 "

Che ATWS-RPT System y~aveAT't a . ereduction of core ow re uces the *v neutron flux andfTHERMAL POWER and, therefore, the rate of coolant boiloff.

Reactor vessel water level signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.

Four channels of Reactor Vessel Water Level-Low LowV

" with two channels in each trip system, are 2Level available and required tobe OPERABLE to ensure that VN

(continued)

B 3.3-93 Rev 1, 04/07/95 BWR/4 STS REVISION F

ATWS-RPT Instrumentation B 3.3.4.Z7-7 BASES Lowt(Level 2hr APPLICABLE a. Reactor Vessel Water Level-Low SAFETY ANALYSES, (continued)

ICO, and (

APPLICABILITY no single instrument failure can precude an ATWS-RPT from this Vessel Function Water on a valid signal. The Reactor Level-Low Low# evel llowable.Value chosen so that the system will not be initiated after a Level 3 scram with feedwater still available, and GCI-Cki* . for convenience with the reactor core isolation coo in-glinitiation.

b. Rector Pressure-High (zi--)

Excessively high RPV pressure may rupture the RCPB.

An increase in the RPV pressure during reactor operation compresses the steam voids and results in a

  • \ positive reactivity insertion. This increases neutron

)flux and THERMAL POWER, which could potentially result in fuel failure and overpressurization. The Reactor Pressure-High Function initiates an RPT for transients that result in a pressure increase, counteracting the pressure increase by rapidly reducing core power generation. For the overpressurization event, the RPT aids in the termination of the ATWS eventand, alon with safety/relief valves limits the peak RPVpressure to less than the ASME Section III Code Service Level C

________________ limits (1500 psig). fAI The Reactor $j1jiimh Pressure-High signals are

(*)nitiated from four pressure transmitters that monitor

'reactor steam dome pressure. Four channels of Reactor 0 r Pressure-High, with two channels in each trip system, are available and are required to be OPERABLE to ensure that no single instrument failure can preclude an ATWS-RPT from this Function on a valid signal. The Reactor G*flf ePressure-High )-T Allowable Value is chosen to provide an adequate margin to the ASKE Section III Code Service Level C

  • allowable Reactor Coolant System pesue ACTIONS A Note has been provided to modify the ACTIONS related to ATWS-RPT instrumentation channels. Section 1.3, Completion (continued)

BWR/4 STS B 3.3-94 Rev 1, 04/07/95 REVISION F

INSERT B 3.3.4.1-1 The Allowable Value is dependent on the number of OPERABLE S/RVs. The peak pressure resulting from an ATWS with Main Steam Isolation Valve (MSIV) closure (the limiting transient) is dependent on the power produced during the transient (which is sensitive to the ATWS-RPT Reactor Pressure-High setpoint) and the capability to remove heat from the RPV (which is sensitive to the number of operable S/RVs). The Allowable Value with Ž 10 S/RVs OPERABLE was derived from the analysis performed in Reference 4. The Allowable Value with

< 10 S/RVs OPERABLE was derived from the analysis performed in Reference 5.

INSERT Function a The Allowable Value is the water level above a zero reference level which is 352.56 inches above the lowest point inside the RPV and is also at the top of a 144 inch fuel column (Ref. 3).

The HPCI, RCIC and ATWS-RPT initiation functions (as described in Table 3.3.5.1 Function 3.a: Table 3.3.5.2, Function 1 and LCO 3.3.4.1.a including SR 3.3.4.1.4, respectively) describe the reactor vessel water level initiation function as "Low Low (Level 2)." The Allowable Values associated with the HPCI and RCIC initiation function is different from the Allowable Value associated with the ATWS-RPT initiation function as the ATWS function has a I separate analog trip unit. Nevertheless, consistent with the nomenclature typically used in design documents, the "Low Low (Level 2)" designation is retained in describing each of these three initiation functions.

Insert Page B 3.3-94 Revision F

ATWS-RPT Instrumentation B 3.3.4.2 0/ i2?ýý BASES ACTIONS Times, specifies that once a Condition has been entered, (continued) subsequent divisions, subsystems, components, or variables or expressed in the Condition, discovered to be inoperable into not within limits, will not result in separate entry the Condition. Section 1.3 also specifies that each Required Actions of the Condition continue to apply for additional failure, with Completion TimesRequired based on initial entry into the Condition. However, the Actions for inoperable AlWS-RPT instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable AlWS-RPT instrumentation channel.

A.Iand A.

With one or more channels inoperable, but with ATWS-RPT capability for each Function maintained (refer to Required Actionf B.1 *3ases), the ATWS-RPT System is capable of performing the intended function. However, the reliability and redundancy of the ATWS-RPT instrumentation hi I rip is reduced, such that a single failure in the system could result in the inability of the ATWS-RPT System to perform the intended function. Therefore, only ato limited time is allowed to restore the inoperable channels OPERABLE status. Because of the diversity of sensors available to provide trip signals, the low probabi-yof E-)

a)T extensive numbers of inoperabilities affecting a Ž-(iIyiriJ the Functions, and the low probability of an event requiring initiation of ATWS-RPT, 14 days is provided to restore the inoperable channel (Required Action A.1). Alternately, the inoperable channel may be placed in trip (Required for Action A.2), since this would conservatively compensate the inoperability, restore capability to accommodate a single failure, and allow operation to continue. As noted, is placing the channel in trip with no further restrictionsan not allowed if the inoperable channel is the result of inoperable breaker, since this may not adequately compensate for the inoperable breaker (e.g., the breaker may be inoperable such that it will not open). If it is not desired to place the channel in trip (e.g., as in the case where placing the inoperable channel would result in an RPT), or if the inoperable channel is the result of an inoperable breaker, Condition D must be entered and its Required Actions taken.

(continued)

B 3.3-95 Rev 1, 04/07/95 BWR/4 STS REVISION F

ATWS-RPT Instrumentation B 3.3.4.V B

ACTIONS (continued)

Required Action 8.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same Function result in the Function not maintaining ATWS-RPT trip capability. A Function is considered to be maintaining ATWS-RPT trip capability when sufficient channels are OPERABLE or in trip such that the ATWS-RPT System will generate a trip signal from the given Function on a valid signal, and both recirculation pumps can be tripped. This requires channelOK of the Function in

,\th-rip system to each be OPERABLE or in trip, and the (L*__3 (V ieirculation pump drive motor breakers to be OPERABLE or in trip. týD 01%.0 The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is sufficient for the operator to take corrective action (e.g., restoration or tripping of channels) and takes into account the likelihood of an event requiring actuation of the ATWS-RPT instrumentation during this period and that one Function is still maintaining 1r ATWS-RPT trip capability.

Required Action C.1 is intended to ensure that appropriate Actions are taken if multiple, inoperable, untripped channels within both Functions result in both Functions not maintaining ATWS-RPT trip capability. The description of a Function maintaining ATWS-RPT trip capability is discussed in the Bases for Required Action B.1 above.

The I hour Completion Time is sufficient for the operator to take corrective action and takes into account the likelihood of an event requiring actuation of the ATWS-RPT instrumentation during this period.

D.Iand D.2 With any Required Action and associated Completion Time not met, the plant must be brought to a MODE or other specified condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (Required Action D.2). Alternately, the associated recirculation pump may be removed from service since this (continued)

BWR/4 STS B 3.3-96 Rev 1, 04/07/95 REVISION F

ATWS-RPT Instrumentation B 3.3.44 BASES ACTIONS . (continued) performs the intended function of the instrumentation

-TAIL TAI3 (Required Action D.1). The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, both to reach MODE 2 from full power conditions and to remove a recirculation pump from service in an orderly manner and 4+4÷u "+ k 1a1 I4" + +ue÷*ww 0

SURVEILLANCE Reviewer' Note: Certain Fre ncies are based on apoe REQUIREMENTS I topical eports. In order f a licensee to use th e times the licensee must tify the Frequencies requiredI Iby e staff Safety Eval tion Report for the t ical r art .

The Surveillances are modified by a Note to indicate t a when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into the associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Function maintains ATWS-RPT trip capability. Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken. (0 This Note is based on the reliability analysis (Ref. L)1 assumption of the average time required to perform channel Surveillance. That analysis demonstrated that the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> testing allowance does not significantly reduce the probability that the recirculation pumps will trip when necessary.

Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or (continued)

BWR/4 STS B 3.3-97 Rev 1, 04/07/95 REVISION F

SDINSERT ACTIONS D.1 and D.2 Required Action D.1 is modified by a Note which states that the Required Action is only applicable if the inoperable channel is the result of an opera RPT breaker. The Note clarifies the situations under which the as cia e Required Action would be the appropriate Required Action.

Insert Page B 3.3-97 Revi si on F

ATWS-RPT Instrumentation B 3 . 3 . 4.jIF BASES SURVEILLANCE S (continued)

REQUIREMENTS something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

r*--'L_..

  • greement criteria are determined by the plant staff based S- - n a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

The Frequency is based upon operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the required channels of this LCO.

A CHANNEL FUNCTIONAL TEST is performed on each required \P?

!)/#*.,* "*_ channel to ensure intended functi on.*that the if channel will perform the Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Frequency of 92 days is based on the reliability analysis of Reference *(

Calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in SR 3.3.4. .4. If the trip setting is discovered to be less conservative than the setting accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the (continued)

BWR/4 STS B 3.3-98 Rev 1, 04/07/95 REVISION F

INSERT SR 3.3.4.1-2 A successful test of the required contacts(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

Insert Page B 3.3-98 Revi si on F

ATWS-RPT Instrumentation B 3.3.4.2 10 BP JRVEILLANCE SR33ý (continued)

SR REQUIREMENTS channel performance is still within the requirements of the setpoint plant safety analysis. Under these conditions, the than must be readjusted to be equal to or more conservative accounted for in the a priate setpoint methodology.

The Frequency of.I2 s is based on the reliability tDý o wI AC Vr u u cy A CHANNEL CALIBRATION is a complete check the of the instrument loop and the sensor. This test verifies channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel for instrument drifts between successive adjusted to account setpoint calibrations consistent with the plant specific methodology. a moh lnth The Frequency is based upon the assumption of the magnitude ab calibration interval in the determination of of equipment drift in the setpoint analysis.

the The LOGIC SYSTEM FUNCTIONAL TEST demonstrates specific OPERABILITY of the required trip logic for a pump breakers is channel. The system functional test of theoverlaps the LOGIC included as part of this Surveillance and testing of the SYSTEM FUNCTIONAL TEST to provide complete is assumed safety function. Therefore, if a breaker channel(s) incapable of operating, the associated instrument would be inoperable.

this The IWl,ý h Frequency is based on the need to perform a plant that apply during Surveillance under the conditions if the outage and the potential for an unplanned transient at power.

Surveillance were performed with the reactor usually pass Operating experience has shown these components month Frequency.

the Surveillance when performed at the (continued) bU0IA CTI B 3.3-99 Rev 1, 04/07/95 0W. 1

ATWS-RPT Instrumentation B 3.3.4.e Z. ý,f if LSAR, igure\QI4 -c iag dases for Changes To Surveillance Test .

41 770.O6Ž For intervals and Allowed Out-of-Service Times /

Selected Instrumentatioon Technical Specifications,4---

Rev 1, 04/07/95 BWR/4 STS B 3.3-100

V32 INSERT REF

2. 10 CFR 50.36(c) (2) (ii).
3. Drawing 11825-5.01-15D, Rev. D, Reactor Assembly Nuclear Boiler, (GE Drawing 919D690BD).
4. [[::JAF-RPT-MISC|JAF-RPT-MISC]] (CHS-96-05), GE letter, FitzPatrick Nuclear Power Plant ATWS Analysis For Recirculation Pump Trip Setpoint Changes High Pressure Trip Setpoint Evalution, May 23, 1996.
5. GE-NE-187-59-1191, FitzPatrick Power Uprate Impact Study Engineering Report: Section 9.3.1, Anticipated Transients Without Scram (ATWS)

Analyses for the James A. FitzPatrick Nuclear Power Plant, November,1991.

Insert Page B 3.3-100

-j JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1, BASES

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS BASES: 3.3.4.1 - ATWS-RPT INSTRUMENTATION RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 The Frequency of ITS SR 3.3.4.1.3 has been extended from 92 days to 184 days consistent with CTS Table 4.2-7.

CLB2 The Frequency of ITS SR 3.3.4.1.5 (LSFT) has been extended from 18 months to 24 months consistent with CTS 4.2-7. This Frequency is consistent with the JAFNPP fuel cycle.

CLB3 The Bases has been revised to be consistent with License Amendment 172 1' which was issued by the NRC by letter dated October 29, 1991.I PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl The FitzPatrick design does not include the EOC-RPT Trip System.

Therefore that Specification is being deleted, and the ATWS-RPT Specification is being renumbered as ITS 3.3.4.1. In addition, the associated Surveillances have been renumbered to reflect this change.

PA2 Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect plant specific nomenclature.

PA3 Changes have been made to be consistent with other places in the Bases.

PA4 The "Reviewer's Note" has been deleted.

PA5 The quotations used in the Bases References have been removed. The Writer's Guide does not require the use of quotations.

PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB1 Not Used. I'*

DB2 Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect plant specific design. References have been added.

Subsequent references have been renumbered as required.

DB3 The description of the setpoint calculation methodology has been revised to reflect the plant specific methodology.

