L-99-029, Forwards Revised Response to Chapter 3.1 RAI Requested in 990726 Conference Call,Rai Response Related to Beyond Scope Issue for Chapter 3.5 Requested by Conference Call on 990805 & RAI Response to Chapter 3.8 Requested on 990615 & 0727
| ML20211D037 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/19/1999 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NEL-99-0293, NUDOCS 9908260154 | |
| Download: ML20211D037 (49) | |
Text
e Dyre M:r:y
. S:uth:rn Nuclear Vice President Optrating Ccmpany. loc.
Farley Project.
Post Oflice Box 1295 Birmingham, Alabama 35201
. Tel 205 992.5131 SOUTHERN August 19,1999 COMPANY Energy to Serve Your World" Docket Nos.
50-348 NEL-99-0293 50-364 U. S. Nuclear Regulatory Commission l
ATTN.: Document Control Desk Washington, DC 20555-0001 Joseph'M. Farley Nuclear Plant Revised Response to Request for Additional Information Related to Conversion to the Improved Technical Specifications - Chapter 3.1 and Response to Reauests for Additional Information '- Beyond Scope issues - Chapters 3.5 and 3.8 Ladies and Gentlemen:
By letters dated March 12,1998, and April 24,1998, Southern Nuclear Operating Company (SNC) submitted the Farley Nuclear Plant (FNP)- specific Improved Technical Specifications (ITS) conversion documentation packages in accordance with 10 CFR 50.90. By letter dated August 20,
~
f 1998, SNC submitted an electronic copy of the Discussion of Changes (DOCS) and Significant Hazards Evaluations (SHEs) associated with the ITS conversion. By letter dated November 20,1998, SNC submitted responses to a Request for Additional Information (RAI) for Chapters 3.6 and 5.0. By letter dated February 20,1999, SNC submitted responses to a RAI for Chapter 3.4. By letters (2) dated April 30,1999, SNC submitted responses to RAls for Chapters 3.1,3.2,3.5,3.7,3.8, and 3.9.
By [[letter::L-99-021, Forwards Response to RAI Re Conversion to ITSs for Chapter 3.3.Attachment II Includes Proposed Revs to Previously Submitted LAR Re Rais,Grouped by RAI number.Clean-typed Copies of Affected ITS Pages Not Included|letter dated May 28,1999]], SNC submitted responses to a RAI for Chapter 3.3. By letter dated i
June 30,1999, SNC submitted responses to a RAI for Chapter 4.0 and revised responses to RAls l
related to Chapters 3.4,3.5,3.6,3.7, and 3.9. By letter d.ved July 27,1999, SNC submitted responses i
to a RAI for a beyond scope issue in Chapter 3.5 and revised responses to RAls related to Chapters 1
3.6 and 3.8. Included with the above responses were hard copies of changes to the original submittal to correct minor editorial errors and in' consistencies within the package and to refl9ct the SNC responses to the RAls.
I This letter addresses the following: 1) A revised response to a Chapter 3.1 RAI requested in an NRC I {-
conference call on July 26,1999; 2) An RAI response related to a beyond scope issue for Chapter 3.5 requested by an NRC conference call on August 5,1999; and 3) An RAI response related to beyond I
scope issues for Chapter 3.8 requested by NRC c-mails dated June 15,1999 and July 27,1999.
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Page 2 U. S. Nuclear Regulatory Commission During meetings held with the NRC on April 19-20,1999, the Staff stated that it was not necessary to provide mark-ups of the Current Technical Specifications (CTS) in responses to RAls. Therefore, the attached pages do not contain CTS mark-ups. Attachment I provides the SNC revised response to an NRC RAI question on Chapter 3.1 and responses to the beyond scope issues for Chapters 3.5 and 3.8. 1 includes revisions to the previously submitted license amendment request related to these RAls, grouped by RAI number.
In response to these RAls, some changes to the SHEs were required. As denoted in 10 CFR 50.92(c),
SNC has determined the proposed changes to the FNP TS do not involve a significant hazards consideration. The revised SHEs are included in Attachment II. SNC has also determined that the proposed changes will not significantly affect the quality of the human environment. A copy of the proposed changes has been sent to Dr. D. E. Williamson, the Alabama State Designee, in accordance with 10 CFR 50.91(b)(i).
Clean-typed copies of the affected ITS pages are not included. A complete clean-typed copy of the FNP ITS will be re-submitted at the end of the NRC review process.
Mr. D. N. Morey states that he is a Vice President of Southern Nuclear Operating Company and is authorized to execute this oath on behalf of Southern Nuclear Operating Company and that, to the best of his knowledge and belief, the facts set fonh in this !ctter and attachments are true.
If there are any questions, please advise.
l Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY f ht]
l Dave Morey Sworn to andsubscribed b re me this /
ay of a b l999
$ dbu Odo S
' NotaryPuSic Q
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My Commission Erpires:
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l > N0l WAS/maf:ITSRAl_8. DOC l
Attachments l
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SNC Revised Response to an NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications - Chapter 3.1 and Responses to Beyond Scope Questions for Chapter 3.5 and 3.8.
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SNC Revised Response to an NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications - Chapter 3.1 and Responses to Beyond Scope Questions for Chapter 3.5 and 3.8 - Associated Package Changes Grouped by RAI Number.
9 Page 3 U. S. Nuclear Regulatory Commission cc:
Southern Nuclear Operatine Company Mr. L. M. Stinson, General Manager - Farley U. S. Nuclear Renulatory Commission. Washington. D. C.
Mr. L. M. Padovan, Licensing Project Manager - Farley U. S. Nuclear Renulatory Commission. Renion 11 Mr. L. A. Reyes, Regional Administrator Mr. T. P. Johnson, Senior Resident Inspector - Farley Alabama Deoartment of Public Health Dr. D. E. Williamson, State Health Officer
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i ATTACHMENT I SNC Revised Response to an NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications -
Chapter 3.1 and Responses to Beyond Scope Questions for Chapters 3.5 and 3.8
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SNC Revised Resp:nse to NRC RAI Related to Chrpter 3.1 ITS 3.1.7 - Rod Position Indication NRC Question:
3.1.7-1 ITS 3.1.7 Rod Position Indication (RPI)
JFD 4 & JFD 1 STS and CTS allow one inoperable RPI. The ITS allows one or more RPI to be inoperable with the same required actions as one inoperable RPI. The STS permits 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (Required Action B.1) to verify rod position after 24 steps of rod movement, while the CTS has an immediate requirement. The ITS grants 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for this verification. Comment: He STS has recently been revised to allow more than one inoperable RPI, based upon approved similar Callaway and Wolf Creek RPI TS. The allowed Completion Time for verifying rod position after rod movement should be 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Recommend revising ITS 3.1.7, on RPI, accordingly.
Additional Comment: The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time is acceptable. However, the Staffreguests that Farley adopt the additional new Condition B contained in TSTF 234, Rev.1 in lieu of the current Farley markup of Condition A with respect to more than one RPI inoperable per group.
