ML051680241

Proposed Technical Specification Changes on Revised Frequency for Tadot of P-4 Interlock Response to Request for Additional Information

ML051680241
Person / Time
Site:	North Anna
Issue date:	06/16/2005
From:	Grecheck E Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
05-330
Download: ML051680241 (37)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 June 16, 2005 U.S. Nuclear Regulatory Commission Serial No.05-330 Attention: Document Control Desk NL&OS/ETS R1 Washington, D.C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATION CHANGES In a letter dated March 1, 2005 (Serial No.05-111), Virginia Electric and Power Company (Dominion) requested amendments, in the form of changes to the Technical Specifications to Facility Operating License Numbers NPF-4 and NPF-7 for North Anna Power Station Units 1 and 2, respectively. The proposed changes were requested to revise the frequency for the Trip Actuating Device Operational Test (TADOT) of the P-4 Interlock Function. In your May 19, 2005 letter, the NRC staff requested additional information associated with the proposed changes. A subsequent conference call was also held with the NRC staff on June 7, 2005 to discuss the questions. The information requested is provided in the attachment to this letter.

If you have any further questions or require additional information, please contact Mr.

Thomas Shaub at (804) 273-2763.

Very truly yours, Eugene S. Grecheck Vice President - Nuclear Support Services Attachment Commitments made in this letter: None

Serial No.: 05-330 Docket Nos.: 50-3381339 Page 2 of 3 cc: U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. J. E. Reasor, Jr.

Old Dominion Electric Cooperative lnnsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, Virginia 23060 Commissioner Bureau of Radiological Health 1500 East Main Street Suite 240 Richmond, Virginia 23218 Mr. J. T. Reece NRC Senior Resident Inspector North Anna Power Station Mr. S. R. Monarque NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8-HI2 Rockville, Maryland 20852 Mr. R. E. Martin NRC Lead Project Manager - North Anna and Surry U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Mr. J. Honcharik NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852

Serial No.: 05-330 Docket Nos.: 50-3381339 Page 3 of 3 COMMONWEALTH OF VIRGINIA )

1 COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck who is Vice President -

Nuclear Support Services of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this E d a y of ,2005.

My Commission Expires:

Notary Public (SEAL)

Attachment 1 Serial No.05-330 Proposed Technical Specification Changes Revised Frequency for TADOT of P-4 Interlock Request for Additional Information Response North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

Serial No.: 05-330 Docket Nos.: 50-338/339 Page 1 of 5 RAI - REVISED FREQUENCY FOR TADOT OF P-4 INTERLOCK In a letter dated March 1, 2005 (Serial No.05-111), Virginia Electric and Power Company (Dominion) requested amendments, in the form of changes to the Technical Specifications to Facility Operating License Numbers NPF-4 and NPF-7 for North Anna Power Station Units 1 and 2, respectively. The proposed changes were requested to revise the frequency for the Trip Actuating Device Operational Test (TADOT) of the P-4 Interlock Function. In a May 19, 2005 letter, the NRC staff requested additional information associated with the proposed changes. A subsequent conference call was held on June 7, 2005 to discuss the questions with the NRC staff. A response to your RAI questions is provided below:

Background

During the development and implementation of the Standard Improved Technical Specifications, the TADOT surveillance requirement of once per Reactor Trip Breaker cycle specified in NUREG-1431, Rev 1, was adopted in lieu of retaining the original surveillance frequency of 18 months. We failed to initiate a Justification for Deviation (JFD) at that time to maintain the original Technical Specifications surveillance frequency of 18 months.

Currently, the performance of TADOT testing is being performed following every cycle of the reactor trip or bypass reactor trip breakers. This occurs a minimum of eight times to as many as 18 times a refueling outage during critical path time over a one to two day period. This has created an unnecessary and unintended burden to perform this TADOT during an outage.