DB4 The Frequency of ITS SR 3.3.4.1.4 has been extended from 18 months to 24 months consistent with CTS Table 4.2-7 and the setpoint calculation methodology.

DB5 The proper plant specific reference have been provided.

JAFNPP Page 1 of 2 Revision F

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS BASES: 3.3.4.1 - ATWS-RPT INSTRUMENTATION DIFFERENCE BASED ON AN APPROVED TRAVELER (TA)

TAl The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler number 205, Revision 3 have been incorporated into the revised Improved Technical Specifications.

TA2 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler number 297, Revision 1 have been incorporated into the revised Improved Technical Specifications.

TA3 The changes presented in the Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Editorial Changes Affecting NUREG-1433 designated as BWROG-ED-7 have been incorporated into the revised Improved Technical Specifications.

TA4 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler number 367, Revision 0 have been incorporated into the revised Improved Technical Specifications.

DIFFERENCE BASED ON A SUBMITTED, BUT PENDING TRAVELER (TP)

None DIFFERENCE FOR ANY REASON OTHER THAN THE ABOVE (X)

Xl NUREG-1433, Revision 1, Bases reference to "the NRC Policy Statement" has been replaced with 10 CFR 50.36(c)(2)(ii), in accordance with 60 FR 36953 effective August 18, 1995.

JAFNPP Page 2 of 2 Revision F

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES

ATWS-RPT Instrumentation 3.3.4.1 3.3 INSTRUMENTATION 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation LCO 3.3.4.1 Two channels per trip system for each ATWS-RPT instrumentation Function listed below shall be OPERABLE:

a. Reactor Vessel Water Level-Low Low (Level 2); and
b. Reactor Pressure-High.

APPLICABILITY: MODE 1.

ACTIONS


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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Restore channel to 14 days inoperable. OPERABLE status.

OR A.2 ........ NOTE --------

Not applicable if inoperable channel is the result of an inoperable breaker.

Place channel in 14 days trip.

(continued)

JAFNPP 3.3-29 Amendment (Rev. F)

/

ATWS-RPT Instrumentation 3.3.4.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One Function with B.1 Restore ATWS-RPT trip 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ATWS-RPT trip capability.

capability not maintained.

C. Both Functions with C.1 Restore ATWS-RPT trip 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ATWS-RPT trip capability for one capability not Function.

maintained.

D. Required Action and D.1 ....... Note .......... 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Only applicable if Time not met. inoperable channel is the result of an inoperable RPT breaker.

S..................... 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Remove the affected reci rcul ati on pump from service.

OR D.2 Be in MODE 2.

JAFNPP 3.3-30 Amendment (Rev. F)

ATWS-RPT Instrumentation 3.3.4.1 SURVEILLANCE REQUIREMENTS


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

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Function maintains ATWS-RPT trip capability.

SURVEILLANCE FREQUENCY SR 3.3.4.1.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.3.4.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.4.1.3 Calibrate the trip units. 184 days SR 3.3.4.1.4 Perform CHANNEL CALIBRATION. The 24 months Allowable Values shall be:

a. Reactor Vessel Water Level - Low Low (Level 2): 2 105.4 inches; and
b. Reactor Pressure- High:
1.  ! 1153 psig with 2 10 Safety/Relief Valves (S/RVs) 1A OPERABLE, or
2. K 1118 psig with < 10 S/RVs iA OPERABLE.

SR 3.3.4.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST 24 months including breaker actuation.

JAFNPP 3.3-31 Amendment (Rev. F)

ATWS - RPT Instrumentation B 3.3.4.1 B 3.3 INSTRUMENTATION B 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation BASES BACKGROUND The ATWS-RPT System initiates an RPT, adding negative reactivity, following events in which a scram does not (but should) occur, to lessen the effects of an ATWS event.

Tripping the recirculation pumps adds negative reactivity from the increase in steam voiding in the core area as core flow decreases. When Reactor Vessel Water Level -Low Low (Level 2) or Reactor Pressure-High setpoint is reached, the recirculation pump motor generater (MG) drive motor breakers trip.

The ATWS-RPT System (Ref. 1) includes sensors, logic circuits, relays, and switches that are necessary to cause initiation of an RPT. The channels include electronic equipment (e.g., trip units) that compares measured input signals with pre-established setpoints. When the setpoint is exceeded, the channel output relay actuates, which then outputs an ATWS-RPT signal to the trip logic.

The ATWS-RPT logic consists of two trip systems for the Reactor Vessel Water Level -Low Low (Level 2) trip function and two trip systems for the Reactor Pressure -High trip function. Each trip system associated with the Reactor Vessel Water Level-Low Low (Level 2) Function includes two reactor water level channels while each trip system V associated with the Reactor Pressure- High Function includes two reactor pressure channels. Each ATWS trip system is a U.,

'-p.,

one-out-of-two logic and both trip systems associated with the same function must trip for the ATWS trip logic to actuate. Therefore, the ATWS trip system logic for each Function is one-out-of-two taken twice.

The two channels in each trip system are powered from a common power supply. For each trip function, the two channels in one trip system are powered independently from the the two the channels in the other trip system.

(Divisions 1 and 2). The logic associated with the two trip systems for the ReactorVessel Water-Low Low (Level 3) trip function and the logic associated with the two trip systems for the Reactor Pressure-High trip function are all powered from one common power supply.

(continued)

JAFNPP B 3.3-86 Revision 0 (Rev. F)

ATWS-RPT Instrumentation B 3.3.4.1 BASES BACKGROUND There is one drive motor breaker provided for each of the (continued) recirculation pump MGs for a total of two breakers. The output of each trip function logic is provided to both recirculation pump MG drive motor breakers.

APPLICABLE The ATWS-RPT is not credited in the safety analysis. The SAFETY ANALYSES, ATWS-RPT initiates an RPT to aid in preserving the integrity LCO, and of the fuel cladding following events in which a scram does APPLICABILITY not, but should, occur. ATWS-RPT instrumentation satifies T ¶'TF Criterion 4 of 10 CFR 50.36 (c) (2) (ii) (Ref. 2).1 7 The OPERABILITY of the ATWS-RPT is dependent on the OPERABILITY of the individual instrumentation channel Functions. Each Function must have a required number of OPERABLE channels in both trip systems, with their setpoints within the specified Allowable Value of SR 3.3.4.1.4. The actual setpoint is calibrated consistent with applicable setpoint methodology assumptions. Channel OPERABILITY also includes the associated recirculation pump MG drive motor breakers.

Allowable Values are specified for each ATWS-RPT Function specified in the LCO. Nominal trip setpoints are specified in the setpoint calculations. The nominal setpoints are selected to ensure that the setpoints do not exceed the Allowable Value between CHANNEL CALIBRATIONS. Operation with a trip setpoint less conservative than the nominal trip setpoint, but within its Allowable Value, is acceptable. A channel is inoperable if its actual trip setpoint is not within its required Allowable Value. Trip setpoints are those predetermined values of output at which an action should take place. _The setpoints are compared to the actual process parameter (e.g., reactor vessel water level), and when the measured output value of the process parameter exceeds the setpoint, the associated device (e.g., trip unit) changes state. The analytic limits are derived from the limiting values of the process parameters obtained from the ATWS analysis. The trip setpoints are derived from the analytical limits and account for all worst case instrumentation uncertainties as appropriate (e.g., drift, process effects, calibration uncertainties, and severe I ,,

environmental errors (for channels that must function in harsh environments as defined by 10 CFR 50.49)). The trip j setpoints derived in this manner provide adequate protection because all expected uncertainties are accounted for. The (continued)

JAFNPP B 3.3-87 Revision 0 (Rev. F)

ATWS-RPT Instrumentation B 3.3.4.1 BASES APPLICABLE Allowable Values are then derived from the trip setpoints by SAFETY ANALYSES, accounting for normal effects that would be seen during f '

LCO, and periodic surveillance or calibration. These effects are APPLICABILITY instrumentation uncertanties observed during normal (continued) operation (e.g., drift and calibration uncertainties). ( .

The individual Functions are required to be OPERABLE in MODE 1 to protect against common mode failures of the Reactor Protection System by providing a diverse trip to mitigate the consequences of a postulated ATWS event. The Reactor Pressure-High and Reactor Vessel Water Level- Low Low (Level 2) Functions are required to be OPERABLE in MODE 1, since the reactor is producing significant power and the recirculation system could be at high flow. During this MODE, the potential exists for pressure increases or low water level, assuming an ATWS event. In MODE 2, the reactor is at low power and the recirculation system is at low flow; thus, the potential is low for a pressure increase or low water level, assuming an ATWS event. Therefore, the ATWS-RPT is not necessary. In MODES 3 and 4, the reactor is shut down with all control rods inserted; thus, an ATWS event is not significant and the possibility of a significant pressure increase or low water level is negligible. In MODE 5, the one rod out interlock ensures that the reactor remains subcritical: thus, an ATWS event is not significant. In addition, the reactor pressure vessel (RPV) head is not fully tensioned and no pressure transient threat to the reactor coolant pressure boundary (RCPB) exists.

The specific Applicable Safety Analyses and LCO discussions are listed below on a Function by Function basis.

a. Reactor Vessel Water Level -Low Low (Level 2)

Low RPV water level indicates that a reactor scram should have occurred and the capability to cool the fuel may be threatened. Should RPV water level decrease too far, fuel damage could result. The ATWS-RPT System is initiated at Level 2 to assist in the mitigation of the ATWS event. The resultant reduction of core flow reduces the neutron flux and THERMAL POWER and, therefore, the rate of coolant boiloff.

(continued)

JAFNPP B 3.3-88 Revision 0 (Rev. F)

/ý ATWS-RPT Instrumentation B 3.3.4.1 BASES APPLICABLE a. Reactor Vessel Water Level - Low Low (Level 2)

SAFETY ANALYSES, (continued)

LCO, and APPLICABILITY Reactor vessel water level signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.

Four channels of Reactor Vessel Water Level -Low Low (Level 2), with two channels in each trip system, are available and required to be OPERABLE to ensure that no single instrument failure can preclude an ATWS-RPT from this Function on a valid signal. The Reactor Vessel Water Level - Low Low (Level 2) Allowable Value is chosen so that the system will not be initiated after a Level 3 scram with feedwater still available, and for convenience with the reactor core isolation cooling (RCIC.) and high pressure coolant injection (HPCI) initiation. The Allowable Value is the water level above a zero reference level which is 352.56 inches above the lowest point inside the RPV and is also at the top of a 144 inch fuel column (Ref. 3).

The HPCI, RCIC and ATWS-RPT initiation functions (as described in Table 3.3.5.1, Function 3.a; Table 3.3.5.2, Function 1 and LCO 3.3.4.1.a including SR 3.3.4.1.4, respectively) describe the reactor vessel water level initiation function as "Low Low (Level 2)." The Allowable Values associated with the HPCI and RCIC initiation function is different from the Allowable Value associated with the ATWS-RPT initiation function as the ATWS function has a separate analog trip unit. Nevertheless, consistent with the nomenclature typically used in design documents, the "Low Low (Level 2)" designation is retained in describing each of these three initiation functions.

b. Reactor Pressure-High Excessively high RPV pressure may rupture the RCPB.

An increase in the RPV pressure during reactor operation compresses the steam voids and results in a positive reactivity insertion. This increases neutron flux and THERMAL POWER, which could potentially result in fuel failure and overpressurization. The Reactor Pressure-High Function initiates an RPT for transients (continued)

JAFNPP B 3.3-89 Revision 0 (Rev. F)

ji ATWS-RPT Instrumentation B 3.3.4.1 BASES APPLICABLE b. Reactor Pressure-High (continued)

SAFETY ANALYSES, LCO,and that result in a pressure increase, counteracting the APPLICABILITY pressure increase by rapidly reducing core power generation. For the overpressurization event, the RPT aids in the termination of the ATWS event and, along with the safety/relief valves (S/RVs), limits the peak RPV pressure to less than the ASME Section III Code Service Level C limits (1500 psig).

The Reactor Pressure-High signals are initiated from four pressure transmitters that monitor reactor steam dome pressure. Four channels of Reactor Pressure-High, with two channels in each trip system, are available and are required to be OPERABLE to ensure that no single instrument failure can preclude an ATWS-RPT from this Function on a valid signal. The Reactor Pressure-High Allowable Value is chosen to grovide an adequate margin to the ASME Section III ode Service Level C allowable Reactor Coolant System pressure. The Allowable Value is dependant on the number of OPERABLE S/RVs. The peak pressure resulting from an ATWS with Main Steam Isolation Valve (MSIV) closure (the limiting transient) is dependant on the power produced during the transient (which is sensitive to the ATWS-RPT Reactor Pressure- High setpoint) and the capability to remove heat from the RPV (which is sensitive to the number of operable S/RVs). The Allowable Value with 2 10 S/RVs OPERABLE was derived from the analysis performed in Reference

4. The Allowable Value with < 10 S/RVs OPERABLE was derived from the analysis performed in Reference 5.

ACTIONS A Note has been provided to modify the ACTIONS related to ATWS-RPT instrumentation channels. Section 1.3, Completion Times, specifies that 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 inoperable ATWS-RPT instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable ATWS-RPT instrumentation channel.