SNC Response:
The ITS requires that action be taken to initiate verification of rod position immediately as opposed to allowing a delay. His is consistent with the CTS and ensures that actions are taken in an expeditious manner. The allowance of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to complete the rod position verification ensures that appropriately trained engineering personnel are available and that the incore system is placed in service and sufYicient analysis time is permitted. Engineering personnel are normally at the station only during the normal daytime workweek. Therefore, a delay in response may occur. The incore system must be placed in service, energized, and warmed up prior to use.
Maintenance support is required to install temporary recorders for the flux traces. There could also be cases where incore thimble paths are blocked or detectors are failed, necessitating use of alternate mapping strategies and significantly increasing the time required to verify the affected RCCA position (s). SNC believes that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> will not provide adequate time to perform this surveillance under certain circumstances. Therefore, SNC intends to leave the LCO as currently submitted.
SNC Revised Response:
SNC will adopt TSTF 234, Rev.1, with the exception of the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> completion time to verify rod position after 24 steps of rod movement. As agreed to with the Staff, SNC will maintain the Completion Times of"Immediately" to initiate action to verify the position of rods with "8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />" to complete the rod position verification.
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f Chapter 3.5 l
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I SNC Resp::nse to NRC RAI Related to Chapter 3.5 j
Beyond Scope Issue i
NRC Comment:
It is acceptable to use a graph for seal injection flow requirements for ITS LCO 3.5.5. However, the graph must be contained in the TS rather than the Bases.
SNC Response:
SNC has moved the graph into the TS.
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SNC Response to NRC RAI Related to Chapter 3.8 Beyond Scope Issue NRC Question:
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Farley ITS Surveilhnce Requirement (SR) 3.8.2.1 excludes performing SR 3.8.1.9.c.2 i
l (energizing auto-connected shutdown loads through the automatic load sequencer). You indicated in a June 15,1999 phone call that there is enough time for operators to manually add required emergency diesel generator (EDG) support loads (e.g., service water cooling) to prevent EDG damage following an automatic EDG start resulting from a loss of offsite power. Please explain how you concluded this.
Additional Comment: The NRC Staff stated in a conference call on July 19,1999 that they could not except the out-of-scope item that eliminated the sequencer in hiodes 5 and 6. The j
Staff's reasoning was that after a loss-of-effsite-power, the diesels start automatically but need service water to operate. Without the sequencer, service water would have to be manually initiated. On a July 20,1999 conference call, the Staff concluded that the issue was generic and should not be handled at this time on Farley. Instead, the TSTF process should be followed. The Staffindicated that SNC should incorporate the ITS which requires the sequencer in hfodes 5 and 6.
SNC Response:
Alarms for low main Service Water (SW) header pressure exist in the hiain Control Room i
(hlCR). In addition, each EDG has local alarms for low SW flow that are relayed to the hiCR as general EDG trouble alarms. These would alert the Operators to the need to establish SW flow.
The Operators are trained to verify and/or establish SW flow to the EDGs once the EDGs are confirmed to be in Operation. The operating procedures for a Loss of Offsite Power (LOSP) include steps to verify SW flow immediately after EDG starts and to establish SW flow if required. Therefore, the EDGs would not be subjected to operation without SW flow for a period of time in which they would sustain damage.
SNC Revised Response:
SNC will incorporate the surveillance into TS 3.8.2 which verifies that the sequencer is capable of sequencing shutdown loads on for the DG required in h1 ODES 5 and 6.
NRC Question:
- 2. The Farley ITS Bases note that during shutdown modes (consistent with LCO 3.8.10 requirements) portions of a second train of the distribution subsystems are required to be operable. The Farley ITS Bases also note that:
- a. required portions of the second train of AC power distribution subsystems may be energized from the associated inverter connected to the required DC bus, or the alternate Class IE power source consisting of the inverter static transfer switch and the associated constant voltage transformer.
- b. required DC buses associated with the second train of distribution subsystems are energized from either an operable DC source consisting of one battery, one battery charger, and the corresponding control equipment and interconnecting cabling associated with that train or a battery charger using the corresponding control equipment and interconnecting cabling within the train.
Page 1 of 2
y SNC Response to NRC RAI Related to Chnpter 3.8 Beyond Scope Issue Since the proposed Farley ITS do not require the above actions, they are considered to be voluntary actions. We suggest that you describe in the ITS Bases additional voluntary actions that you are already taking to assure that the desired level of shutdown risk is maintained if the second source connected is not a fully complimented Class IE power source. Please note that utility voluntary actions beyond the current TSs, which include safety planning and assessment in shutdown, were an important part of the Commission's decision to cancel the shutdown rule. The following is an example of what another utility added to their ITS Bases to address this issue:
"In addition to the requirements established by the technical specifications, the plant staff must also manage shutdown tasks and electrical support to maintain risk at an acceptably low value.
As required by the technical specifications, one train of the required equipment during shutdown conditions is supported by one train of AC and DC power and distribution. The availability of additional equipment, both redundant equipment as required by the technical specifications and equipment not required by the specifications, contributes to risk reduction and this equipment should be supported by reliable electrical power systems. Typically the Class 1E power sources and distribution systems of the unit are used to power this equipment because these power and distribution systems are available and reliable. When portions of the Class IE power or distribution systems are not available (usually as a result of maintenance or modifications), other reliable power sources or distribution are used to provide the needed electrical support. The plant staff assesses these alternate power sources and distribution systems to assure that the desired level of minimal risk is maintained (frequently referred to as maintaining a desired defense in depth). The level of detail involved in the assessment will vary with the significance of the equipment being supported.
In some cases, prepared guidelines are used which include controls designed to manage risk and retain the desired defense in depth."
SNC Response:
The following sentences will be added to the FNP ITS Bases for ITS LCOs 3.8.8 and 3.8.10.
" Class IE power and distribution systems are normally used because these systems are available and reliable. However, due to events such as maintenance or modification, portions of the Class IE system may be temporarily unavailable. In such an instance the plant staff assesses the alternate systems to ensure that defense in depth is maintained and that risk is minimized."