NRC Question 1 The P-4 interlock is enabled when a reactor trip breaker (RTB) and its associated bypass breaker is open. Once the P-4 interlock is enabled, automatic safety injection (SI) initiation is blocked after a time delay. This function allows operators to take manual control of SI systems after the initial phase of injection is complete. Once SI is blocked, automatic actuation of SI cannot occur until the RTBs have been manually closed. The RTB position switches provide input to the P-4 interlock.

NUREG-1431, Rev 3, Standard Technical Specifications Westinghouse Plants, requires that the surveillance frequency for P-4 interlock is once per RTB cycle, every 62 days on a staggered test basis. This license amendment request (LAR) proposes to change the surveillance frequency for P-4 interlock to once every refueling outage, every 18 months. In order for the NRC staff to approve this type of surveillance frequency change, the licensee should provide justification to demonstrate that the

Serial No.: 05-330 Docket Nos.: 50-338/339 Page 2 of 5 proposed TS change is based on either hardship (such as challenges to the protection system or increased radiation exposure to plant personnel) or on a risk-informed basis.

Dominion Response:

Background:

During the development and implementation of the Standard Improved Technical Specifications, the TADOT surveillance requirement of once per Reactor Trip Breaker cycle specified in NUREG-1431, Rev 1, was adopted in lieu of retaining the original North Anna Power Station Technical Specifications surveillance frequency of 18 months. As stated in the Discussion of Changes, the purpose of the proposed change is to modify the frequency of TADOT testing from once every reactor trip breaker cycle to 18 months to be consistent with the original licensing bases at North Anna and TSTF-444-T, Rev 1. Since the implementation of the Improved Standard Technical Specifications at North Anna, the performance of TADOT testing is required every time the reactor trip breaker is cycled. This occurs a minimum of eight times to as many as 18 times during a refueling outage within a one to two day period and requires approximately 20 to 30 minutes (minimum of a three man team) to complete each test.

This does not include preparation time nor pre-job brief time. The testing impacts outage critical path time and has created an unnecessary burden to perform this TADOT. Since the testing occurs over a short period of time, the usefulness of the P-4 testing is of insignificant value to component reliability or plant safety. Therefore, is not commensurate with the burden imposed.

As noted in the Technical Specifications Bases, to satisfy the requirements of the Surveillance Requirement for the performance of the TADOT for the P-4 interlock per Surveillance Requirement 3.3.2.10, the reactor trip breaker and associated bypass breaker must be opened at the same time. Thus, the plant cannot be in Modes 1 or 2 to perform this TADOT test. Therefore, the P-4 TADOT may only be performed at an 18 month frequency if the unit remains at power the entire operating cycle. However, as noted above, the TADOT test may be required numerous times in a few day period to meet the surveillance frequency requirements. This TADOT requires a verification of the change of state of a single set of contacts. It should be noted that the P-4 TADOT required by Surveillance Requirement 3.3.2.10 is not petformed every 62 days on a staggered test basis. As noted above, the P-4 TADOT can only be performed with the unit shutdown with the reactor trip breakers open. The Reactor Protection and Engineering Safety Features Actuation Logic Testing is performed 31 days on a staggered test basis. This Actuation Logic Testing of the Reactor Trip and Engineering Safety Features automatic trip and actuation logic includes the performance of a TADOT of the reactor trip and bypass breakers in accordance with Technical Specification Surveillance Requirement 3.3.1.4.

The proposed changes to perform the TADOT on an 18 month frequency are based upon and are consistent with the surveillance frequency that was in effect prior to North Annas conversion to the Improved Standard Technical Specifications

Serial No.: 05-330 Docket Nos.: 50-338/339 Page 3 of 5 (NUREG-1431, Rev 1). The changes are also consistent with the recommendations and proposed changes specified in TSTF-444-T, Rev 1, and the requirements specified in NUREG-0452, Rev 4, to perform the TADOT once every refueling interval. The 18 month surveillance frequency will eliminate the hardship of testing the P-4 interlock numerous times during reactor startup and provide adequate assurance of operability of the P-4 interlock function.