(continued)

JAFNPP B 3.3-90 Revision 0 (Rev. F)

ATWS-RPT Instrumentation B 3.3.4.1 BASES ACTIONS A.1 and A.2 (continued) With one or more channels inoperable, but with ATWS-RPT capability for each Function maintained (refer to Required Action B.1 Bases), the ATWS-RPT System is capable of performing the intended function. However, the reliability and redundancy of the ATWS-RPT instrumentation is reduced, such that a single failure in the same trip system could result in the inability of the ATWS-RPT System to perform the intended function. Therefore, only a limited time is allowed to restore the inoperable channels to OPERABLE status. Because of the diversity of sensors available to provide trip signals, the low probability of extensive number of inoperabilities affecting both'Functions, and the low probability of an event requiring the initiation of ATWS-RPT, 14 days is provided to restore the inoperable channel (Required Action A.1). Alternately, the inoperable channel may be placed in trip (Required Action A.2), since this would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue. As noted, placing the channel in trip with no further restrictions is not allowed if the inoperable channel is the result of an inoperable breaker, since this may not adequately compensate for the inoperable breaker (e.g., the breaker may be inoperable such that it will not open). If it is not desired to place the channel in trip (e.g., as in the case where placing the inoperable channel would result in an RPT), or if the inoperable channel is the result of an inoperable breaker, Condition D must be entered and its Required Actions taken.

B.1 Required Action B.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same Function result in the Function not maintaining ATWS-RPT trip capability. A Function is considered to be maintaining ATWS-RPT trip capability when sufficient channels are OPERABLE or in trip such that the ATWS-RPT System will generate a trip signal from the given Function on a valid signal, and both recirculation pumps can be tripped. This requires one channel of the Function in each trip system to each be OPERABLE or in trip, and the (continued)

JAFNPP B 3.3-91 Revision 0 (Rev. F)

ATWS-RPT Instrumentation B 3.3.4.1 BASES ACTIONS B.1 (continued) recirculation pump MG drive motor breakers to be OPERABLE or in trip.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is sufficient for the operator to take corrective action (e.g., restoration or tripping of channels) and takes into account the likelihood of an event requiring actuation of the ATWS-RPT instrumentation during this period and that one Function is still maintaining ATWS . RPT trip capability. In addition, the Completion Time is sufficient to modify the setpoint of all four pressure channels if there are less than ten OPERABLE S/RVs.

C.1 Required Action C.1 is intended to ensure that appropriate Actions are taken if multiple, inoperable, untripped channels within both Functions result in both Functions not maintaining ATWS-RPT trip capability. The description of a Function maintaining ATWS-RPT trip capability is discussed in the Bases for Required Action B.1 above.

The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is sufficient for the operator to take corrective action and takes into account the likelihood of an event requiring actuation of the ATWS-RPT instrumentation during this period.

D.1 and D.2 With any Required Action and associated Completion Time not met, the plant must be brought to a MODE or other specified condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (Required Action D.2). Alternately, the associated recirculation pump may be removed from service since this performs the intended function of the instrumentation (Required Action D.1). The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, both to reach MODE 2 from full power conditions and to remove a recirculation pump from service in an orderly manner and without challenging plant systems. Required Action D.1 is modified by a Note which states that the Required Action is only applicable if the inoperable channel is the result of an inoperable RPT breaker. The Note clarifies the situations under which the associated Required Action would be the appropriate Required Action.

(continued)

JAFNPP B 3.3-92 Revision 0 (Rev. F)

ATWS- RPT Instrumentation B 3.3.4.1 BASES SURVEILLANCE The Surveillances are modified by a Note to indicate that REQUIREMENTS when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into the associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Function maintains ATWS-RPT trip capability. Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.

This Note is based on the reliability analysis (Ref. 6) assumption of the average time required to perform channelSurveillance. That analysis demonstrated that the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> testing allowance does not significantly reduce the probability that the recirculation pumps will trip when necessary.

SR 3.3.4.1.1 Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Channel agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

The Frequency is based upon operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the required channels of this LCO.

(continued)

JAFNPP B 3.3-93 Revision 0 (Rev. F)

ATWS-RPT Instrumentation B 3.3.4.1 BASES SURVEILLANCE SR 3.3.4.1.2 REQUIREMENTS (continued) A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the channel will perform the intended function. A successful test of the required contacts(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodol ogy.

The Frequency of 92 days is based on the reliability analysis of Reference 6.

SR 3.3.4.1.3 Calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in SR 3.3.4.1.4. If the trip setting is discovered to be less conservative than the setting accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Frequency of 184 days is based on the reliability, accuracy, and low failure rates of these solid-state electronic components.

SR 3.3.4.1.4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary (continued)

JAFNPP B 3.3-94 Revision 0 (Rev. F)

ATWS-RPT Instrumentation B 3.3.4.1 BASES SURVEILLANCE SR 3.3.4.1.4 (continued)

REQU IREMENTS 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 Frequency is based upon the assumption of a 24 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.

SR 3.3.4.1.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the pump breakers is included as part of this Surveillance and overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the assumed safety function. Therefore, if a breaker is incapable of operating, the associated instrument channel(s) would be inoperable.

The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.

REFERENCES 1. UFSAR, Figure 7.4-9 Reactor Recirculation Sy&tem (FCD).

2. 10 CFR 50.36(c)(2)(ii).
3. Drawing 11825-5.01-15D, Rev. D, Reactor Assembly Nuclear Boiler, (GE Drawing 919D690BD).
4. JAF-RPT-MISC-02738 (CHS-96-05), GE letter, FitzPatrick Nuclear Power Plant ATWS Analysis For Recirculation Pump Trip Setpoint Changes High Pressure Trip Setpoint Evaluation, May 23, 1996.

(continued)

JAFNPP B 3.3-95 Revision 0 (Rev. F)

ATWS-RPT Instrumentation B 3.3.4.1 BASES REFERENCES 5. GE-NE-187-59-1191, FitzPatrick Power Uprate Impact (continued) Study Engineering Report: Section 9.3.1, Anticipated Transients Without Scram (ATWS) Analyses for the James A. FitzPatrick Nuclear Power Plant, November, 1991.

6. GENE-770-06-1-A, Bases for Changes To Surveillance Test Intervals And Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications, December 1992.

JAFNPP B 3.3-96 Revision 0 (Rev. F)

/

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.5.1 Emergency Core Cooling System (ECCS)

Instrumentation MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

DISCUSSION OF CHANGES (DOCs) TO THE CTS NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC)

FOR LESS RESTRICTIVE CHANGES MARKUP OF NUREG-1433, REVISION 1, SPECIFICATION JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION 1 MARKUP OF NUREG-1433, REVISION 1, BASES JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION 1, BASES RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.5.1 Emergency Core Cooling System (ECCS)

Instrumentation MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

3435 '!-61 JAFNPP aWCotanya CdigSystemsC!t )

St[AI

'Instrumentaion shall be functionally tested, calibrated, and ch ked as Indicated In Table - 3 3'5 1--

The limiting cOndtion fof q f'1th!Mntates or controls the(

61 9SvUE ame lven In T"bl System logic shall be functionally tested as indicated In Table ._ /

CAPPI 0 Control Rod Block Actuatlo aI The liniting coontlons of operation for theMsrumentalon Instnjmentation shall be functionally tested, calibrated, that Initiates control rod block are given InTable 3.2-3. checked as Indicated In Table 4.2-3.

I System logic shall be functionally tested as indicated in Table 4.2-3. / "'

/ o;/C Amendment No. X, i,, 227 50

3~3 5~I-IecJ~4io~

Ta~La.. .

JAFHPP ed 10 o e, ýP- ýao M?

W, 40. W7".-44 AmwxkrieM No . . 1212 25 66 REVISION F

4 ýý

ý 3 3 -,5.

Amendment No. 10, 8, 67, 8, , 110,22;, 250, 263 67 PZýf- -7 EW /J-REVISION F

5j e C A d VA

,CVA .*

JAFNPP ini mu No. \

Opera e Insarumen Tin P'r L4uurnA Chanyels Auto Blowdown Timer < 134 sec.

TA;-,j/7te #a,4 2-1J RHR ILPCI) Pump 125 psig t 20 psig Discharge Pressure Interlock Ly-Ur Core Spray Pump Discharge Pressure 100 psig t 10 psig Interlock Condensate Storage S59.5 in. above Tank Low Level tank bottom

(= 15,600 gal. avail)

Condensate Storage Tank Low Level * . aýsii- --(4ý4 oo,6ý050 Suppression Chamber f*6 inaboven a 2 High Level ToWA16e- ,

Amendment No. 10, 48, 84, 1...... 7,2.0, 263 68

,Re-("IO0. P*

AmendhmeflA No. 3. 37, 48. 4v2P. 2 50 69 REVISION F

S ec '-'JC '%,"-z-*,.

1.5". )

C7111 NT lei 4 cPow A773' Alak/'

1. With on or more channeals inoperable for HPCI cu (I--ý A. Within one hour from discovery of loss of system initiation capability, declare the affected system inoperable, and I

Low, %. B. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, place channel in trip.

are not met, immediatsly declare the affected system cki

c. it required actions and associated completion times of actions A or B inoparable. j . ,I.d2
  • 1 (
2. With one of morxe channels imprbeo for Core Spray arndlix RHR:

declare the supported featuwes

.0. o A. Within one how from discovery of los of initiation capability for feeturwes) in both divisiios.

inopeable. and C(..P.,;,.,

SB. Within 24 hows. place chawne i trip.

C. If required actions OWd associated completion times of actions A or B re not met. inimmistely declare associated supported featwelsi ~inoWeable.

3. With one or mote channels inokeable lot ADS:

systems, declare ADS inoperable, and Within one hour from discovery of loss of ADS initiation capability in both trip

(..,, V.J% A.

inoperable. place channel in trip, and B. Within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from discovery of an inoperable channel concurrent with HPCI or RCIC t cL,.q. "C. Within 8 days. place channel in trip.

declare ADS inoperable.

Z.r ý",-* D. If required actions and associated completion times of actions A, B, or C are not met, immediately 3I Amendment No. a,48-,27, 2 5 0 70 ?ae.Iseo Revision B

JAFNPP COREEýAND VLOQUI61 COO ONTMoffIII ýftMMAM ffv MOIN&MBIt TIM 116118 N AND RC

  • With one or more hanneFls inoperable for lHPC' ArC,)U Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, restore channel to operable status.

inoperable.

SC troN %" . If required action and associated completion time of action A is not met, immediately declare affected system Fcrl0#6J -. With one or more channels inoperable for containment spray:

S A. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, piece channel in trip.

'I A is not met, immediately declare associated supported featurels r4%( TIP

  • J It required action and associated completion time of action inoperablie.

With one or more channels inoperable for injection permissive and/or reciculation discharge valve permissive:

of loss of initiation capability for feature1s) in both divisions, declare the supported fatures I, I*A C*, A. Within one hour forn discovery inoperable. and

  • A .(f.1 B. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, restore channel to operable status.

Erl t 0lif raetuired actions and associated completion times of actions A or B We not met, immediately declare associated supported LA( ('loi) featurels) inoperable.

i*e NJý A 76)I=.

No. 48, 67. 106, 120.g6g. 227,2 50 Revision B

JAFNPP C3 (COE ýAND COQINMENT COOLING SYS, M INITIATION A-N-D

  • CONTROL I TRUMENTATION OPER3A*.ITY REQUIREMEN.TS LVA C.'gJ7. A. With one start timer inoperable, restore the timer to an operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

inoperable.

With two or more start timers inoperable, within one hour declare the associated ECCS subsystem(s) i3 8. ECCS subsystem(s) tjCT. If the required actions and associated completion times of A and B cannot be met declare the associated inoperable.

/ 8. With one or more channels inoperable for ADS:

and 1AI.6B. Within one hour from discovery of loss of ADS initiation capability in both trip systems, declare ADS inoperable, channel to operable Within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from discovery of an inoperable channel concurrent with HPCI or RCIC inoperable, restore status, and Within 8 days, restore channel to operable status.

ADS inoperable.

If required actions and associated completion times of actions A, B, or C are not met, immediately declare A P.

(9. With one or more channels inoperable for HPCI -h Hile suction for theeaffected s stem is ali to the Within one hour from discovery of loss of system initiation capability declare the affected system inoperable,VIA andDx- -- -.. ,1: A. U 2" ,

[AU10wJ1 C for the affected system to the suppression Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, rhanneintriorj~li-n suc io the affected system If required actions and associated completion times of actions A or B are not met, immediately declare inoperable.

,iflWE 4 ~i~~AA$le' ( 2 3. 5 1 ;M 3

£4 Amendment No. 22, 2 5 0 71a Revision B

/'

JAFNPP ,5'FO-e CO- bow% 3,3. S.

the affected Emergency Diesel)

B. If required action and associated completion time of action A is not met, immediately declare Generator System lnopable.

Noi--' J When a channel is placed in an inoperable status solely for performance actions ot required surveuilances.

may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided e.-y UTripa.Function or the redundant the associated Conditions For Operation and required b() capability.

LTrip Function maintains ECCS initiation associated Limiting for performance of required surveillances, entry Into When a channel Is placed in an Inoperable status solely t3.