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ATTACIIMENT II SNC Revised Response to an NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications -
Chapter 3.1 and Responses to Beyond Scope Questions for Chapters 3.5 and 3.8 i
Associated Package Changes Grouped by RAI Number l
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Mr. J. D. Woodard Mr. R. D. Hill Mr. M. J. Ajiani Mr. D. J. Shelton Mr. G. P. Crone Mr. J. W. Kale Mr. G. W. Bouler Unit 1 Control Room Mr. K. W. McCracken Mr. J. W. McGowan Mr. J. A. Bailey Mr. Mehdi Sheibani Mr. D. M. Crowe Mr. S. B. Tipps Mr. W. A. Sparkman NEL Reading File NEL CATLIPS
. SNC Document Management RTYPE: A4.54 NS File: A4000 T/S 3.1,3.5,3.8 i
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Associated Package Changes for RAI-3.1.7-1 Revised Response
o FNP TS Conversion - Discussion of Changes to CTS Chapter 3.1 - Reactivity Control Systems CTS 3/4.1.3.2 POSITION INDICATING SYSTEMS - OPERATING FNP ITS 3.1.7 ROD POSITION INDICATION DOC NO SHE DISCUSSION l1 A
The CTS 3/4.1.3.2 Actions are modified by the addition of a Note and other action statement text consistent with the STS. The STS " separate Condition entry" note and associated action statement text "for one or more groups or banks" are added to the CTS Actions to provide a clarification of 5
how the STS Conditions are entered for each inoperable rod position l
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indicator per group. The inclusion of such notes in the STS conforms to the 3)q.y format and presentation of the rules of TS usage as explained in STS g~ g Section 1.3 (example 1.3-5). The Note which st entry is allowed for each inoperable rod position indicator and each demand position indicator" and the associated action statement text "for one or more groups or banks" are consistent with the CTS actions which are also expressed on a per group and per bank basis. As this change is made to reflect the STS format and introduces no technical change to the STS, it is seen as an administrative change.
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A new Condition, Condition B, is added consistent with the STS. When more than one DRPI per group is inoperable, additional actions are necessary to ensure that acceptable power distribution limits are maintained, minimum SDM is maintained, and the potential effects of rod misalignment on associated accident analyses are limited. However, in the STS, provided that the system can be restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> such that a maximum of one DRPI per group is inoperable, no power reduction is required. The 24-hour Completion Time provides sufficient time to troubleshoot and restore the DRPI system to operation while avoiding the plant challenges associated with a shutdown without full rod position indication. Since the probability of simultaneously having a rod significantly out ofposition and an event sensitive to that rod position is small this change is acceptable for Farley.
l However, as this condition provides for additional actions not available in i
the CTS, its addition is seen as a less restrictive change.
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LA The CTS 3/4.1.3.2 LCO and Actions are revised consistent with the STS.
l Descriptive details regarding the operability of the digital rod position indication system are included in the bases for this TS. The STS bases includes a detailed description of the digital rod position indication system 1
and what is required operable to meet the LCO. As such, the information in the CTS LCO and Actions is effectively addressed by the STS bases. The location of such information in the bases is consistent with the philosophy Chapter 3.1 E2-1-H August,1999
FNP TS Conversion
- - Discussion of Changes to CTS Chapter 3.1 - Reactivity Control Systems CTS 3/4.1.3.2 POSITION INDICATING SYSTEMS - OPERATING FNP ITS 3.1.7 ROD POSITION INDICATION DOC
]iQ jiHE DISCUSSION for placement of descriptive or detailed information in the STS. Reliance on the information contained in the STS bases is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.
3 Not used.
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The CTS 3/4.1.3.2 Action b.1 is revised consistent with the STS. This CTS action requires that all rod position indicators for the affected bank be verified operable. Strict compliance with this action would require performance of the associated surveillance test for each rod position indicator. The new STS surveillance would require that each rod be moved through its entire range of travel. Since in Mode 1 or 2, performance of this j
surveillance is not practical or desired, the STS includes the term "by
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administrative means" in this action. In this context the STS term "by j
administrative means"is intended to allow the operability of the affected rod position indicators to be verified by a review of existing information (previous surveillances, logs, etc.) and not require the performance of the associated surveillance test to meet the action. Since the addition of the STS term "by administrative means" provides a clarification of the appropriate required action, it is considered an administrative change necessary to conform with the new STS surveillance requirement for this LCO.
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The CTS 3/4.1.3.2 action statement c is deleted consistent with the STS.
The CTS action provided an exception to Specification 3.0.4 when verifying system operability following repair. The required actions of this LCO permit continued operation in Mode 1 or 2 with inoperable rod position indication. The new STS LCO 3.0.4 contains a " built in" exception for LCOs with actions that provide for continued operation of the plant. Therefore, Mode changes are permitted even when such actions are applicable. As such, a specific exception to LCO 3.0.4 in CTS 3/4.1.3.2 is 4
no longer required. Since this change is made to conform to the new LCO Qt /g 3.0.4 requirements and does not introduce a technical change to the CTS, it FQB is considered administrative.
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The CTS 3/4.1.3.2 actions are revised by the addition of Actions Condition l
"E" consistent with the STS. The new Condition provides the required 1
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Chapter 3.1 E2-2-H August,1999
FNP TS Conversion
~ - Discussion of Changes to CTS l
Chapter 3.1 - Reactivity Control Systems CTS 3/4.1.3.2 POSITION INDICATING SYSTEMS - OPERATING FNP ITS 3.1.7 ROD POSITION INDICATION DOC l
NO SHE DISCUSSION actions that are applicable if the other actions and completion times of this LCO are not met. If the actions or completion times of an LCO are not met, pf and the LCO does not contain a condition such as the proposed Condition "E," LCO 3.0.3 would be applicable. As the proposed Condition "E" p d,)/ provides less total time than LCO 3.0.3 to place the plant in p@M change is considered more restrictive.
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The CTS surveillance 4.1.3.2 is retained in the FNP ITS Rod Group Alignment Limits LCO (as SR 3.1.4.1) consistent with the STS. This CTS surveillance verifies the agreement between the demand position indication and the DRPI. The limit (12 steps) for this surveillance is also the LCO limit for the Rod Group Alignment Limits LCO. As such, the surveillance is more appropriate in the Rod Group Alignment Limit LCO. Since this change only reorganizes the existing surveillance requirements it is considered an administrative change.
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A new surveillance requirement (SR 3.1.7.1) is added to CTS 3/4.1.3.2 consistent with the STS. The new STS surveillance requires that the l
agreement between each DRPI and the demand position indication be j
l verified for the full range ofrod travel once prior to criticality after each
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l removal of the reactor head. The STS surveillance provides assurance that the DRPI and demand position indication are properly calibrated and indicating correctly. As such, the STS surveillance is applicable and j
appropriate for FNP. However, the addition of this surveillance represents l
new a TS requirement for FNP and is therefore considered a more l
restrictive change.