Current TADOT Testing Current TADOT testing is performed by two electricians and is coordinated by Operations personnel. The voltage across the contacts is measured while the Reactor Trip Breakers and Bypass Breakers are open and then checked again when the Reactor Trip Breakers are cycled. A successful test of the required contacts of a channel relay may be performed by the verification of the changes of a single contact of the relay. The change of state occurs when the Reactor Trip Breaker or Bypass Breaker is closed because the contacts for the Reactor Trip Breakers and the Bypass Breakers are in series. As such, the performance of the TADOT for each P-4 interlock train is considered to be the combined completion of the before breaker closure contact check AND the after breaker closure contact check. Since the implementation of ITS and the performance of this TADOT testing, the results of the testing have been satisfactory. These contacts are associated with the input circuit to the Solid State Protection System for Feedwater isolation. The remaining three P-4 circuits, which include the MCR annunciator for Reactor Trip Turbine Trip, the Turbine Trip on Reactor Trip function, and the P-4 input to reset the Hi Steam Flow setpoint are checked by other station procedures at least once per refueling interval.

TADOT testing of the reactor trip and bypass breakers is also performed during Reactor Protection and Engineering Safety Features Actuation Logic Testing per Surveillance Requirement 3.3.1.4 on a 31 day staggered test bases. This surveillance tests the logic functions of the Solid State Protection System, as well as, the reactor trip and bypass breakers. The breakers are tested to ensure operability of the reactor trip and bypass breakers and that the breakers will open on a trip signal.

Request for 18 Month Testing Frequency Since the implementation of the Improved Standard Technical Specifications at North Anna, the performance of TADOT testing is required every time the reactor trip breaker is cycled. This occurs a minimum of eight times to as many as 18 times during a refueling outage within a one to two day period and requires approximately 20 to 30 minutes (minimum of a three man team) to complete each test. This does not include preparation time nor pre-job brief time. These tests are performed during critical path time during the plant restart from the outage and has created an unnecessary and unintended burden to perform this TADOT.

Serial No.: 05-330 Docket Nos.: 50-338/339 Page 4 of 5 Prior to ITS, the 18 month test was adequate to ensure that the P-4 interlock was operable to perform its intended safety function. Since the initial testing of the P-4 interlock functions, there have been no identified failures of the P-4 interlock. This includes previous testing at the 18 month frequency and currently at the frequency of once per reactor trip breaker cycle. The increased testing to once every reactor trip breaker cycle is unnecessary to ensure that the P-4 interlock will perform its intended safety function. Most of the additional P-4 interlock testing is performed over a few day period during plant startup from a refueling outage prior to the reactor being critical. No extra protection is provided by performing multiple testing over a short period of time (e.g., normally within one day). The reactor trip breaker position switches that provide input to the P-4 interlock only function to open or close the.contacts. Therefore, this function has no adjustable trip setpoints with which to associate an allowable value.

The P-4 interlock is generated by an auxiliary contact in the reactor trip breaker and not subject to instrument drift. Thus, reducing the testing frequency to once every 18 months does not adversely impact safety and does not require any changes to the ESFAS instrumentation design requirements.

NRC Question 2 NUREG-1431, Revision 3, specifies for P-4 interlock that the applicable modes are 1, 2, and 3. This LAR proposes to add Mode 4 for this function. Additional analysis is required to support the proposed change.

Dominion Response:

The addition of Mode 4 is discussed in TSTF-444, Rev 1. The block of the auto Safety Injection (SI) signal is required to support long-term ECCS operation in the post-LOCA recirculation mode. This Function must be operable in Modes 1, 2, 3, and 4 when the reactor may be critical or approaching criticality, or when the support of the auto SI block function is required. The Required Modes for the various P-4 functions are specified in the Engineered Safety Feature Actuation System Interlocks - Reactor Trip, P-4 section of the Bases.

NRC Question 3 The March 1, 2005, submittal cited that the proposed changes are consistent with the intent of the Westinghouse Owners Group Technical Specification Task Force Process TSTF-444, Rev 1, ESFAS Interlocks P-4, P-11, & P-12 LCO Actions and Surveillance Requirements Revisions. Since TSTF-444 has not been approved by the NRC staff, the P-4 interlock-related information contained in TSTF-444 should be submitted with this LAR.