N? --L actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

rA 1(141 ,...._Conditions For Operation and required and oss-of-vollage) iniliale the (degraded voltage LOCA, degraded voltage non-LOCA, motor breakers (in conjunction The 4kV Emergency Bus Underotage Timers trips all 4kV trips the normallreserve lie breakers and following: starts the Emergency Diesel-Generators; (in conjunction with 90 voltages); initiates diesel-generator breaker close permissive with 75 percent Emergency Diesel-Generator conjunction with low-low-low reactor and; initiates sequential starting of vital loads in percent Emergency Diesel-Generator voltages) water level or high drywell pressure.

14. A secondary voltage Of 110.6 volts corresponds to approximately 93% of 4160 volts on the bus. $;e *TT5.*. '

oxima-t--ely 71.5% of 4160 volts on the bus.

V5. A s-cond-a,,y v~;-* of 85 vol-".s correspronds to app*r 4 Amendment No. 2.5 0 71b Revision B

S5c*@ 335 y JAFNPP q.3

.f. j.

t.Calibration Frequency 'Check INote 41

.nstrument Functional Test R

-. .SAI

- SA I R 5"-R

_41 Auto Sequencing Timers I LPCI or CS Pump Disch. 0

?1 51 ADS -

t 1 HPCI & RCIC Suction Source Levels R J R

4kV Emergency Bus Under-Voltage iLoss.of-Voltage, Degraded Voltage -, *3, i, -T-F LOCA and non-LOCAl Relays and Timers.

AmendmenSee Neos fo-A 1 oiov"n e4-._- -2ab-4. 6 80. 5 (. D REo O F

-- 14; .7ýl, ;L2,z72--k"3' al44

  • 4l 263 Amendment No. a_.,-l.

REVISION F

5 JAFNPP t3 PI, J Logic System Functional Test Frequency

1) Core Spray Subsystem 7 &(1
2) Low Pressure Coolant Injection Subsystem R :Notes otes &

13] 3) f,-P 2- Containment Cooling Subsystem R -j q VI.,tV)

4) HPCI Subsystem R notes &

ADS Subsystem RR otes &

5)

/0-OTE: ýSee ýesfol ýwing Table 4.t2-5.

Amendment No. 3, 62, 94 818, 22:7, 28.. 263 1, 81 REVISION F

JP -VP

)I

1. Initially once every mont until acceptance failure rate data are 8. Reactor low water level., jnd high drywell pressure area n-ot k I( r " \ available; thereafter, a request may be made to the NRC to included on Table 4.2-1 since they are listed on Table ,3 I

"". change the test frequency. The compilation of instrument 4.1-2 "4

" . \ failure rate data may include data obtained from other boiling St2.

vwater seactors for which the same design instruments operate ia a env t similar to that of JAFNPP.

Functional tests wre not required when these Instrents are

9. 1 system I of tip deola (slays f untionini Sof lM ional test hall include timer cessary f proper tio svsea./

calibration ED not required to be operable or wre tripped. Functional tests (Deleted;.

Wl.

3 ý~Z, shall be performed within seven 47) days prior to each startup 17 (111. Perform.a

3. Calibrations are not required when these instruments are not source. PI required to be operable or we tripped. Calibration tests shall -".ly 3 m be performed within seven (7) days prior to each startup_

ior to a pre-planned shutdow n. .. .. .. .. .. )

a kowm n i~nstue n ý1,*_

channeilgmntoc srumenot heu* noe r*qr tw .sa ..

w 1..IUý.-LUUIU I qS---WeOlOateUr (5. This lpi~tnmtetio9J-xempt from efuntNiwonal t/* *'*  ; il

\ %...siniated~l.M~ctrlcal deftion. The hlactional test wi~l~onsist of injactjga -'. Il ( .a -JD.Q nt 1) ter/slave trie signal in~toAIf.e me~asu..ement 4hnel..l. *iit ciH5i cali ri o nper6month

6. These nstrument channels will be calibrated using simuhateh aiy califatlon of the temperature sensor consists prS electrical signals once evey tlvee months. of compal ring the active temperature signal with a .

h*Rh ýrhxrnddgmd 2 t temperature signal. _ _ '_ _

7. Simulated automatic actuation shfal be performed once per 24 months.

Amandment No. ;4. 48.

  • IW*V*V*WWVWW* .... .. w - * *
67. Be. !84. 207. 227. 233 84 YO I-L ýý

-SI,1(&~"3, 3,5*,t JAFNPP DA(

3.5 (cont'd) 4.5 ((cont'd)

b. Flow Rate Test In accordant ce with the Core spray pumps Inservice Te sting shall deliver at Program least 4,265 gpm against a system head corresponding to a reactor vessel pressure greater then or equal to 113 psi above primary containment pressure.
c. Verify that each valve Once per 31 Days (manual, power operated or automatic) in the flow path that is not locked, sealed or otherwise secured in position, is in the correct position.
d. Motor operated valves. In accordanc:e with the Inservice Program Teosting
e. Core Spray Header Ap Instrumentation Check Once/day Calibrate Oncel3 montths .

Test Once/3 mont thss LU Logic System Functional Test

g. Testable Check Valves Amendment No. 40. 149,204,233, 241 113 P'k I /,

e Cý i / -f-

2S JAFNPP K,3 5 (cont'd) 4.5 (cont'd)

2. From and after the date that one of the Core Spray 2. When it is determined that one Core Spray System is Systems Is made or found inoperable for any reason, Selz Inoperable, the operable Core Spray System. and both .

continued reactor operation Is permissible during the LPCI subsystems, shall be verified to be operable succeeding 7 days unless the system is made operable immediately. The remaining Core Spray System shall be earlier, provided that during the 7 days all active verified to be operable daily thereafter.

components of the other Core Spray System and the LPCI System shall be operable. CS-S.3 ýA. qJ

3. LPCI System testing shall asspecifed In.4.5.A.-1 c
3. Both LPCI subsystems of the RHR System shall be

ý_...d. g exceptt each RHR pump deliver at least operable whenever Irradiated fuel Is in the reactor and prior to reactor startup from a cold condition, except as 8,910 gpm against a system head corresponding to a g reactor vessel to primary containment differential pressure specified below. of greater than or equal to 20 psid.

K. a.

Icontinued From the time that one of the LPCI subsystems Is nmade or found to be inoperable for any reason, reactor operation Is permissible during the succeeding 7 days unless that subsystem is made operable earlier provided that during these 7 days

a. When it Is determined that one LPCI subsystem is inoperable, the operable LPCI subsystem and both Core Spray Systems shall be verified to be operable Inmediately and daily thereafter.

the operable LPCI subsystem and both Core Spray I ,_Systems shall be operable.

1 I

Amendment No. j -A, I ,/,

114

/ILIL L("r Q0A 0-

i 5P-e Cf, 9..

34.6 S* JAFNPP lcant'd) 3.6 (cont'dl4.

DELET ED COOLAN-L*ET IO HC YT C.

r O HIGH PRESSURE COOLANT INJECTION rrn IHPCI SYSTEIM) C. . H G PRE~SSURE HIGH g SI R performed as follows Surveillance of HPCI System shall be If steam Is not provided a reactor steam supply Inavailable.

is scheduled to be available at the time the surveillance test 10 days of.

performed, the test shall be performed within le operation from the time steam ava_._. becomes the continuous

i. The HPCI System shall be operable whenever Idi rsueI reco r atehn 150 psig and reactor (jo.. 4-5-A.

HPCI Systemb.2c, testing a a" d ffaCshall be as specified in ceerien pressure Is in greater than the reactor the vessel, psi and e 21 except as Jaanb___jf bj50 c.

krradiated fuel is pump shall deliver a learnt 4.250 p agt specified below: vessel system head corresponding to a reactor si10

ýpressure of11.1195 p5i9 to 160 Amendment No. 4OrO. 239 117 ty 0-ý

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.5.1 Emergency Core Cooling System (ECCS)

Instrumentation DISCUSSION OF CHANGES (DOCs) TO THE CTS

'10 DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION ADMINISTRATIVE CHANGES Al In the conversion of the James A. FitzPatrick Nuclear Power Plant (JAFNPP) Current Technical Specification (CTS) to the proposed plant specific Improved Technical Specifications (ITS) certain wording preferences or conventions are adopted which do not result in technical changes. Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the conventions in NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4",

Revision 1 (i.e., Improved Standard Technical Specifications (ISTS)).

A2 A Note has been added at the start of the CTS Table 3.2-2 Actions Table

("Separate Condition entry is allowed for each channel.") to provide more explicit instructions for proper application of the Actions for Technical Specification compliance (ITS 3.3.5.1 ACTIONS Note). In conjunction with the proposed Specification 1.3 "Completion Times," this Note provides direction consistent with the intent of the Required Actions for inoperable ECCS channels, functions, or trip systems. It is intended that each Required Action be applied regardless of it having been applied previously for other inoperable ECCS channels, functions, trip systems or breakers. This clarification is considered administrative.

A3 The proposed format for this Specification includes an ACTION (ACTION A) that directs entry into the appropriate Conditions referenced in Table 3.3.5.1-1 when one or more channels are inoperable. The ACTION has been added since not all Functions have the same ACTIONS. This change represents a presentation preference only and is, therefore, considered administrative.

A4 CTS 3.2.D and 4.2.D provide a cross reference to the Radiological Effluent Technical Specification (Appendix B) for those Radiation Monitoring Systems which provide an Isolation and Initiation Function. Since CTS 3.2.D and 4.2.D do not prescribe any specific requirements and since the changes to the current requirements in Appendix B are discussed in the Discussion of Changes within this submittal, this cross reference has been deleted. This change is considered administrative since it simply eliminates a cross reference. This change is consistent with NUREG-1433, Revision 1.

A5 CTS Table 4.2-2, Note 5 states that "This instrumentation is exempt from the functional test definition. The functional test will consist of injecting a simulated electrical signal into the measurement channel."

The ITS definition of Channel Functional Test (CFT) defines a CFT as "the injection of a simulated or actual signal into the channel as close to the sensor as practicable". Therefore, the test defined by CTS Table JAFNPP Page 1 of 14 Revision F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION ADMINISTRATIVE CHANGES A5 (continued) 4.2-2 Note 5 is consistent with the ITS definition of a CFT, and the Note can be deleted. Since this represents no new or different requirements it is considered administrative, and is consistent with NUREG-1433, Revision 1.

A6 CTS Table 4.2-2, Note 4 states that "instrument checks are not required when these instruments are not required to be operable or are tripped."

ITS SR 3.0.1 states that "SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR." The SR also states that "surveillances do not have to be performed on inoperable equipment or variables outside specified limits." These two statements in SR 3.0.1 equate to Table 4.2-2, Note 2, deleting the need to have the note. Its deletion does not cause a new or different requirement from the CTS. Therefore, the change is considered administrative, and is consistent with NUREG-1433, Revision 1.

A7 The column title in CTS Table 3.2-2 (Total Number of Instrumentation Channels Provided by Design for Both Trip Systems) is proposed to be changed to a per Function basis in ITS 3.3.5.1 rather than the current per Trip System basis. Therefore, except as otherwise noted, the number of channels in the proposed column will be changed to identify the number of channels associated with the new ITS 3.3.5.1 Function. This new categorization is used for all ECCS instrumentation, except the ADS instrumentation. For the ADS instrumentation, each of the two trip systems is listed separately in the Table 3.3.5.1-1 (proposed Functions 4 and 5), thus, the channels per Function do not change. This is considered to be an administrative change.

A8 The details in the CTS Table 3.2-2 "Total Number of Instrumentation Channels Provided by Design for Both Trip Systems" column identifying which systems are supported by the CTS Trip Functions have been deleted (e.g., Core Spray and RHR). ITS Table 3.3.5.1-1 is arranged to identify each Function providing support to a specific ECCS System. Therefore, all the Trip Functions in CTS Table 3.2-2 providing a support Function to the Core Spray System, Low Pressure Injection System (LPCI), High Pressure Coolant Injection (HPCI) System and the Automatic Depressurization System (ADS) Trip System A and B are now associated with the specific System in ITS Table 3.3.5.1-1, thus it is not necessary to identify this cross reference to each system. This change JAFNPP Page 2 of 14 Revi si on F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION ADMINISTRATIVE CHANGES A8 (continued) in format does not alter any technical requirements, and is therefore, considered administrative. This change is consistent with NUREG-1433, Revision 1.

A9 CTS Table 3.2-2 Item 12 identifies specific start timer setpoints for the "1st Pump" and "2nd Pump" for RHR (LPCI) Loops A and B. In ITS Table 3.3.5.1-1 Function 2.f, the specific LPCI pumps (e.g., A, D) are identified and are associated along with the appropriate Allowable Values. This change in format does not alter any technical requirements and is therefore considered administrative. This change is consistent with NUREG-1433, Revision 1.

A1O CTS 3.2.B requires the Core and Containment Cooling System instrumentation to be Operable whenever the system(s) it initiates or controls are required to be operable as specified in CTS 3.5. CTS 3.5.A.1 and CTS 3.5.A.2 require the Core Spray (CS) and Low Pressure Coolant Injection (LPCI) Systems to be Operable whenever irradiated fuel is in the reactor vessel and prior to reactor startup from a cold condition (ITS MODES 1, 2 and 3). CTS 3.5.C.1 requires the High Pressure Injection System (HPCI) to be Operable whenever the reactor pressure is > 150 psig and reactor coolant temperature is greater than 212°F and irradiated fuel is in the reactor vessel (MODE 1, and MODES 2 and 3 when reactor pressure is > 150 psig), and CTS 3.5.D.1 requires Automatic Depressurization System (ADS) to be Operable whenever the reactor pressure is greater than 100 psig and irradiated fuel is in the reactor vessel. In addition, CTS 3.5.F provides specific Applicability requirements during cold conditions and refueling operations. During a cold condition, two Emergency Core Cooling subsystems are required to be Operable whenever irradiated fuel is in the reactor and work is being performed with the potential for draining the reactor vessel and only one subsystem is required when there are no operations with the potential of draining the vessel. During refueling operations, when the cavity is flooded and the spent fuel pool gates are removed and the water level above the fuel is in accordance with CTS 3.10.C (> 33 feet in the fuel storage pool), no Emergency Core Cooling low pressure subsystems are required.