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Chapter 3.1 E2-3-H August,1999
o FNP TS Conversion - Significant Hazards Evaluations Chapter 3.1 - Reactivity Control Systems III. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS l
CTS 3/4.1.3.2 POSITION INDICATION SYSTEMS-OPERATING FNP ITS 3.1.7 ROD POSITION INDICATION hk Deleted A
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1 Chapter 3.1 E3-1-C August,1999
44 FNP TS Conversion - Significant Hazards Evaluations Chapter 3.1 - Reactivity Control Systems III. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS CTS 3/4.1.3.2 POSITION INDICATION SYSTEMS-OPERATING g
FNP ITS 3.1.7 ROD POSITION INDICATION
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- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change involves the addition of a new Condition "B" consistent with the STS which allows for multiple inoperable rod position indicators in a group for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The rod position indicators are not directly assumed in any safety analysis but are the method used to determine the required rod position to verify the safety analysis assumptions (rod insertion and alignment limits). The STS Actions for multiple inoperable rod position indicators in a group require that the rod position be determined by using the incore detectors in addition to requiring other compensatory actions. The Actions adequately accomplish the function of the rod position indicators using a different method. As long as the rod position is known, the safety function of the position indicators is accomplished and the plant may continue to be operated in the same manner as before. In addition, time in this condition is limited, further reducing the likelihood of simultaneously having a rod significantly out of position and an event sensitive to the position of the same rod. Therefore the proposed change will not significantly affect the probability or consequences of any accident previously evaluated.
- 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed change does not involve a physical alteration of the plant (no new or different types of equipment will be installed) or changes in parameters governing normal plant operation. The proposed change only affects the method used to verify rod positions and allows the incore instrumentation to perform this function when the indicators are inoperable.
The Action requirements of the FNP ITS continue to ensure that rod positions are adequately verified. Therefore, the proposed change will not create the possibility of a new or different kind of accident than any previously evaluated.
- 3. Does the proposed change involve a significant reduction in a margin of safety?
The FNP ITS Actions for inoperable rod position indication continue to ensure that rod position is adequately verified and must be met for each inoperable rod position indicator.
The Actions ensure adequate compensatory measures are taken for each inoperable rod position indicator (rod position verified with incore detectors). As such, the assumptions of the safety analysis regarding the rod insertion limits and rod alignment limits continue to be adequately verified and confirmed. Therefore, the proposed change does not involve a significant decrease in any margin of safety.
Chapter 3.1 E3-1-C August,1999
Rod Position Indication 3.1 1
3.1 R ACTIVITY CONTROL SYSTEMS 3.1.
Rod Position Indication E%
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The Digital Rod Position Indication ([ RPI) System and the emand Position Indication System shall be OPERABLE.
APPLICABILITY:
MODES 1 and 2.
My
%t 3d 3]y ACTIONS e
NOTE-------------
Sep_arate gomfition entry is allowed for each inoperabl d position indicator
@r groupand each demand position indicatormer can.
"T$TF-7,3% ka% I CONDITION REQUIRED ACTION COMPLETION TIME A.
One PI per group A.1 Verify the position Once per inoperable for one or of the rods with I 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> more groups, inoperab11/ position)(
Gndicatorg using movable incor 2
detectors.
g Ird$EttTtJ g
'isTF 23j 6,l A.2 Reduce THERMAL POWER 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> TtTF-23'f, Acv. I to s 50% RTP.
/
mb.te, ochon to j
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g One or more rods with
.1 rify the position
([4] hours) inoperableAositionM of the rods with j-Sndicators11 ave been
,1 inoperablejrosition).
moved in excess of onoicatorsD y using N 24 steps in one movable inc r p p,p13 direction since the detectors.
i W41 last determination of d-w tu g 2.
the rod's position.
M (continued) f
. fY w n b o n
- f * ' I ','L '." e
..s pequirecb Ac fron 81,l WOG STS 3.1 y 1, 04/07/95
o CHAPTER 3.1 1
INSERT N TO STS PAGE 3.1-17
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3'O' NEWITS CONDITION B l
fp4'g) i (TSTF-234, Rev.1)
CONDITION REQUIRED ACTION COMPLETION TIME l
l B. More than one DRPIper B.1 Place the control rods Immediately group inoperable, under manual control.
AND l
B.2 Monitor and Record Once per I bour l
RCS T,vs.
AND l
B.3 Verify the position of '
Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> the rods with inoperable position indicators indirectly using the movable incore j
detectors.
AND l
B.4 Restore the inoperable 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> position indicators to OPERABLE status such that a maximum of one DRPIper group is inoperable.
Chapter 3.1 Insert Page j
jpg Rod Position Indication 3.1.
TsTF-27% 9s. I TsTp.sg ACTIONS REQUIRED ACTION COMPLETION TIME CONDITION (continued)
Reduce THERMAL POWER 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to s 50% RTP.
One demand position
.1 Verify Once per indicator per bank p
admin tive means 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable for one or all D PIs for the more banks.
affected banks are OPERABLE.
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w 1.2 Verify the most Once per withdrawn rod and the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> least withdrawn rod of the affected banks are s 12 steps apart.
.2 Reduce THERMAL POWER 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
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to s 50% RTP.
Required Action and Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.
h p&
m WOG STS 3.1-18 Rev 1, 04/07/95
]
I FNP TS Conversion - JD from STS Chapter 3.1 - Reactivity Control Systems STS 3.1.8 ROD POSITION INDICATION FNP ITS 3.1.7 ROD POSITION INDICATION JD NUMBER JUSTIFICATION 1
The STS Condition C Required Action and Completion Time are revised to be more consistent with the corresponding CTS 3/4.1.3.2 action statement a.1 and 2.
The CTS action requires that the position of non-indicating rods be verified immediately after any motion that exceeds 24 steps in one direction since the last determination of the rods position or reduce power to less than 50% RTP. The CTS l
requires that action begin immediately after the applicable rod motion and implies the action must be completed within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or power must be reduced. The STS is revised to reflect this CTS requirement. This change to the STS maintains consistency with the current licensing basis of FNP as specified in the CTS and i
preserves the format and presentation requirements of the STS.
l 2
The STS Conditions A, B and C are revised to use the term DRPI consistently within this LCO. The term DRPI is inserted in place of the generic term " position l
indicator" where appropriate. This change clearly identifies Conditions A, B and C with Digital Rod Position Indication consistent with the STS LCO and Condition A statements. This change clarifies the differences between Conditions A, B and C (which address DRPI) and Condition D which addresses the " demand position indicator." This change does not alter the intent or meaning of the CTS or STS requirements. This change is made solely to enhance clarity, utilize standard FNP terminology, and provide consistency within this STS LCO.
3 The Note above the Actions of FNP ITS LCO 3.1.7 is modified by the addition of the word " digital" to maintain consistency with the LCO statement and the i
l Conditions." This change does not alter the intent or meaning of the CTS or STS requirements. This change is made solely to enhance clarity, utilize standard FNP termmology, and provide consistency within this STS LCO.
l 4
Not used.
l Y,W. p /
3*tbf(
%d l
Chapter 3.1 E5-1-G August,1999
Rod Poaition Indication B 3.1.h
% T F -\\ 3 fo BASES LCO OPERABILITY of the po ition indicator channels ensures that (continued) inoperable, misaligned, or mispositioned control rods can be detected. Therefore, power peaking, ejected rod worth, and SDM can be controlled within acceptable limits.
(p TbTF&
\\
APPLICABILITY
' The requir.ents on t e DRPI and step counters are only
., and LCO 3.1. [, because these are the only MODES in MODES 1 a (consistent with LCO 3.1.
applicabl LCO 3.1 n whic power is generated, and the OPERABILITY and alignment of roos have the potential 'go affect the safety of j
the plant.