Serial No.: 05-330 Docket Nos.: 50-338/339 Page 5 of 5 Dominion Response:

A copy of TSTF-444, Rev 1, ESFAS Interlock P-4, P-11, & P-12 LCO Actions and Surveillance Requirements Revisions, is included for your information. According to the Westinghouse Owners Group Status Report, TSTF-444 was submitted to the NRC on August 7,2002. However, it was later withdrawn by WOG on October 31, 2003 due to imposed review fees by the NRC. The changes proposed in the TSTF change request then became an Improved Standard Technical Specifications Change Traveler.

While it is understood that the NRC staff had not approved the P-4 interlock-related information contained in TSTF-444, the recommendations and proposed changes from the TSTF-444, Rev 1, traveler associated with the P-4 interlock were only used as the basis of our plant specific Technical Specification changes for this LAR submittal.

As stated in our LAR submittal, the changes are consistent with TSTF-444-T, Rev 1.

TSTF-444 proposed the deletion of Surveillance 3.3.2.11 and the addition of the surveillance for the P-4 Interlock to Surveillance 3.3.2.8 with the frequency of 18 months, and the applicability of Mode 4. Changes were also recommended to the Bases to correct the design basis of the ESFAS Interlock for P-4 which were also incorporated into the proposed changes for this LAR submittal.

NRC Question 4 The March 1, 2005, submittal cited precedents from five other plants (Wolf Creek, Byron, Braidwood, Comanche Peak and DC Cook) that maintained their 18-month surveillance test requirement to perform the TADOT of the P-4 interlock function. The NRC staff found that these plants were licensed on that basis; therefore, these precedents cannot be considered as a precedent for a technical specification change as requested in this LAR. However, the operational experience from these plants may be able to be credited as part of a risk-informed basis.

Dominion Response:

The intent of the precedents listed was to identify several plants that took exception to the specific requirements of NUREG-1431 during ITS conversion whereby they retained their original requirement to perform the TADOT during their refueling outage intervals in lieu of once every reactor trip breaker cycle. North Anna had that same requirement to perform the TADOT every 18 months prior to adopting NUREG-1431 for the Improved Standard Technical Specifications. We failed to initiate a Justification for Deviation (JFD) at that time to maintain the current Technical Specifications surveillance frequency of 18 months for North Anna. The proposed amendment requests a return to the previous surveillance frequency to eliminate unnecessary testing, which is consistent with the cited examples that maintained the 18 month surveillance.

WOG-166, Rev. 0 TSTF-444-T, Rev. 1

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Technical Specification Task Force

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Improved Standard __

Technical Specifications Change Traveler

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ESFAS Interlocks P-4, P-11 & P-12 LCO Actions and Surveillance Requirements Revisions NUREGsAffected: C; 1430 @ 1431 0 1432 0 1433 1434 Note: This T Traveler has been reviewed and approved by the Technical Specification Task Force and is made available as a template for plant-specific license amendments. This Traveler has not been reviewed and approved by the Nuclear Regulatory Commission.

Classification: 1) Technical Change Recommended for CLIP?: No Correction or Improvement: (Unassigned)

Industry

Contact:

Denny Buschbaum, (254) 897-5851, dbuschbl @txu.com The proposed change to the Improved Standard Technical Specifications (ISTS) will accomplish the following:

Add a new functional item, Automatic Actuation Logic and Actuation Relays, on Engineered Safety Feature Actuation System (ESFAS) Instrumentation Table 3.3.2-1, which includes Mode (1,2 ,3 & 4),Channel (2 trains), Condition (M) and Surveillance Requirements (3.3.2.2, 3.3.2.4 & 3.3.2.6), under Function No. 8 ESFAS Interlocks. Revise Condition L by changing the requirements from one to two or more required channels inoperable. Add new Condition M, which will be applicable to the ESFAS interlock logic and relays with one train inoperable. Delete Surveillance 3.3.2.11 under Technical Specification (TS) 3.3.2, ESFAS Instrumentation, and add new Surveillance 3.3.2.8 to P-4 on Table 3.3.2-1. Delete Surveillance 3.3.2.1 from P-11 & P-12 on Table 3.3.2-1. Revise Bases Section B 3.3.2, ESFAS Instrumentation, to reflect the correct design basis of the ESFAS Interlocks P-4, P-1 1 & P-12.