The CTS 3.5 Applicability during MODES 1, 2 and 3 is consistent with the ITS 3.5.1 (ECCS-Operating) Applicability except for the requirements of ADS. As described in the Discussion of Changes for ITS 3.5.1 the Applicability of ADS has been changed to be consistent with the Applicability of HPCI. The changes to the Applicability requirements JAFNPP Page 3 of 14 Revision F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION ADMINISTRATIVE CHANGES A1O (continued) during cold shutdown (MODE 4) and refueling operations (MODE 5) are discussed in the Discussion of Changes for ITS 3.5.2 (ECCS-Shutdown).

The requirements for Operability during MODE 4 are consistent with the current requirements. However, in MODE 5 the minimum water level when no ECCS subsystems are required has been increased to 22 feet 2 inches above the reactor pressure vessel flange. This change is more restrictive than CTS 3.5.F Applicability and is discussed in M3 of the Discussion of Changes for ITS 3.5.2.

The proposed Applicability for ITS 3.3.5.1 is indicated in Table 3.3.5.1-1 for each Function and is consistent with the new Applicability in ITS 3.5.1 and 3.5.2. Since the modifications to the Applicability are adequately discussed in the Discussion of Changes for ITS 3.5.1 and 3.5.3, the corresponding changes to the ECCS instrumentation Applicability are considered administrative since the CTS clearly identifies the instrumentation to be provide a support Function to the associated ECCS subsystems.. Any additional changes to the Applicability of any specific Function is discussed below.

Footnote (a) to ITS Table 3.3.5.1-1 requires ECCS subsystems to be operable per LCO 3.5.2, ECCS-Shutdown. This ITS requirement is consistent with CTS requirements as described above. Specifically, the CTS 3.2.B requires the Core and Containment Cooling System instrumentation to be Operable whenever the system(s) it initiates or controls are required to be operable as specified in CTS 3.5. Therefore, the footnote reflects the current licensing basis requirements.

Accordingly, the incorporation of this ITS footnote is considered an administrative change.

All A Note has been added to CTS Table 3.2-2 Action Notes L.A to clearly identify the Functions which these actions are applicable to. ITS 3.3.5.1 Required Action B.2 Note specifies that Required Action B.2 is only applicable to ITS 3.3.5.1 Functions 3.a and 3.b. This note is simply a clarification of the current requirements and therefore this change is considered administrative, but aids in the Application of the Required Actions. This change is consistent with NUREG-1433, Revision 1.

JAFNPP Page 4 of 14 Revision F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION ADMINISTRATIVE CHANGES A12 CTS Table 3.2-2 includes a "Trip Level Setting" column. The setting for each Core and Containment Cooling System Initiation and Control Instrumentation Operability Requirements Functions is listed in this column. In the ITS, the ECCS Functions are included in Table 3.3.5.1-1 along with its associated "Allowable Value".

The CTS "trip level settings" are considered the "Allowable Values" as described in the ITS since the instrumentation is considered inoperable if the value is exceeded when either the CTS or the ITS is applicable.

A detailed explanation of trip setpoints, allowable values and analytical limits as they relate to instrumentation uncertainties is provided below.

Trip setpoints are those predetermined values of output at which an action is expected to take place. The setpoints are compared to the actual process parameter and when the measured output value of the process parameter exceeds the setpoint in either the increasing or decreasing direction, the associated device (e.g., trip unit) changes state.

The trip setpoints are specified in the setpoint calculations, are derived from the analytical limits, and account for all worst case applicable instrumentation uncertainties (e.g., drift, process effects, calibration uncertainties, and severe environmental effects as appropriate). The trip setpoints derived in this manner provide adequate protection because all expected uncertainties are accounted for in the setpoint calculations.

The setpoints specified in the setpoint calculations are selected to ensure that the actual field trip setpoints do not exceed the ITS Allowable Values (i.e., the CTS 'trip level settings") between successive CHANNEL CALIBRATIONS- The CTS "trip settings" and the "ITS Allowable Values" are both the TS limit values that are placed on the actual field setpoints. The Allowable Values are derived from the trip setpoints by accounting for normal effects that would be seen during periodic surveillance or calibration. These effects are instrumentation uncertainties observed during normal operation (e.g., drift and calibration uncertainties). Accordingly, the ITS Allowable Values include all applicable instrument channel and measurement uncertainties.

A channel is inoperable if its actual field trip setpoint is not within its required ITS Allowable Value.

The analytical limits are derived from the limiting values of the process parameters obtained from the safety analysis or other appropriate documents.

JAFNPP Page 5 of 14 Revision F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION ADMINISTRATIVE CHANGES A12 (continued) 1/4 These "Trip Level Settings" or "Allowable Values" have been established consistent with the NYPA Engineering Standards Manual, IES-3A, "Instrument Loop Accuracy and Setpoint Calculation Methodology." The methodology used to determine the "Allowable Values" are consistent with the methodology discussed in ISA-$67.04-1994, Part II, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation." This change revises the terminology used in the CTS from "Trip Level Setting" to "Allowable Values". Since the instrumentation will be declared inoperable at the same numerical value, this change is considered administrative. Any changes to any "Trip Level Setting" in the CTS will be discussed below. This change is consistent with NUREG-1433, Revision 1.

A13 The explicit requirement to perform a quarterly Functional Test of the Drywell Pressure (non-ATTS), ADS - LPCI or CS Pump Discharge, and HPCI Suction Source Levels instrument channels in CTS Table 4.2-2 is being deleted. CTS Table 4.2-2 and ITS SR 3.3.5.1.3 require a CHANNEL CALIBRATION at the same Frequency, therefore this explicit requirement to perform a quarterly CHANNEL FUNCTIONAL TEST is not required since the ITS definition of CHANNEL CALIBRATION fulfills all the requirements of the CHANNEL FUNCTIONAL TEST. This change is considered administrative since the existing requirements will be fulfilled by performing a CHANNEL CALIBRATION every 92 days.

A14 CTS Table 4.2-2 divides the Surveillance Requirements for Drywell Pressure and Reactor Pressure Functions as non-Analog Transmitter Trip System (ATTS) components and ATTS components. ITS 3.3.5.1 does not specify this explicitly in Table 3.3.5.1-1. Each of the Functions are listed separately along with the associated Surveillance Requirements.

Since the required surveillances for non-ATTS and ATTS in the CTS are included in the ITS this change is considered administrative since no technical requirements have been changed. This change is consistent with NUREG-1433, Revision 1.

A15 CTS Table Note 4.2-2 Note 9 requires the calibration of the time delay relays and timers necessary for proper functioning of the trip systems to be performed during the Logic System Functional Test (LFST) which is currently required to be performed every 6 months. This explicit requirement to calibrate the timers during the LSFT has been deleted.

The LSFT has been extended to 24 months as justified in L5. The calibration Frequencies of the timers and relays as identified in CTS Table 4.2-2 for the auto sequencing timers is 24 months. The Table does JAFNPP Page 6 of 14 Revi si on F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION ADMINISTRATIVE CHANGES A15 (continued) not specify a calibration frequency for the ADS auto blowdown timers.

Therefore, JAFNPP has interpreted the calibration requirements for all timers to be every 6 months. The calibration Frequency of all timers have been evaluated in accordance with Li and have been extended from every 6 months to 24 months. Since the calibration and LFST Frequency of all timers have been extended to 24 months, and since all the required timers are explicitly identified as requiring a CALIBRATION and an LFST in ITS Table 3.3.5.1-1 every 24 months, the explicit requirement to perform a calibration of timers during the LFST is not needed. Since the justifications for the Frequency extensions are justified in Li and L5, this change is considered administrative. This change in format is consistent with NUREG-1433, Revision 1.

A16 CTS Table 3.2-2 Item 17 specifies that the Condensate Storage Tank Low Level setting must be > 59.5 inches above the tank bottom. ITS Table 3.3.5.1-1 Function 3.d-does not specify the reference point since it is implied by the associated name of the Function (Condensate Storage Tank Level), however, the current setting is maintained as the Allowable Value (see A12). In addition, CTS Table 3.2-2 Item 18 specifies that the Suppression Pool High Level setting must be < 6 inches above normal level. The normal Suppression Pool Water Level Ts specified in CTS 3.7.A.1 as being from 13.88 to 14.00 feet. ITS Table 3.3.5.1-1 specifies the Allowable Value to be < 14.5 feet. These changes are considered administrative since there is no technical change in the current requirement. This change is consistent with the format of NUREG-1433, Revision 1.

TECHNICAL CHANGES - MORE RESTRICTIVE M1 CTS Table 3.2-2 Item No. 17 (Condensate Storage Tank Level -Low) requires two channels to be Operable. For the same Function in the ITS (ITS 3.3.5.1-1 Function 3.d) the required number of channels has been increased to 4 channels. The JAFNPP design includes two condensate storage tanks. Both tanks provide suction to the High Pressure Coolant Injection Pump and each tank is instrumented with two channels of Condensate Storage Tank Level -Low. At least one channel in each tank must indicate low water level for the automatic transfer logic to function to initiate the transfer of the suction source from the CSTs to the suppression pool. Therefore to ensure that no single instrument failure can preclude HPCI swap to the suppression pool source four channels of Condensate Storage Tank Level -Low are proposed to be included in the ITS. The addition of new requirements constitutes a more restrictive change.

JAFNPP Page 7 of 14 Revi si on F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - MORE RESTRICTIVE M2 Five additional Functions are proposed to be added to the requirements in CTS Tables 3.2-2 and 4.2-2 to ensure the Core Spray, Low Pressure Coolant Injection (LPCI), and High Pressure Coolant Injection (HPCI)

System minimum flow control valves operate as required. Appropriate Actions and Surveillance Requirements have also been added. This instrumentation ensures each minimum flow control valve operates properly. This will ensure each Emergency Core Cooling System pump is Operable and will function as designed during a design basis accident.

The addition of new requirements constitutes a more restrictive change.

The following Functions have been added as a result of this change:

i.e Core Spray Pump Discharge Flow- Low (Bypass) 1.f Core Spray Pump Discharge Pressure-High (Bypass) 2.g Low Pressure Coolant Injection Pump Discharge Flow-Low (Bypass) 3.f High Pressure Coolant Injection Pump Discharge Flow- Low (Bypass) 3.g High Pressure Coolant Injection Pump Discharge Pressure-High (Bypass)

Each Function will be calibrated every 3 months (SR 3.3.5.1.3) and will be tested every 24 months in accordance with the Logic System Function Test (SR 3.3.5.1.6). The calibration Frequency is consistent with the Frequencies for similar instrumentation and also consistent with the setpoint calculation methodology.

M3 CTS Table 4.2-2 presently contain daily requirements for performing instrument checks on reactor water level, drywell pressure, and reactor pressure instrumentation. ITS SR 3.3.5.1.1 requires that these Channel Checks be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Performing these checks on a more frequent basis adds to the ability to verify that the channels are operable, and therefore, does not represent a change that could affect safety. The channel check ensures once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that a gross failure of instrumentation has not occurred. Since the change is requiring a surveillance to be performed on a more frequent basis, the change is considered more restrictive. The proposed change is consistent with NUREG-1433, Revision 1.

M4 Not Used M5 Not Used JAFNPP Page 8 of 14 Revision F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - MORE RESTRICTIVE M6 This change replaces the setpoint or Allowable Value (A12) in CTS Table 3.2-2, Item 5, Reactor Low Level (inside shroud), containment spray interlock of

  • 0.0 in. with k 1 inch (ITS Table 3.3.5.1-1 Function 2.e).

The Allowable Values (to be included in the Technical Specifications) and the Trip Setpoints (to be included in plant procedures) have been established consistent with the NYPA Engineering Standards Manual, IES 3A, "Instrument Loop Accuracy and Setpoint Calculation Methodology."

The methodology used to determine the "Allowable Values" are consistent with the methodology discussed in ISA-$67.04-1994, Part II, "Methodologies for the Determination of Setpoints for Nuclear Safety Related Instrumentation." The proposed value will ensure the most limiting requirement is met. All design limits, applied in the methodologies, were confirmed as ensuring that applicable design requirements of the associated system is maintained.

M7 This change replaces the setpoint or Allowable Value (A12) in CTS Table 3.2-2, Item 3, Reactor High Water Level : 222.5 inches with < 222.4 inches (ITS Table 3.5.1.1-1, Function 3.c, Reactor Vessel Water Level High, Level 8). The Allowable Values (to be included in the Technical Specifications) and the Trip Setpoints (to be included in plant procedures) have been established consistent with the NYPA Engineering Standards Manual, IES-3A, "Instrument Loop Accuracy and Setpoint Calculation Methodology." The methodology used to determine the "Allowable Values" are consistent with the methodology discussed in ISA S67.04-1994, Part II, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation." The proposed value will ensure the most limiting requirement is met. All design limits, applied in the methodologies, were confirmed as ensuring that applicable design requirements of the associated system is maintained.

TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC)

LA1 The details in the CTS Table 3.2-2 "Remarks" column (i.e., initiates HPCI, SGTS, Core Spray, RHR (LPCI) and, etc) are proposed to be relocated to the Bases and therefore the "Remarks" column has been deleted. The Trip Functions in CTS Table 3.2-2 will be associated along with the System which is provides a support Function in the ITS.

Therefore all Functions in CTS Table 3.2-2 providing a support Function JAFNPP Page 9 of 14 Revi si on F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC)

LA1 (continued) to the Core Spray System, Low Pressure Injection System (LPCI), High Pressure Coolant Injection (HPCI) System and the Automatic Depressurization System (Trip System A and B) are now associated with the specific System in ITS Table 3.3.5.1-1. Therefore the details in the "Remarks" column are not necessary and have been relocated to the Bases. The Bases will describe the actual support Function (e.g.,

initiate HPCI). The requirement in ITS LCO 3.3.5.1 that the ECCS instrumentation for each Function in Table 3.3.5.1-1 shall be OPERABLE, the details in Table 3.3.5.1-1 for each Function, the definition of Operability and the associated Surveillance Requirements will ensure the instrumentation remains Operable. As such, these details are not required to be in the ITS to provide adequate protection of public health and safety. Changes to the Bases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the ITS.

LA2 CTS Table 3.2-2 includes both a "Minimum No. of Operable Instrument Channels Per Trip System" column and a "Total Number of Instrument Channels Provided by Design-for Both Trip Systems." In addition, Note 16 further specifies there is only one trip system associated with certain High Pressure Coolant Injection Functions (i.e., Item 3, 17, and 18), Item 11 (Core Spray Pump Start Timer), Item 12 (RHR Pump Start Timers). The details that some Functions include more than one trip system and that others Functions only include one trip system are proposed to be relocated to the Bases (except for ADS, see A7). The requirement in ITS LCO 3.3.5.1 that the ECCS instrumentation for each Function in Table 3.3.5.1-1 must be OPERABLE, the details in Table 3.3.5.1-1 for each Function (Required Channels per Function or per pump), the definition of Operability and the associated Surveillance Requirements will ensure the instrumentation remains Operable. As such, this detail (number of trip systems) is not required to be in the ITS to rovide adequate protection of public health and safety. Changes to the ases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the ITS.

LA3 The detail in the CTS Table 3.2-2 "Trip Level Setting" column for Function 17 (Condensate Storage Tank Low Level) that the setting is equivalent to 15,600 gallons available is proposed to be relocated to the Bases. The requirement in ITS LCO 3.3.5.1 that the ECCS instrumentation for each Function in Table 3.3.5.1-1 shall be OPERABLE, the Allowable Value for Function 3.d (Condensate Storage Tank Level Low) of > 59.5 inches, and the specified Surveillances will ensure that the associated instrumentation remains OPERABLE. As such, this detail JAFNPP Page 10 of 14 Revision F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

LA3 (continued) is not required to be in the ITS to provide adequate protection of public health and safety. Changes to the Bases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the ITS.

LA4 The detail in CTS Table 3.2-2 that the Trip Level Setting of the Reactor Water Level Trip Functions (1, 2, 3, 5, and 7) is referenced from the Top of Active Fuel (TAF) is proposed to be relocated to the Bases. CTS 1.0.Z definition specifies that the Top of Active Fuel, corresponding to the top of the enriched fuel column of each fuel bundle, is located 352.5 inches above vessel zero, which is the lowest point in the inside bottom of the reactor pressure vessel. (See General Electric drawing No. 919D690BD). These details are also proposed to be relocated to the Bases. The requirement in ITS LCO 3.3.5.1 that the ECCS instrumentation for each Function in Table 3.3.5.1-1 shall be OPERABLE, the requirements in the Table including the Allowable Value for Functions l.a, 2.a, 2.e, 3.a, 3.c, 4.a and 5.a, the definition of Operability, the proposed Actions, and Surveillance Requirements are adequate to ensure the instrumentation is properly maintained. In addition, the Bases includes a statement that the Allowable Value is referenced from a level of water 352.56 inches above the lowest point in the inside bottom of the reactor pressure vessel and also corresponds to the top of a 144 inch fuel column. As such, these details are not required to be in the ITS to provide adequate protection of public health and safety. Changes to the Bases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the ITS.

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li Not Used.

JAFNPP Page 11 of 14 Revi si on F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 CTS Table 3.2-2 Item 9 directs entry into Note 6 which requires the repair of one or more inoperable channels in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The current action is independent of the plant conditions. An option has been provided in the ITS for these same Functions if operating in MODES 4 or

5. ITS Table 3.3.5.1 Functions 1.c and 2.c will now require entry into ITS 3.3.5.1 ACTION B and Required Action B.3 will require to place inoperable channels in the tripped condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if operating in MODES 4 or 5. The allowance to restore the channels to operable status is still applicable since LCO 3.0.2 will allow this action to be exited if the channel is restored to operable status prior to the Completion Time. In MODES 4 and 5 the reactor pressure is low and the pressure setpoint of all instrument channels should already be actuated. Therefore, placing the channel(s) in trip accomplishes the Function of the instrumentation. With the channels in trip the Core Spray System and Low Pressure Coolant Injection System injection valves will not open since the opening of these valves is also dependent on a Loss of Coolant Signal in conjunction with low reactor pressure.

Therefore, placing one or more channels in trip is acceptable if operating in MODES 4 and 5.

L3 CTS Table 3.2-2 Item 24 (Reactor Pressure- Low) is currently required whenever the associated Low Pressure Coolant Injection (LPCI) System is required to be Operable as specified in CTS 3.2.B. In the ITS this Applicability has been reduced. ITS 3.3.5.1 Function 2.d will only require this Function to be Operable in MODE 1, 2 and 3 when the associated discharge valve is open (ITS Table 3.3.5.1-1 Footnote c).

With the valve(s) closed, the function of the instrumentation has been erformed; thus, the Function is not required. In MODES 4 and 5, the oop injection location is not critical since LPCI injection through the recirculation loop in either direction will still ensure that LPCI flow reaches the core (i.e., there is no significant reactor back pressure).

Therefore, this change in the CTS Applicability is acceptable since the associated LPCI loop will still be able to perform its associated safety function.

L4 CTS Table 3.2-2 Action Notes 2.A and 6.A require action to be taken in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> upon discovery of loss of initiation capability. ITS 3.3.5.1 Required Actions B.2 and C.1 require these same actions but Note 1 has been added to both of these actions which will only require these actions to be taken during MODES 1, 2 and 3. Note 2 simply clarifies which Functions these actions are applicable to. This change is less restrictive since it will allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore initiation capability as governed by ITS 3.3.5.1 Required Actions B.3 and C.2. In MODES 4 and 5, the specific initiation time of the low pressure ECCS is not assumed and the probability of a LOCA is lower. Thus, a total loss JAFNPP Page 12 of 14 Revision F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L4 (continued) of initiation capability for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed during MODES 4 and 5.

L5- Not Used.

L6 The CTS Table 3.2-2 Trip Level Settings (Allowable Value) for Item 6 (Containment High Pressure), which prevents inadvertent operation of containment spray during accident conditions, Item 9 (Reactor Low Pressure), which provides an open signal to the Core Spray (CS) and Low Pressure Coolant Injection (LPCI) System injection valves, and Item 24 (Reactor Low Pressure), which provides a close signal to the recirculation pump discharge valves, have been revised. The Allowable Value for Item 6 has been changed from > 1 psig and < 2.7 psig to 2 1 psig to ! 2.7 psig (ITS Table 3.3.5.1 Function 2.h). The Allowable Value for Item 9 has been changed from 2 450 psig to 2 410 psig and

  • 490 psig (ITS Table 3.3.5.1-1 Functions 1.c for CS and 2.c for LPCI).

The Trip Level Setting for Item 24 is 285 to 335 psig. This has been changed to Ž 295 psig (ITS Table 3.3.5.1-1 Function 2.d). The Allowable Value for Functions 1.c and 2.c is low enough to prevent overpressuring the equipment in the low pressure ECCS, but high enough to ensure that the ECCS injection prevents the fuel peak cladding temperature from exceeding the limits of 10 CFR 50.46. The Allowable Value for Function 2.d is chosen to ensure that the valves close prior to commencement of LPCI injection flow into the core, as assumed in the safety analysis.

The Allowable Value for Function 2.h is low enough to ensure containment spray is not isolated when needed, but high enough to ensure isolation of containment spray prior to establishing a negative containment pressure. The Allowable Values have been established consistent with the NYPA Engineering Standards Manual, IES-3A, "Instrument Loop Accuracy and Setpoint Calculation Methodology." The methodology used to determine the Allowable Values are consistent with the methodology discussed in ISA-S67.04-1994, Part II, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation.

Any changes to the safety analysis limits, applied in the methodologies, were evaluated and confirmed as ensuring safety analysis licensing acceptance limits are maintained. All design limits, applied in the methodologies, were confirmed as ensuring that applicable design requirements of the associated systems are maintained. The use of this methodology for establishing Allowable Values and Trip Setpoints ensures design or safety analysis limits are not exceeded in the event of transients or accidents and accounts for uncertainties and environmental conditions. This change is consistent with NUREG-1433, Revision 1.

JAFNPP Page 13 of 14 Revision F

DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC) (continued)

L7 CTS Table 3.2-2, Item 11 specifies the trip level setting for the Core Spray Pump Start Time to be 11 +/- 1.34 seconds. CTS Table 3.2-2, Item 12 specifies the trip level setting for the RHR (LPCI) Pump Start Timers to be 1.25 +/- 0.26 seconds for the 1st pump in loops A and B and 6.0 +/- 0.73 seconds for the 2nd pump in loops A and B. In ITS Table 3.3.5.1-1 the Allowable Value for Function l.d (Core Spray Pump Start-Time Delay Relay) is < 12.34 seconds while the Allowable Value for Function 2.f (LPCI Start-Time Delay Relays) is < 1.51 seconds for the A and D pumps and g 6.73 seconds for the B and C pumps. The proposed Allowable Values for the time delay relays are consistent with the upper limit of the CTS trip level settings (e.g., 11 + 1.34 seconds). The lower limit for the timers have been deleted. The Allowable Values included in ITS 3.3.5.1 ensure ECCS will operate within the time period assumed in the accident analyses. The current timer settings also ensure that the time delays are long enough so that most of the starting transient of a pump is complete before starting a subsequent pump. This requirement is maintained since a more restrictive requirement has been added for AC Sources in ITS 3.8.1. SR 3.8.1.13 requires the verification that the interval between each sequenced load block is within the minimum design interval. If this new requirement is not met, then the associated EDG subsystem and reserve circuit must be declared inoperable and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> are provided to restore the EDG or reserve circuit to operable status.

This allowed out of service time is shorter than that currently provided by CTS Table 3.2-2 (Note 7.A). Therefore, the removal of the low limit for the timers from CTS Table 3.2-2 based on the addition of the requirement in ITS 3.8.1 is acceptable.

TECHNICAL CHANGES - RELOCATIONS None JAFNPP Page 14 of 14 Revision F

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.5.1 Emergency Core Cooling System (ECCS)

Instrumentation NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC) FOR LESS RESTRICTIVE CHANGES

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li CHANGE Not Used.

JAFNPP Page 1 of 13 Revision F

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 CHANGE New York Power Authority has evaluated the proposed Technical Specification change identified as "Technical Changes - Less Restrictive" and has determined that it does not involve a significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The bases for the determination that the proposed change does not involve a significant hazards consideration are discussed below.

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

This change will allow the Reactor Pressure- Low (Injection Permissive) channels associated with the Core Spray and Low Pressure Coolant Injection (LPCI) System to be placed in trip instead of restored to service in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in MODES 4 and 5. The allowance to restore the channels to operable status is still applicable since LCO 3.0.2 will allow this action to be exited if the channel is restored to operable status prior to the Completion Time. The proposed change does not affect the probability of an accident. The ECCS System instrumentation is not assumed to be an initiator of any analyzed event. In MODES 4 and 5 the reactor pressure is low and the pressure setpoint of all instrument channels should already be actuated. Therefore, placing the channel(s) in trip accomplishes the Function of the instrumentation.

With the channels in trip the CS and LPCI injection valves will not open since the opening of these valves is also dependent on a Loss of Coolant Signal in conjunction with low reactor pressure. Therefore, placing one or more channels in trip is acceptable if operating in MODES 4 and 5 since the safety function will be met. This change will ensure the associated System is available to mitigate any event requiring it to operate in MODES 4 and 5. Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

This change will allow the Reactor Pressure- Low (Injection Permissive) channels associated with the Core Spray and Low Pressure Coolant Injection (LPCI) System to be placed in trip instead of restored to service in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in MODES 4 and 5. This change will not physically JAFNPP Page 2 of 13 Revision F

/

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 CHANGE

2. (continued) alter the plant (no new or different type of equipment will be installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. Does this change involve a significant reduction in a margin of safety?