In the shutdown MODES, the OPERABILITY of the g
shutdown and control banks has the potential to affect the g.
required SDM, but this effect can be compensated for by an T-
- )
increase in the boron concentration of the Reactor Coolant System.
T5TF. 2pl ACTIONS The ACTIONS table is modified by a Note indicating that a Sfv.I separate condition entry is owed for each inoperable rod "geth position indicator geer greu and each demand position indicator Ger ban # This is acceptable because the Required j
Actions for each Condition provide appropriate compensatory j
actions for each inoperable position indicator or ord, o more foQ
- -~-^ --
qs pop]
pgg g
oS6 Rv mbxecH When on RPI (channel) per group fail ',/the position o he rod still be determinedby use of thehncoreTuovable) etectors,p Based on experience, normal power operation does (not require excessive movement of banks.
If bankysbeen significantly moved, the Required Action of 1 or g.2 below q
is required. Therefore, verification of RC pos tion within the Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is adeq2at for allowing continued full power operation, sinde t e probability of simultaneously having a rod s;.gni icantly out of position and an event sensitive to that rod osition is small.
% s R eay lrc0 A c % <
mso O SOLS30 b'1 Cn50*G A
W st m ee per y % M P S&h Leo 3. 2.i, F 5Mes Lco 3.L2, g
M $NToowN tA Ag,N is JM N l*'is proGded 'iw %c CO%
Pfei A SA 4 r.m.% bled,'q r oh 6e. ncd been m oved, (continued)
WOG STS B 3.1-49 Rev 1, 04/07/95
I Rod Position Indication B 3.1.(,
BASES Nb ACTIONS M
'(continued) g Reduction of THERMAL POWER to 5 50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factors Qef. [
The allowed completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is reasonable, based on operating experience, for reducing power to 5 50% RTP DNO from full power conditions without challenging plant systems and allowing for rod position determination by Required
=
Action A.
bove.
. I C.1.'1.
[1and N
/
IM
.2 Pp. \\
m c
These Require Actions el ify that when one r more rods with inoperab o positio indicators have be moved in excess of 24 steps in e direction, since he position was last determiri d, the equired Actions of A 1 and A.2 still apprope te must be initiated {comptly)under Required Action
.1 to begin verifying that these rods are still properly positioned, relative to their group 0
- of O'I; positions.
4 c.*%U
\\i If,Iwithin hours, the rod positions have not be u --
g determined, THERMAL, POWER must be reduced to 5 50% RTP (ithin8hourpToavoidundesirablepowerdistributionsthat t
could result from continued operation at > 50% RTP, if one or more rods are misaligned b more than 24 steps. The allowed completion Time o 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provid an acceptable period of time'to verify tiie rod position
--gg L ung +b novaW be 6 56% TR 1.1 and
.2 n^f *rt With one demand position indicator per bank inoperable, the g'dh\\
normal power operation does not require excessive movement p
rod positions can be determined by the DRPI System. Since of rods, verification by administrative means that the rod position indicators are OPERABLE and the most. withdrawn rod and the least withdrawn rod are $ 12 steps apart within the allowed completion Time of once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is adequate.
(continued)
WOG STS B 3.1-50 Rev 1, 04/07/95
[
)b CHAPTER 3.1 l
pt. h,Y INSERT O TO STS PAGE B 3.1-50 9# p#g NEW BASES FORITS CONDITION B (TSTF-234, Rev.1)
B.l. B.2. B.3 and B.4 When more than one DRPI channel per group fails (Data A and Data B), additional actions are necessary to ensure that acceptable power distribution limits are maintained, minimum SDM is maintained, and the potential effects of rod misalignment on associated accident analyses are l
limited. Placing the Rod Control System in manual assures unplanned rod motion will not occur.
Together with the indirect position determination available via movable incore detectors, this I
action will minimize the potential for rod misalignment. The immediate Completion Time for placing the Rod Control System in manual reflects the urgency with which unplanned rod motion must be prevented while in this Condition.
Monitoring and recording reactor coolant L, help assure that significant changes in power distribution and SDM are avoided. The once per hour Completion Time is acceptable because only minor fluctuations in RCS temperature are expected at steady state plant operating conditions.
The position of the rods may be determined indirectly by use of the movable incore detectors.
The Required Action say also be satisfied by ensuring at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> that Fosatisfies LCO 3.2.1, F% satisfies LCG 2 ?.2, and SHUTDOWN MARGIN is within the limits provided in the COLR, provided the non-indicating rods have not been moved. Verification of control rod position once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is adequate for allowing continued full power operation for a limited, 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time provides sufficient time to troubleshoot and restore the DRPI system to operation while avoiding the plant challenges associated with a shutdown without full rod position indication.
Based on operating experience, nonnal plant operation does not require excessive rod movement.
If one or more rods has been significantly moved, the Required Action of C.1 or C.2 below is required.
i I
1 y
l 1
i 1
Chapter 3.1 Insert Page 1
r
/97 Rod Position Indication
~
B 3.1 ETF-136 BASES g
,,as u (continued)
Reduction of THERMAL POWER to $ 50% RTP puts the core into a condition where rod positihn is no gnificantly affecting Q) core peaking factor limits' The allowed completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provides an acceptable period of time to verify the rod positions per Required Actions C.l.1 I
g\\
and c.l.2 or reduce power to $ 50% RTP.
W 6
If the Required Actions cannot be completed within the
'3*[.h [5 associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed completion Time is reasonable, based on operating experience, for reaching thi required MODE from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLAN E SR 3.1 REQUIREMENTS Verifica io that the DRPI agrees with the demand position within 12 steps ensures that the DRPI is operating correctly.JSinceyheDRPIdyesnotdisp[0 steps ay the ctua g
Ishu own rgh posi ions betwepn 18 and 2 only poin s sit _in thef ind,1ca ed rances /are recuire in comparis The [18 month) Frequency is based on the need to perwna this Surveillance under the conditions that apply during a MM plant outage and the potential for unnecessary plant 1
M transients if the SR were performed with the reactor at power. Operating experience has shown these components usually pass the SR when performed at a Frequency of once IM every [18 months.] Therefore, the Frequency was concluded o be acceptable from a reliability standpoint.
REFERENCES 1.
10 CFR 50, Appendix A, GDC 13.
2.
FSAR, Chapter 5
FSAR, Chapter [15).
WOG STS B 3.1-51 Rev 1, 04/07/95
Chapter 3.5 l
Associated Package Changes for Beyond Scope Issue Seal Injection Graph Chapter 3.5 1
i 1
e l
l
FNP TS Conversion - Discussion of Changes to CTS Chapter 3.5 - ECCS CTS 3/4.4.7.2 RCS OPERATIONAL LEAKAGE (CONTROLLED LEAKAGE ONLY)
FNP ITS 3.5.5 SEALINJECTION FLOW DOC NO SHE DISCUSSION l1 Not Used.