2.0 PROPOSED CHANGE

With regard to ESFAS Interlock Functions P-4 (Reactor Trip), P-1 1 (Pressurizer Pressure), and P-12 (Tavg Low-Low), the NUREG-143 1 Revision 2 LCO Actions, Surveillance Requirements and Bases are not technically in agreement with the ESFAS Interlock hardware or the design bases.

ISTS Condition L is revised consistent with NUREG-0452. This ISTS Condition addresses an inoperable ESFAS interlock function (P-1 1 or P-12). The P-1 1 interlock function is comprised of three instrument channels and two actuation logic trains, each with a two-out-of-three logic circuit and associated master and slave relays. The P-12 interlock hnction is comprised of three or four instrument channels and two actuation logic trains, each with a two-out-of-three or two-out-of-four logic circuit and associated master and slave relays. The P-4 interlock function is comprised of two trains of cell switches and auxiliary contacts, which sense reactor trip and bypass breaker position, and the corresponding logic circuits in each SSPS train. In addition, the P-4 circuits in the Reactor Trip switchgear provide direct actuation signals (e.g., turbine trip). The corresponding NUREG-0452 Actions address multiple inoperable instrument channels and an inoperable logic circuit in one SSPS train. The NUREG-0452 Actions were more clearly designed to address an inoperable interlock function, which may have resulted from more than one inoperable instrument channel or an inoperable train of logic. NUREG-0452 required no action for one inoperable channel.

17-Jun-04 Traveler Rev. 3. Copyright (C) 2004, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S.Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-166, Rev. 0 TSTF-444-T, Rev. 1 The following changes are made:

ISTS Condition L will apply when one or more channels are inoperable, and ISTS Condition M will apply when one train is inoperable. SR 3.3.2.11 is deleted. Table 3.3.2-1 is revised by the addition of a new function, 8.a, "Automatic Actuation Logic and Actuation Relays." This new function is applicable in Modes 1, 2, 3, and 4 and the applicable Condition and surveillance requirements are Condition M and SR 3.3.2.2, SR 3.3.2.4, and SR 3.3.2.6. Existing functions 8.a. through 8.c are therefore renumbered. Renumbered function 8.b. (old &a,), "Reactor Trip, P-4," is revised by replacing Condition F with Condition C and replacing SR 3.3.2.1 1 with SR 3.3.2.8. SR 3.3.2.1 is deleted from both renumbered function 8.c. and 8.d. Applicable Bases changes are made.

3.0 BACKGROUND

Based on a comparison of the ESFAS Interlock LCO Actions and the Surveillance Requirements in NUREG-0452 Revision 4 (Tables 3.3-3 and 4.3-2) to NUREG-0452 Revision 3 (SR 4.3.2.3 and Tables 3.3-3 and 4.3-2), Revision 4 introduced technical inadequacies which were camed-over into NUREG-143 1.