This change will allow the Reactor Pressure- Low (Injection Permissive) channels associated with the Core Spray and Low Pressure Coolant Injection (LPCI) System to be placed in trip instead of restored to service in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in MODES 4 and 5. The allowance to restore the channels to operable status is still applicable since LCO 3.0.2 will allow this action to be exited if the channel is restored to operable status prior to the Completion Time. In MODES 4 and 5 the reactor pressure is low and the pressure setpoint of all instrument channels should already be actuated. Therefore, placing the channel(s) in trip accomplishes the Function of the instrumentation. With the channels in trip the CS and LPCI injection valves will not open since the opening of these valves is also dependent on a Loss of Coolant Signal in conjunction with low reactor pressure. Therefore, placing one or more channels in trip is acceptable if operating in MODES 4 and 5 since the safety function will be met. This change will ensure the associated System is available to mitigate any event requiring it to operate in MODES 4 and 5. Therefore no question of safety exists. Therefore, this change will not involve a significant reduction in a margin of safety.

JAFNPP Page 3 of 13 Revision F

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L3 CHANGE New York Power Authority has evaluated the proposed Technical Specification change identified as "Technical Changes - Less Restrictive" and has determined that it does not involve a significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The bases for the determination that the proposed change does not involve a significant hazards consideration are discussed below.

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

This change will only require the Reactor Pressure-Low (Recirculation Discharge Valve Permissive) Function channels to be Operable in MODES 1, 2 and 3 with the associated discharge valve open. The ECCS System instrumentation is not assumed to be an initiator of any analyzed event.

Therefore the proposed change does not affect the probability of an accident. With the recirculation discharge valve closed, the function of the instrumentation has been performed: thus, the Function is not required. In MODES 4 and 5, the loop injection location is not critical since LPCI injection through the recirculation loop in either direction will still ensure that LPCI flow reaches the core (i.e., there is no significant reactor back pressure). Therefore this change in the CTS Applicability is acceptable since the associated LPCI loop will still be able to perform its associated safety function. The consequences of an accident are not affected by changing this applicability since the LPCI injection flow will enter the vessel and the safety analysis assumptions will be met. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

This change will only require the Reactor Pressure- Low (Recirculation Discharge Valve Permissive) Function channels to be Operable in MODES 1, 2 and 3 with the associated discharge valve open. The proposed change will not create the possibility of an accident. This change will not physically alter the plant (no new or different type of equipment will be installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

JAFNPP Page 4 of 13 Revision F

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L3 CHANGE

3. Does this change involve a significant reduction in a margin of safety?

This change will only require the Reactor Pressure-Low (Recirculation Discharge Valve Permissive) Function channels to be Operable in MODES 1, 2 and 3 with the associated discharge valve open. With the recirculation discharge valve closed, the function of the instrumentation has been performed; thus, the Function is not required.

In MODES 4 and 5, the loop injection location is not critical since LPCI injection through the recirculation loop in either direction will still ensure that LPCI flow reaches the core (i.e., there is no significant reactor back pressure). Therefore this change in the CTS Applicability is acceptable since the associated LPCI loop will still be able to perform its associated safety function. This change will ensure the associated System pathway is available to mitigate any event requiring the LPCI System to operate. Therefore no question of safety exists.

Therefore, this change will not involve a significant reduction in a margin of safety.

JAFNPP Page 5 of 13 Revision F

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L4 CHANGE New York Power Authority has evaluated the proposed Technical Specification change identified as "Technical Changes - Less Restrictive" and has determined that it does not involve a significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92. The bases for the determination that the proposed change does not involve a significant hazards consideration are discussed below.

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

The proposed change will allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore inoperable Low Pressure Coolant Injection (LPCI) and Core Spray (CS) start time delay relay channels to Operable status in MODES 4 and 5 whether or not automatic initiation capability is maintained. The ECCS System instrumentation is not assumed to be an initiator of any analyzed event.

Therefore the proposed change does not affect the probability of an accident. In MODES 4 and 5, the specific initiation time of the low pressure ECCS is not assumed and the probability of a LOCA is lower.

The ECCS System is required in MODES 4 and 5 to mitigate the consequences of an inadvertent draindown event. Automatic initiation is not required in this condition since one LPCI subsystem may be aligned in the Residual Heat Removal Shutdown Cooling mode of operation. In this condition manual alignment to the injection mode will be necessary to mitigate the consequences of any inadvertent draindown event.

Therefore the consequences of any inadvertent draindown event in these conditions will be bounded by the consequences of the same event if manual alignment of the required LPCI subsystem is necessary.

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

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

The proposed change will allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore inoperable Low Pressure Coolant Injection (LPCI) and Core Spray (CS) start time delay relay channels to Operable status in MODES 4 and 5 whether or not automatic initiation capability is maintained. This change will not physically alter the plant (no new or different type of equipment will be installed). Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

JAFNPP Page 6 of 13 Revi si on F

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L4 CHANGE

3. Does this change involve a significant reduction in a margin of safety?

The proposed change will allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore inoperable Low Pressure Coolant Injection (LPCI) and Core Spray (CS) start time delay relay channels to Operable status in MODES 4 and 5 whether or not automatic initiation capability is maintained. In MODES 4 and 5, the specific initiation time of the low pressure ECCS is not assumed and the probability of a LOCA is lower. The ECCS System is required in MODES 4 and 5 to mitigate the consequences of an inadvertent draindown event.

Automatic initiation is not required in this condition since one LPCI subsystem may be aligned in the Residual Heat Removal Shutdown Cooling mode of operation. In this condition manual alignment to the injection mode will be necessary to mitigate the consequences of any inadvertent draindown event. Therefore the consequences of any inadvertent draindown event in these conditions will be bounded by the consequences of the same event if manual alignment of the required LPCI subsystem is necessary. The margin of safety is not significantly reduced since automatic initiation of the low pressure ECCS Systems is not required in these conditions. Therefore, this change will not involve a significant reduction in a margin of safety.

JAFNPP Page 7 of 13 Revision F

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC)

L5 CHANGE Not Used.

JAFNPP Page 8 of 13 Revision F

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L6 CHANGE The Licensee has evaluated the proposed Technical Specification change j identified as "Technical Changes - Less Restrictive" and has determined that it does not involve a significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92.

The bases for thedetermination that the proposed change does not involve a significant hazards consideration are discussed below.

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

The trip setpoints (Allowable Values) for the Reactor Low Pressure and Containment High Pressure Functions have been revised. The Allowable Value for Item 6 has been changed from > 1 psig and < 2.7psig to 11 psig and

  • 2.7 psig (ITS Table 3.3.5.1-1 Function 2.h). Allowable Value for Item 9 has been changed from 2 450 psig to 2 410 psig and
  • 490 psig (ITS Table 3.3.5.1-1 Functions 1.c for CS and 2.c for LPCI).

The Trip Level Setting for Item 24 is 285 to 335 psig. This has been changed to > 295 psig (ITS Table 3.3.5.1-1 Function 2.d). The ECCS System instrumentation is not assumed to be an initiator of any analyzed event. Therefore, this change does not significantly increase the probability of an accident previoulsy evaluated. The role of the ECCS System instrumentation is in mitigating and thereby limiting the consequences of an accident. The Allowable Value for Function 2.h is low enough to ensure containment spray is not isolated when needed, but high enough to ensure isolation of containment spray prior to establishing a negative containment pressure. The Allowable Value for Functions 1.c and 2.c is low enough to prevent overpressuring the equipment in the low pressure ECCS, but high enough to ensure that the ECCS injection prevents the fuel peak cladding temperature from exceeding the limits fo 10 CFR 50.46. The Allowable Value for Function 2.d is chosen to ensure that the valves close prior to commencement of LPCI injection flow into the core, as assumed in the safety analysis.

The Allowable Values have been established consistent with the NYPA Engineering Standards Manual, IES-3A, "Instrument Loop Accuracy and Setpoint Calculation Methodology." The methodology used to determine the Allowable Values are consistent with the methodology discussed in ISA-S67.04-1994, Part II, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation. The proposed change still provides assurance that ECCS System instrumentation Operability is maintained consistent with analysis assumptions. This change will not alter assumptions relative to the mitigation of an accident or transient event. Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated.

JAFNPP Page 9 of 13 Revision F

,0 NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L6 CHANGE (continued)

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

The trip setpoints (Allowable Values) for the Reactor Low Pressure Functions have been revised. The proposed change to Allowable Values will not create the possibility of an accident. This change will not hysically alter the plant (no new or different type of equipment will e installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

The trip setpoints (Allowable Values) for the Reactor Low Pressure and Containment High Pressure Functions have been revised. The Allowable Value for Item 6 has been changed from > 1 psig and < 2.7psig to Ž1 psig and g 2.7 psig (ITS Table 3.3.5.1-1 Function 2.h). The Allowable Value for Item 9 has been changed from > 450 psig to > 410 psig and <

490 psig (ITS Table 3.3.5.1-1 Functions-l.c for CS and 2.c for LPCI)_

The Trip Level Setting for Item 24 is 285 to 335 psig. This has been changed to > 295 psig (ITS Table 3.3.5.1-1 Function 2.d). The role of 1L6 the ECCS System instrumentation is in mitigating and thereby limiting the consequences of an accident. The Allowable Value for Functions 1.c and 2.c is low enough to prevent overpressuring the equipment in the low pressure ECCS, but high enough to ensure that the ECCS injection prevents the fuel peak cladding temperature from exceeding the limits of 10 CFR 50.46. The Allowable Value for Function 2.h is low enough to ensure containment spray is not isolated when needed, but high enough to ensure isolation of containment spray prior to establishing a negative containment pressure. The Allowable Value for Function 2.d is chosen to ensure that the valves close prior to commencement of LPCI injection flow into the core, as assumed in the safety analysis. The Allowable Values have been established consistent with the NYPA Engineering Standards Manual, IES-3A, "Instrument Loop Accuracy and Setpoint Calculation Methodology." The methodology used to determine the Allowable Values are consistent with the methodology discussed in ISA

$67.04-1994, Part II, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation. Therefore, the margin of safety is not significantly reduced because the proposed changes Technical Specification Values will continue to provide the necessary assurance that the ECCS System instrumentation will automatically initiate when required. The safety analysis assumptions will still be JAFNPP Page 10 of 13 Revi si on F

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L6 CHANGE

3. (continued) maintained, thus, no question of safety exists. Therefore, this change will not involve a significant reduction in a margin of safety.

JAFNPP Page 11 of 13 Revision F

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L7 CHANGE The Licensee has evaluated the proposed Technical Specification change identified as "Technical Changes - Less Restrictive' and has determined that it does not involve a significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the determination that the proposed change does not involve a significant hazards consideration are discussed below.

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

The proposed change deletes the lower limit of the ECCS pump time delay relays in the ECCS Instrument Specification, however a new Surveillance has been added to the AC Sources-Operating Specification (ITS 3.8.1) which requires the verification that the interval between each sequenced load block is within the minimum design interval. The ECCS System instrumentation is not assumed to be an initiator of any analyzed event. Therefore, the proposed change does not affect the probability of an accident. The proposed Allowable Values for the time delays relays are consistent with the upper limit of the CTS trip level settings (e.g., 11 + 1.34 seconds). The lower limit for the timers have been deleted. The Allowable Values included in ITS 3.3.5.1 ensure ECCS will operate within the time period assumed in the accident analyses.

The current timer settings also ensure that the time delays are long enough so that most of the starting transient of a pump is complete before starting a subsequent pump. This requirement is maintianed since a more restrictive requirement has been added for AC Sources-Operating in ITS 3.8.1. SR 3.8.1.13 requires the verification that the interval between each sequenced load block is within the minimum design interval.

If this new requirement is not met, then the associated EDG subsystem and reserve circuit must be declared inoperable and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> are provided to restore the EDG or reserve circuit to operable status. This allowed out of service time is shorter than that currently provided by CTS Table 3.2-2 (Note 7.A). Therefore, the removal of the low limit for the times from CTS Table 3.7-2 based on the addition of the requirement in ITS 3.8.1 is acceptable. This change will not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

The proposed change deletes the lower limit of the ECCS pump time delay relays in the ECCS Instrument Specification, however a new Surveillance has been added to the AC Sources-Operating Specification (ITS 3.8.1)

JAFNPP Page 12 of 13 Revi si on F

NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.3.5.1 ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L7 CHANGE

2. (continued) which requires the verification that the interval between each sequenced load block is within the minimum design interval. The ECCS System instrumentation is not assumed to be an initiator of any analyzed event.

This change will not physically alter the plant (no new or different type of equipment will be installed). Therefore, this change will not create the possibility of a new or different kind of accident from any previously evaluated.

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

The proposed change deletes the lower limit of the ECCS pump time delay relays in the ECCS Instrument Specification, however a new Surveillance has been added to the AC Sources-Operating Specification (ITS 3.8.1) which requires the verification that the interval between each sequenced load block is within the minimum design interval. The proposed requirements will continue to ensure that the ECCS pumps will initiate in sufficient time to cool the core during a Loss of Coolant Accident and at the same time ensure that the time delays are long enough so that most of the starting transient of a pump is complete before starting a subsequent pump. Therefore, this change will not involve a significant reduction in a margin of safety.

JAFNPP Page 13 of 13 Revision F

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.3.5.1 Emergency Core Cooling System (ECCS)

Instrumentation MARKUP OF NUREG-1433, REVISION 1 SPECIFICATION.