2 L
In separating the RCP seal injection flow limit (controlled leakage) from l
9,g other RCS leakage limits in CTS LCO 3.4.7.2, RCS Operational Leakage, the Mode of applicability for the RCP seal injection limit was revised bg. )
consistent with the STS. The CTS LCO 3.4.7.2 requirement to maintain this limit in Mode 4 was eliminated. The STS applicability for the RCP 6
0 seal water injection flow limit is Modes 1-3. Additionally, the actions 0
M3 associated with this TS limit are also revised consistent with the STS to reflect the change in the Mode of applicability. If the actions are not met, the STS requires that the unit be placed in Mode 4 in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> instead of Mode 5 in the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> as the CTS actions require.
'Ibe revised actions are standard STS requirements for a TS with a Mode 1-3 applicability and are appropriate for FNP. The elimination of the Mode 4 requirement is based on the reduced significance of the RCP seal water injection flow to the applicable safety analyses. In Mode 4, high RCP seal water injection flow is less critical to the applicable safety analyses due to the lower initial RCS pressure and the reduced heat removal requirements in this Mode. Since the STS provides a separate LCO for the seal water injection flow limit, an appropriate individual applicability (Modes 1-3) and action (Mode 4) for this limit may be assigned.
3 A
The CTS 3.4.7.2, RCS Operational leakage, action statement b is revised consistent with the STS to be specific to the RCP seal water injection flow limit. The CTS action statement b becomes Condition A and B in the STS 3.5.5 for seal injection flow. Although the specific action required is revised consistent with the STS requirements, the basic requirement to restore the seal injection flow to within the limit and the time allowed to restore the seal injection flow to within the limit remain unchanged. As such, this change is considered administrative to conform with the format and presentation of the STS.
4 M
The CTS 3.4.7.2.e requirement for controlled leakage is revised consistent with the intent of the STS. The CTS requirement specifies a flow limit (31 gpm) and an RCS pressure (2235 20 psig). The STS adds an additional f
parameter (charging pump discharge header pressure) to the LCO Chapter 3.5 E2-1-F August,1999
o FNP TS Conversion - Discussion of Changes to CTS Chapter 3.5 - ECCS CTS 3/4.4.7.2 RCS OPERATIONAL LEAKAGE (CONTROLLED LEAKAGE ONLY)
FNP ITS 3.5.5 SEAL IN.IECTION FLOW DOC NO SHE DISCUSSION requirements. The addition of the charging pump discharge header pressure in conjunction with the currently specified RCS pressure allows a reference differential pressure to be established across the RCP seal water injection flow throttle valves. Establishing a reference differential pressure allows a more precise and repeatable verification of seal injection flow and proper throttle valve position. In the conversion to ITS, this change in the measurement of the seal injection flow is addressed by use of a graph from which the appropriate flow can be determined based on the delta between the RCS pressure and the charging discharge header pressure. The information in the CTS LCO and the additional requirement for charging discharge header pressure is contained as a single point on this graph. The 35 points on the graph are based on FNP-specific safety analysis assumptions CM )
which provide the relationship between seal injection flow, RCS pressure, M
t.
and charging discharge header pressure over a range of values for each of 4A these parameters. The surveillance requirement will require the flow to be I
within ECCS safety analysis limits as expressed in the figure. Therefore, the figure must maintain those limits. The verification of seal water flow within the limit by establishing a reference differential pressure is more consistent with the method used to determine the seal water flow values assumed in the applicable ECCS safety analyses. As such, this change is applicable to FNP. Since this change introduces an additional requirement in the TS, it is considered more restrictive.
5 M
The CTS surveillance 4.4.7.2.1.c for verification of seal water flow is revised consistent with the STS. The CTS surveillance contains an exception to the provisions of Specification 4.0.4 for entry into modes 3 and
- 4. The CTS exception to specification 4.0.4 allowed the performance of this surveillance to be delayed until the RCS pressure was within the specified limits. The CTS surveillance contains no specific time limits for performing this surveillance after entering Modes 4 or 3. In the STS, there are no exceptions to the equivalent SR 3.0.4. Instead of specifying a blanket exception to the requirement to perform all surveillances prior to entering the Mode of applicability or other specified conditions, the STS specifies the conditions under which the surveillance must be performed and a specific time in which it should be performed after the specified conditions are met. In this way no exceptions for the performance of surveillance requirements are required in the STS. The STS surveillance SR 3.5.5.1 for verifying seal injection flow specifies the equivalent RCS Chapter 3.5 E2-2-F August,1999
Seal Injection Flow 3.5.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.5.1
NOTE--------------------
Not required to performed until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the Reacto colant System pressure s2255psig(f6 stabilizes a 215 psig and
).
g.*
CNM 6c.o[
Verify manual seal injection throttle 31 days e
valves are adjusted to give a flow within e is a h
-~l and the Qcnarging71okytontrol va. ve full A
open.
$co.I code,r'mjechJn f(N 1
i WOG STS 3.5-12 Rev 1, 04/07/95
25 0 e
i
)
i
,5,
~
T j
N 200
'5 i
l
./ :
E ACCEPTABLE l
REGION i
h 150 i I
I E
1,141 c
N 27,113 g ioo
'24,92 So is 18 20 25 30 35 e
GPM
.h N }y6@f VfS#
FIGURE 3.5.5-1 SEAL INJECTION FLOW LIMITS j
S t
I
~
FNP TS Conversion - JD from STS Chapter 3.5 - ECCS STS 3.5.5 SEAL INJECTION FLOW FNP ITS 3.5.5 SEAL INJECTION FLOW JD NUMBER JUSTIFICATION l
1 LCO 3.5.5 for Seal Water Injection Flow is revised to utilize a graph to indicate the limits for seal injection flow. These limits are better expressed graphically than by a single point on a curve. The appropriate seal injection flow can be determined I
based on the difference between the Pressurizer pressure and the charging discharge header pressure. The points on the graph are based on FNP-specific safety analysis I
assumptions which provide the relationship between seal injection flow, Pressurizer pressure, and charging discharge header pressure over a range of values for each of these parameters. The smveillance requirement will require the flow to be within 4
l ECCS safety analysis limits as expressed in the figure. Therefore, the figure must maintain those limits. Hence, the TS requirements will continue to maintain ECCS performance within the envelope of the safety analysis.
(,h'T' 3 6 6{a)f 90 i
Chapter 3.5 ES-1-E August,1999
i
.e h8 Seal Injection Flow B 3.5.5 BASES APPLICABLE injection flow satisfies Criterion 2 of the NRC Policy SAFETY ANALYSES Statement.
(continued)
LC0 The intent of the LCO limit on seal injection flow is to make sure that flow through the RCP seal water injection line is low enough to ensure that sufficient centrifugal charging pump injection flow is directed to the RCS via the injection points (Ref. 2).