4.0 TECHNICAL ANALYSIS

The P-4 interlock functions are developed on a per train basis by Reactor Trip Breaker (RTB) cell switches and auxiliary contacts, Solid State Protection System (SSPS) logic circuits and safeguards actuation circuits and relays, and associated interface relay circuits. Each P-1 1 and P-12 function is developed on a per train basis by inputs from shared channels and outputs from independent logic circuits and safeguards actuation circuits and relays. To be consistent with the hardware and the other ESFAS functions on Table 3.3.2-1, there must be a separate functional item for the P-4, P-1 1 & P-12 actuation logic and relays with applicable mode, channel, condition and surveillance requirements. Because the P-11 & P-12 logic requires two-out-of-four (or -three) channels above (or below) the setpoint (or reset) before the interlock can achieve the required state, no action is required until two (or three) channels are inoperable. Some P-4 safety functions (e.g., turbine trip and reset high steam flow setpoint) can only be tested when the plait is shutdown; theretore, a 'I'AUOT I _ - -~ -test frequency of each RTB cv'Ee (SR 3.3.2.1 1) is not appropriate. T h e P - l l & P-12 channel check requirement (SR 3.3.2.1) is a duplication of the channel check required for other pressurizer pressure and RCS Tavg ESFAS functions. The TS Bases do not capture important functions, which must be included in surveillance testing, for P-4 (seal-in Feed Water Isolation (FWI) by Safety Injection (SI) and reset high steam flow setpoint), P-1 1 (interlock pressurizer PORVs closed), and P-12 (interlock steam dump valves closed) as defined by the Westinghouse "Reactor Control and Protection System Functional Requirements." The permissives (P-4, P-1 1, and P-12) are not directly credited in the safety analyses, although some analyses "model" selected permissive functions, such as the turbine trip on reactor trip function of the P-4 permissive, as it is expected to occur and result in a limiting transient for many events.

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WOG-166, Rev. 0 TSTF-444-T, Rev. 1

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The ISTS surveillance SR 3.3.2.1 1 is deleted. The ISTS surveillance SR 3.3.2.1 1 was applicable to the P-4 interlock. The required P-4 interlock testing previously addressed by ISTS SR 3.3.2.1 1 is replaced with ISTS SR 3.3.2.8. ISTS SR 3.3.2.8 requires a TADOT be performed every 18 months for manual initiation functions and is consistent with the NUREG-0452 P-4 testing frequency specified on Table 4.3-2 for the ESFAS interlocks 1. By assigning ISTS SR 3.3.2.8 to the P-4 interlock instead of ISTS SR 3.3.2.1 1, the ISTS frequency of testing the P-4 interlock Once per reactor trip breaker cycle is revised to be consistent with the NUREG-0452 18 month test frequency. The P-4 testing requirements associated with ITS SR 3.3.2.8 are also consistent with NUREG-0452 surveillance 4.3.2.2, which requires that the total interlock function be demonstrated operable every 18 months. Therefore, consistent with NUREG-0452, the P-4 inputs to the SSPS logic circuits and P-4 actuation signals (e.g., turbine trip) will be tested under this ISTS TADOT.

Additionally, the setpoint verification not required note which modifies ISTS SR 3.3.2.8 is revised to include the P-4 interlock consistent with the P-4 ISTS surveillance SR 3.3.2.1 1 (the reference to manual initiation functions is deleted from the note).

The ISTS surveillances associated with the P-1 1 and P-12 ESFAS interlock functions are revised consistent with the NUREG-0452 surveillance requirements for these functions. Separate surveillance requirements will be provided for the instrument channel and the actuation logic. The ISTS 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> channel check surveillance requirement for these functions is deleted, since it is redundant to channel checks performed for the other pressurizer pressure and RCS temperature ESF functions. This approach is also consistent with the RTS Permissive/Interlock channel check surveillance (i.e., no channel check is specified when the channel check is performed for other RTS functions). The NUREG-0452 Surveillance SR 4.3.2.2 and Table 4.3-2 require that the interlock logic be tested with the Automatic Actuation Logic test and that the total interlock function be tested and the individual channels be calibrated every 18 months. To make the change from the NUREG-0452 to the ISTS format, the Automatic Actuation Logic and Actuation Relays function for the interlocks was broken out and listed separately. This approachlformat is consistent with all other ESF functions. The logic for generating each permissive/interlock signal will be tested for each interlock function as described below to meet the logic circuit testing requirements of NUREG-0452 SR 4.3.2.2. The total interlock function will be tested with ISTS SR 3.3.2.9 Channel Calibration, ISTS SR 3.3.2.2 Actuation Logic Test, ISTS SR 3.3.2.4 Master Relay Test, and ISTS 3.3.2.6 Slave Relay Test. The ISTS SR 3.3.2.5 COT for P-11 and P-12 will be performed on a 92-day interval in conjunction with the associated ESFAS pressure and temperature channel COT. This frequency is consistent with the setpoint uncertainty calculation allowances for rack drift for other ESF functions that utilize identical hardware. The 18-month calibration for P-11 and P-12 will complete the total interlock functional check and coincide with the refueling outage channel calibration requirement from the NUREG-0452 surveillance requirement 4.3.2.2 and Table 4.3-2. The ISTS changes also ensure that the Logic Test, Master and Slave Relay Tests, COT and Channel Calibration requirements for P-12 are identical to the surveillance requirements for the RCS TavgLow-Low input for Main Steam Line Isolation (MSLI).