ECCS Instrumentation 3.3.5.1 3.3 INSTRUMENTATION 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation LCO 3.3.5.1 The ECCS instrumentation for each Function in Table 3.3.5.1-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.1-1.

ACTIONS ITE ----------------------------

[A23 Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME LA A. One or more channels A.1 Enter the Condition Immediately inoperable, referenced in Table 3.3.5.1-1 for the channel.

B. As required by B. I ------ NOTES-----

Required Action A.1 1. Only applicable

] and referenced in Table 3.3.5.1-1.

in MODES 1, 2, and 3.

)

2. Only applicable for Functions Co), 1.a, 1.b, 2.a, and 2.b.

Declare supported 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from feature(s) inoperable discovery of when its redundant loss of feature ECCS initiation initiation capability capability for is inoperable. feature(s) in both divisions AND (continued)

A.

BWR/4 STS 3.3-36 Rev 1, 04/07/95

ECCS Instrumentation 3.3.5.1 A1T TA*M CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2 -------- NOTE--------

Only applicable for Functions 3.a and 3.b.

Declare High Pressure I hour from Coolant Injection discovery of (HPCI) System loss of HPCI inoperable, initiation capability AND B.3 Place channel in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> trip.

C. As required by C.1 -------- NOTES-----

Required Action A.1 1. Only applicable and referenced in in MODES 1, 2, Table 3.3.5.1-1. and 3.

K- J

2. Only applicable or Functions

.c, 2c, 2.d,

-3, and 2.f.

'*47 q)c~ Declare supported 1hour from feature(s) inoperable discovery of CLIO when its redundant loss of feature ECCS initiation initiation capability capability for is inoperable. feature(s) in both divisions AND C.2 Restore channel to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE status.

___________________ I (continued)

BWR/4 STS 3.3-37 Rev 1, 04/07/95

ECCS Instrumentation 3.3.5.1 A P'TT nkl* / *An÷'* *lmnel

  • AL&,I UIr3 &L. UIl .IIIUCU_

CONDITION REQUIRED ACTION COMPLETION TIME D. As required by D.1 -------- NOTE------

Required Action A.- Only applicable if and referenced in HPCI pump suction is Table 3.3.5.1-1. not aligned to the suppression pool.

Declare HPCI System 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from inoperable. discovery of loss of HPCI initiation capability AND D.2.1 Place channel in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> trip.

OR D.2.2 Align the HPCI pump 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> suction to the suppression pool.

E. As required by E. 1 ------- NOTES-----

Required Action A.1 1. Only applicable and referenced in in MODES 1, 2, Table 3.3.5.1-1. and 3.

r-mg 2. Only applicable for Functions 1.0(

and 2.g.

.0 Declare supported I hour from feature(s) inoperable discovery of when its redundant loss of feature ECCS initiation initiation capability capability for is inoperable. subsystems in both divisions AND (continued)

___________________ I I BWR/4 STS 3.3-38 Rev 1, 04/07/95

j ECCS Instrumentation 3.3.5.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. (continued) E.2 Restore channel to 7 days OPERABLE status.

F. As required by F. 1 Declare Automatic 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from Required Action A.1 Depressurization discovery of and referenced in System (ADS) valves loss of ADS Table 3.3.5.1-1. inoperable. initiation capability in both trip L~iv systems AND F.2 Place channel in 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from trip. discovery of inoperable channel concurrent with HPCI or reactor core isolation cooling (RCIC) inoperable AND 8 days (continued)

BWR/4 STS 3.3-39 Rev 1, 04/07/95

ECCS Instrumentation 3.3.5.1 CONDITION REQUIRED ACTION COMPLETION TIME G. As required by G.1 ------- $T- - -

Required Action A.1 Only app icable fc*

SFunctio s4.,.,

and referenced in 4.f, 4 g, 5.c, 5 e, Table 3.3.5.1-1.

5.9d 5.g.

Declare ADS valves 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from inoperable. discovery of loss of ADS initiation capability in both trip systems AND G.2 Restore channel to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from OPERABLE status. discovery of inoperable channel concurrent with HPCI or RCIC inoperable AND 8 days I i H. Required Action and H.1 Declare associated Immediately associated Completion supported feature(s)

WKSz Time of Condition B, inoperable.

C, D, E, F, or G not I C4e met.

BWR/4 STS 3.3-40 Rev 1, 04/07/95

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS


NOTES

1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function.
2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required k3 H,-i

/17v Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 3.c, 3.f, and 3.g; and (b) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions other than 3.c, 3.f, and 3.g provided the associated Function or the redundant Function maintains ECCS initiation capability.

LN.

BWR/4 STS 3.3-41 Rev 1, 04/07/95 REVISION F

ECCS Instrumentat ion 3.3.5.1 labis 3.3.5.1-1 Cpwg I sf 6) gmelgency ewe. Coalting Sytme lrwnsmmntat ion mom cotOU "owl UlcIFIN RaCTNAM VALUEM CZT5IOS ACrIau A.1 auoiUuIEMNTS FUNCTION FUNCTION

1. car* Spray SYStM

.61 b) 0 1(

a. Reactor Vessel. waer 1,2,3f S3.3.5.1._

LeWL - LOW Low Low$ 4(a) SOa)

I U3.3.5.1.5 6 Levsk~

b. DuweL I 1,2.3 I se 3.3.5. 1.1 S tA(Ips ig Pressure - Nig a3 3.35.1. 2i ur YL- (16)] (0(4
0R 3.3.5:1.5'. J 1,2.3 sm 3. 3. 5 .1.5 l C. Reactor nM Pressure - Low "CT th..~ (injection Permissive)

E L7. 1) C s 3.3.5.1 .1 1 4012g St3.3.5. 1.5

/.M. 5(a) s3 3.3.5.1.6 SR

.3..11 14 SR 3351. n VLNSLfý S ~

core Spay Pww .23 Discharge Plow-Low () 5 a

2. Low Pwres"ma Cosimit injection CMPI) Systme I Si 3.3.5.1.1 t
a. Rawor Voesset water 123 N

Lwvel -Low Low LOf ovt"I 4()J5s C) 5 a R 3.3.5.1.

Cb) 3.3-42 Rev 1~,04/07/9S WWR/4 STS REVIIS:NJI F

ý5~ INSERT Function l.d

_L_7] d. Core Spray Pump Start-Time Delay 1,2,3, 4 (a). 5 (a) 1 per pump C SR 3.3.5.1.5 SR 3.3.5.1.6 S12.34 seconds 14ý Relay INSERT Function lf

f. Core Spray Pump 1,2,3. 1 per pump E SR 3.3.5.1.3 S90 psig and Discharge SR 3.3.5.1.6 S 110 psig Pressure - High 4 (a). 5 (a)

(Bypass)

Insert Page B 3.3-42 Revision F

/

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 2 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS NODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REWIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQ.IIEMENTS VALUE

2. LPCI System (continued)

S SR 3.3.5.1.1 S .* Psig 1,2,3 / *

(-7 3 . 2 -z(63J - b. Dryettl Pressure - High SR3.3.5.1.* .

rrT qo -z _0 SR 3.3.5.1.5 SR 3.3.5.1.6 Reactor 1,2,3 04t C SR 3.3.5.1.1 1ýAcz SR 3.3.5.1.2 and .

KF3- -20) Pressure - Low 3.3.5.1.*- fj (Injection Permissive) *- SR SR 3.3.5.1.6 s

t) tie 39.3.-5-.1D 4(a), 5 (a) a4f) B SR 3.3.5.1.1 a SR3.3.5.1.2 and~

ý:

ý33 5R33.5.1 ig SR 3.351 VA~

L 3.3.5.1.6 Reactor 1(c),2(c), C SR 3.3.5.1.1 ,

rrJ.3.2-,4Z*7 e Pressure - Low (RecircuLation 3 (c)

R 3.3.5.1.2 3R.3.5.1 .6 Discharge VaLve SR 3:35:

Permissive) SR 3.33.5.N 1,2,3 3.3.5.1.1 t 03 Reactor Vessel Shroud B SR 3.3.5.1 2 C*C. Level LeveL 0

& V Lab) SSR SR 3.3.5.1.5, 3.3.5.1.66 Low Pressuri* Coolant 1,2,3,

-dope C SR SR 3.3.5.1.5 3.3.5.1.6 Injection PtuMp p(Iper 4 (a), 5 (a)

Start - Time Delay Relay Punps AgD second 6F Pumi.*

4 (ce3t5I nueds.L t cont inued) en associated sbsystem(s) are required to be OPERASLEý L ) I

-r 'ie0- (b) ALtso required to initiate the associated Iate e sociated PSW # atirvave th associated recirculation pump discharge valve open.

ýý ) cc) Wi BWR/4 STS 3.3-43 Rev 1, 04/07/95 REVISION F

ECCS Instrumentation 3.3.5.1 TabLe 3.3.5.1-1 (page 3 of 6)

Emergency Core CooLing System Instrumentation APPLICABLE CONDITIONS REQUIRED REFERENCED NODES OR OTHER CHANNELS FROM PER REQUIRED SURVEILLANCE ALLOWABLE SPECIFIED VALUE FUNCTION ACTION A.1 REQUIREMENTS FUNCTION CONDITIONS PLO r (15

,2-2 3.

High Pressure Coolant L -" .

Injection (HPCI) System 3."~ a. 1, B SR 3.3.5.1 inches, Reactor Vessel Water SR3.51 Level-Lo Le) 25 LOW& Lev.*~~S3~

2(d (ed)

L*

ýS~R 3,o3

.35..ý5"1, 66 3.351.

SR 3.3.5.1.5 psig 1, tS SR 3.3.5.1.1 3.3.5.1.2 Drywetl Pressure - High 2(d) 3 (d) L O R 3.3.5.1.6 C SR 3.3.5.1.1 -d 1,

CT3.Z 2.() C. Reactor Vessel Water p23-. *

- R SR 3.3.5.1.2 3.3.5.1 ins aes Level - Highg Level 8 2 (d), 3 (d) SR 3.3.5.1.5 1,

Condensate Storage Tank Level - Low 2(d), (d) 3 8 SR 3.3.5.1.6 Do

[_7YZ (4 )] Suppression Pool Water 1,

Level - High 2(d), 3 (d) SR 3.3.5.1.6

)* SR 3.3.5.1.6 tA;O] (d) With reactor steam dome pressure

  • 3.3-44 Rev 1, 04/07/95 BWR/4 STS

INSERT Function 2.h 1.2.3 4 B SR SR 3.3.5.1.3 3.3.5.1.6 t< 2.7 1 psig psigand

h. Containment Pressure -High I

Insert Page 3.3-44

ECCS Instrumentation 3.3.5.1 Tabte 3.3.5.1-1 (page 4 of 6)

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

3. HPCI System

- (continued)

Ricah Pressure CooLant 1, f1i E , 'i1ý f-Injection PuMp Discharge FIow - Low 2 (d), 3 (d) IL (Bypass) 2 (d), 3 (d)

4. Automatic Depressurization System (ADS) Trip System A 3.3.5.1.2 inches c L- ft 3.3.5.1.&

3.3.5.1.5 3.3.5.1.6 F SR .5.1.1 s El. psig S *.3.5.1.2 R 3.3.5.1.33 SR 3.3.5.1.5 SR 3.3.5.1.6 t1i 3 -i

  • nc5.1.5 Automatic 1, 6'tR Er-2-2 Depressurization 3.3.5.1. seconds system Initiation 2 (d), 3 (d)

V Cz(~J Timer Reactor Vessel Water (l 1,t SR SR 3 . 3 .5.1.$12(/-t 3.3.5.1.2 i nches LowgLevel 3 )

LaveL --**~(d cJC 2,3(d) 2 SR 3.3.5.1.5 SR 3.3.5.1.6 _( 0 1 7(IJ 2 G and

"(. Core Spray Pump Discharge 12 2(d), 3(d)

Pressure - Hi gh 3 c #a~gb7) (continued) 4 (d) With reactor steam dome pressure ), 150ýpsig.

3.3-45 Rev 1, 04/07/95 BWR/4 STS REVISION F

INSERT Function 3.q

g. High Pressure Coolant 1, 1 E SR 3.3.5.1.3 S25 psig Injection Pump Discharge SR 3.3.5.1.6 and Pressure- High (Byasss) 2 (d), 3 (d)

S80 psig Insert Page 3.3-45

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 5 of 6)

Emergency Core Cooling System Instrumentation IAMU I APPLICABLE APPL ICABLE lA.T;MU&

I Ilma REFERENCED MODES OR REQUIRED CHANNELS FROM OTHER ALLOWABLE PER REWUIRED SPECIFIED SURVEILLANCE REQUIREMENTS VALUE CONDITIONS FUNCTION ACTION A.1 wJ'r FUNCTION 4.- ADS Trip System A (continued) to LI psig9

~ ,(iýj)J Lowi Pressure Coolant 1, G and Injection Pump so psig Discharge 2 (d), 3 (d)

Pressure - Hi gh Automatic Depressuri zati

=g. System Low W* er Levw Actuation mer 7h. ManuaL Initia 8;

5. ADS Trip System B 1 F SR 3.3.5.1.;, 1 coa T, 73.2-1 (2] a. Reactor Vessel Water SR 3.3.5.1.2 1 inches

~-2Li Y Level-Lowi Low Lov SR 3.3.5.1.6 2(d), 3(d)

BWR/4 STS 3.3-47 Rev 1, 04/07/95