QEW~ '
The LC0 is not strictly a flow limit, but rather a flow limit based on a flow line resistance.
In order to The flow line resistancejdetermine establish the proper flow line resistance, a pres re and flow must be known.
r opeiting/{
fb as ming nat t tu, pressure is At nor al es re a tha he cpntrifjdal c)frgin ump charge j
er t, an or 40ual to the lue s cified in) pre sure
_ gre h
4!L s LC0J The centrifugal charging pump discharge header pressure remains essentially constant through all the applicable MODES of this LCO. A reduction in RCS pressure would result in more flow being diverted to the RCP seal injection line than at normal operating pressure. The valve settings established at the prescribed centrifugal charging pump discharge header pressure result in a conservative 5
0 valve position should RCS pressure decrease. The additional 4
i modifier of this LC0, the control valveJcharging tiow for OPsc M
go
- four icop units ano a,r operated seal injection for three d
, loop units)fbeing full open, is required since the valve is designed to fail open for the accident condition. With the h psW discharge pre.ssure control valve position as specified by the LCO, limit is established.
It is this o
rey,M limit t at s use in th acciden,t anal l
(
& 6 -the, Auf g bleE TKcf i3 %
_345'.
mTS p
TJe imit on se iiijecM owFcomDTrietr with th 0
[f Centrifugal cnaraina oumo discharce headei 3ressure limit t
and an open wide condition of thethargindfflow control g 3,g valve, must be met to render the ECCS OPERABLE.
If these conditions are not met, the ECCS flow will not be as assumed Dy qr, in the accident analyses.
APPLICABILITY In MODES 1, 2, and 3, the seal injection flow limit is dictated by ECCS flow requirements, which are specified for (continued)
WOG STS B 3.5-33 Rev1,04/07/95
I4)
CHAPTER 3.5 INSERT C TO LCO 3.5.5 BASES established by adjusting the reactor coolant pump seal injection needle valves to provide a total l
seal injection flow in the Acceptable Region of Figure 3.5.5-1 at a given pressure differential between the charging header pressure and the pressurizer pressure.
Cbf-8m" ro
- df f
l Chapter 3.5 Insert Page
e.
Seal Injection Flow B 3.5.5 I
BASES (continued) n OC PCh n o f Rpre, SURVEILLANCE SR 3.5.5.1 h (opero+ aa m Y NP i
REQUIREMENTS U f 5-8 g
Verification eve %
ry 31 ays a the manual seal injection i
33 throttle valves are adjusted to give a flow within the limits A ka('
ensures that proper manual seal injection throttle valve CM
,A position, and hence, proper seal injection flow, is 7
maintained.xThe Frequency of 31 days is based on gngineering judgment and is consistent with other ECCS valve Tdtegr p l
Surveillance Frequencies. The Frequency has proven to be acceptable through operating experience.
PSC.
As noted, the Surveillance is not required to be performed until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the RCS pressure has stab'.11 zed within a 20 psig range of normal operating pressure. The RCS pressure requirement is specified since this configuration will produce the required pressure conditions necessary to assure that the manual valves are set correctly. The exception is limited to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to ensure that the Surveillance is timely.
.)
,i,i REFERENCES 1.
FSAR, Chapter d Chapter 2.
l WOG STS B 3.5-35 Rev 1, 04/07/95
h b
7'^f 8
A vd a
Lco cy. u BeyaJ supe vc zu
/
O 9 a 8
a l
Chapter 3.8 i
l i
Associated Package Changes for Chapter 3.8 Beyond Scope Issue No.1 Sequencer in Modes 5 and 6 I
i
FNP TS Conversion - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.1.2 ELECTRICAL POWER SYSTEMS SHUTDOWN FNP ITS LCO 3.8.2 AC SOURCES - SHUTDOWN DOC liO SHE DISCUSSION restrictive.
8 L
The CTS 4.8.1.2 surveillance is revised to eliminate the requirement to perform surveillances that demonstrate capabilities which are not required j
in Modes 5 and 6 consistent with the guidance provided in the STS. Since the surveillance requirements in AC Sources - Shutdown define and verify the operability requirements of the AC Sources required in Modes 5 and 6, the AC Sources - Shutdown surveillance requirement is revised to more clearly identify the applicable operability requirements and allow exceptions to be taken for those surveillances that demonstrate capabilities which are not required operable in Modes 5 and 6. The proposed exceptions are in addition to the existing CTS exception for 4.8.1.1.2.a.5 (STS 3.8.1.3) which is retained and are consistent with the definition of operability. The definition of Operability refers to the system or equipment being capable ofperforming its " required safety function". The surveillances proposed to be included in the STS exception for Modes 5 and 6 do not demonstrate any capability related to an AC Source's " required safety function"in Modes 5 and 6. The revised AC Sources - Shutdown surveillance does not require the excepted surveillances to be met or performed in Modes 5 and 6. The surveillances for which an exception is taken are those which require the following:
The capability to transfer offsite circuits be demonstrated (only one offsite circuit is required in Modes 5 and 6),
The AC Source response to an ESF actuation signal (SI) be 3
demonstrated (SI is not a required safety function in Modes 5 and h h.t g
That DG starting independence be verified (only one DG is required in Modes 5 and 6), and That automatic load sequence timing capabilities of emergency load sequencers be verified.
l 9
L The CTS surveillance requirement 4.8.1.2 for AC Sources Shutdown is revised by the addition of a Note consistent with the STS. The Note is l
Chapter 3.8 E2-4-B August,1999 l
l
le/
AC Sources - Shutdown 3.8.2 P
plea.ble, but i
SURVEILLANCE REQUIREMENTS SURVEILLANC FREQUENCY SR 3.8.2.1
-NOTE------------__--_ j-_ #
The following__SRs are not reauired to be Derformed: f5R 3 8.1.3, 3.8.
9 thro Qh j SR
.8.1. 1, SR 3.8.1.1 throu S
3.8.
16, [
3.8.
18,] a d 3.8.
19.
For AC sources required to be OPERABLE, the In accordance SRs of Specificatio_n 3.8.1, "AC Sources _- }'with applicable Operating. " except) SR 3.8.1.8, SR 3.8.1.17,)
SRs gndSR3.8.1.20,fareapplicaDie.
Cm
\\
l R 3'f,*g,'f -
bs f-r.rtsite cmurf3
, jr >
l g
4 9e lM
- At S1. Auto sta.et-6I ev e<-ride Test en C.
$ R 3,8,/, /Of seguencing inferds 5%
s g 3, 8, l. lS,
'*SP +beoes sid eF te s siend.
} 6 A 2
- 0
- l* IID*
c,o men Luded.b6 run The. fotidnbrmed., SN.016l.eo S R 3,S. /* 17e ^d-o SRs c.u.,
1 5 R 3. B' /* lie G R 3,s.t. 4, git 3,perg.t 5,sud sU,e.t fe9 oired.to be.
- 8. /./
q
~tM'I'7' sg3,g,I.g, SR 3,B.I.(5R 3@ l'lI; 6t S R 3,8 I.ld, SR B.g*p g A Sk 3,8.l.18 g.3A g
ect"1 N
$. t S$d WOG STS 3.8-20 Rev1,04/07/95
o FNP TS Conversion l - JD from STS Chapter 3.8 - Electrical Power Systems STS 3.8.2 AC SOURCES - SHUTDOWN 1
FNP ITS 3.8.2 AC SOURCES - SHUTDOWN JD NUMBER JUSTIFICATION 1
The Note modifying STS surveillance 3.8.2.1 is revised editorially for clarity. The Note is revised to clearly state the surveillances listed in the Note "are applicable".
This editorially enhancement is completely consistent with the detailed STS bases explanation of this Note. The inclusion of this enhancement will help users to l
understand the intent of the Note more readily. The exception provided by the Note I
does not except the requirement for the DG to be capable of performing the l
particular function,just that the capability need not be demonstrated while that source of power is being relied on to meet the LCO.
2 The Note modifying STS surveillance 3.8.2.1 is revised to include the appropriate FNP ITS surveillance numbers. The numbers included correspond to the STS surveillances listed and are different due to changes in the numbering of the I
surveillances or the omission of surveillances from the FNP ITS. The revisions to the STS causing changes in surveillance numbering including the deletion of STS surveillances are discussed elsewhere in Enclosure 5 (STS 3.8.1 AC Sources Operating). In addition, SR 3.8.1.3 (the 60 minute full load DG run surveillance) is included as an exception to SR 3.8.2.1 in the body of the SR and not in the note.
The inclusion of this SR as an exception in the body of the SR is consistent with the existing surveillance exception in CTS surveillance 4.8.1.2, and the intent of the STS exceptions which include surveillances that require periods of being synchronized to the offsite circuit. As such, the inclusion of SR 3.8.1.3 as an I
exception in the body of SR 3.8.2.1 instead of the note is consistent with the STS and maintains the FNP current licensing basis as specified in CTS 3/4.8.1.2 for DG testing. The surveillances included in the FNP ITS Note are those that meet the intent of the exception provided by the Note. The Note is intended to preclude requiring the operable DG from being paralleled with the offsite power network or otherwise rendered inoperable for the performance of a surveillance. Many of the l
surveillances required to be performed involve tests that would require the DG to be l
paralleled to offsite power. This condition (the only required DG and the only l
required offsite circuit connected) presents a significant risk of a single fault i
resulting in a station blackout. In an effort to consistently address this concern and to avoid other potential conflicts with testing and operability, the STS includes a 1
note in the surveillance to except the requirement to perform certain surveillance tests. The exception provided by the Note does not except the requirement for the DG to be caoable ofperforming the particular function,just that the capability need not be demonstrated while that source of power is being relied on to meet the LCO.
3 The STS SR 3.8.2..I surveillance provides an exception for surveillances that Chapter 3.8 E5-1-B March,1998
FNP TS Conversion - JD from STS Chapter 3.8 - Electrical Power Systems STS 3.8.2 AC SOURCES - SHUTDOWN l
FNP ITS 3.8.2 AC SOURCES - SHUTDOWN l
JD l
NUMBER JUSTIFICATION l
demonstrate capabilities which are not required in Modes 5 and 6. The list of surveillances in the STS for which the exception applies is not complete. The STS t
SR 3.8.2.1 surveillance is revised to include additional FNP ITS surveillances that demonstrate capabilities which are not required in Modes 5 and 6 consistent with the intent of the STS. Since the surveillance requirements in AC Sources -
Shutdown define and verify the operability requirements of the AC Sources required in Modes 5 and 6, the AC Sources - Shutdown surveillance requirement is revised to more clearly identify the applicable operability requirements and allow i
exceptions to be taken for those surveillances that demonstrate capabilities which are not required operable in Modes 5 and 6. The proposed exceptions are consistent j
with the definition of Operability. The definition of Operability refers to the system or equipment being capable of performing its " required safety function". The l
surveillances proposed to be included in the STS exception for Modes 5 and 6 do not demonstrate any capability related to an AC Source's " required safety function" in Modes 5 and 6. The revised AC Sources - Shutdown surveillance does not require the excepted surveillances to be met or performed in Modes 5 and 6. The surveillances for which an exception is taken are those which require the following:
The capability to transfer offsite circuits be demonstrated (only one offsite circuit is required in Modes 5 and 6),
h pd g(g The AC Source response to an ESF actuation signal (SI) be demonstrated g pe-(SIis not a required safety function in Modes 5 and 6),
i That DG starting independence be verified (only one DG is required in Modes 5 and 6), and That automatic load sequence timing capabilities of emergency load sequencers be verified.
In addition to the exceptions discussed above, SR 3.8.1.3 (the 60 minute full load DG run surveillance) is included as an exception to SR 3.8.2.1. The inclusion of this SR as an exception is consistent with the existing surveillance exception in CTS surveillance 4.8.1.2, and the intent of the STS exceptions which include surveillances that require periods of being synchronized to the offsite circuit.
Therefore, the inclusion of SR 3.8.1.3 as an exception to SR 3.8.2.1 is consistent l
with the STS and maintains the FNP current licensing basis as specified in CTS 3/4.8.1.2 for DG testing.
Chapter 3.8 E5-2-B August,1999 i
~
97'l Acsources-Sgug BASES LC0 provide electrical power support, assuming a loss of the (continued) offsite circuit. Together, OPERABILITY of the required offsite circuit and DG ensures the availability of sufficient AC sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).
The qualified offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the Engineered Safety OgG Feature (ESF) bus (es). Qualified offsite circuits are those that are described in the FSAR and are part of the licensing basis for the unit.
IN6EET circuit #1 consists of Safeguards Transformer pg which 1 lied from Switchyard Bus B, and i through breaker 52-3 p the ESF transform I, which, in turn, powers the il thro s r.ormal feeder s
breaker. The second offs it consists of the Startup Transformer, which rmally fed the Switchyard Bus A, and i Je through breaker PA 0201 ing the ESF trans r, which, in turn, powers the #2 ESF bu ough f. norma.1 feeder breaker The DG must be capable f s arting, accelerating to rated speed and voltage, and co ecting to its respective ESF bus on detection of bus tage. This sequence must be accomplished within seconds. The DG must be capable _.of OE acceptindequired1 (ETithin tne assumeo loading sequenc nterval5) and continue to operate until offsite power can two.nu be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with the engine hot and DG in standby at ambient conditions.
g.3 Proper sequencing of loads, including tripping of nonessential loads, is a required function for DG.
PERABILITY.f In a ro er sequencer operation is an r
of offsite circu TY noperability SC~l impacts on the a art n energized loads
,ph.KABLE by LCO 3.8.10.
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