The ISTS Automatic Actuation Logic and Actuation Relay function associated with the P-4, P-1 1 and P-12 interlock functions was added to be consistent with the NUREG-0452 surveillance requirement for these functions. NUREG-0452 surveillance requirement 4.3.2.2 required that the logic for the interlock be demonstrated operable during the automatic actuation logic test. This new line item under the function provides for the explicit testing of the SSPS automatic actuation logic associated with P-4, P-1 1 and P-12.

Additionally, this line item will contain the surveillance requirements for testing the Master and Slave relays associated with the P-1 1 function of interlocking closed the PORVs and the P-12 function of interlocking closed the Steam Dump Control System valves. This change maintains the format for these functions as specified in the NUREG-0452 LCO 3.3.2 and surveillance requirement 4.3.2.2 and allows assignment of a separate Condition for the interlock function and the interlock channels. The change also provides consistency with all other ESFAS functions that utilize the SSPS logic circuits and safeguards actuation circuits and relays.

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WOG-166, Rev. 0 TSTF-444-T, Rev. 1

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5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration The proposed change to the ISTS will accomplish the following: Add a new functional item, Automatic Actuation Logic and Actuation Relays, on ESFAS Instrumentation Table 3.3.2-1, which includes Mode (1,2, 3 & 4), Channel (2 trains), Condition (M) and Surveillance Requirements (3.3.2.2,3.3.2.4 & 3.3.2.6), under Function No. 8 ESFAS Interlocks. Revise Condition L by changing the requirements from one or more channels inoperable to one or more required channels inoperable. Add new Condition M, which will be applicable to the ESFAS interlock logic and relays with one train inoperable. Delete surveillance 3.3.2.1 1 under TS 3.3.2, ESFAS Instrumentation, and add new surveillance 3.3.2.8 to P-4 on Table 3.3.2-1. Delete surveillance 3.3.2.1 from P-11 & P-12 on Table 3.3.2-1. Revise Bases Section B 3.3.2, ESFAS Instrumentation, to reflect the correct design basis of the ESFAS Interlocks P-4, P-1 1 & P-12.

In accordance with the criteria set forth in 10 CFR 50.92, the proposed changes to NUREG-1431 have been evaluated and determined they do not represent a significant hazards consideration. The following is provided in support of this conclusion:

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

Response: No The proposed changes do not significantly increase the probability or consequences of an accident previously evaluated in the Final Safety Analysis Report (FSAR). These interlocks and the associated testing do not directly initiate an accident. The consequences of accidents previously evaluated in the FSAR are not adversely affected by these proposed changes because the changes are made to accurately reflect the design of the ESFAS system and format of the ISTS. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No The proposed changes do not create the possibility of a new or different kind of accident than any accident already evaluated in the FSAR. No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed change. The proposed Technical Specifications change does not challenge the performance or integrity of any safety-related systems. Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously analyzed.

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

Response: No The proposed changes do not involve a significant reduction in a margin of safety. The proposed changes are made to accurately reflect the design of the ESFAS system and format of the ISTS. The nominal actuation setpoints specified by the Technical Specifications and the safety analysis limits assumed in the transient and accident analysis are unchanged. The margin of safety associated with the acceptance criteria for any accident is unchanged. Therefore, the proposed change will not significantly reduce the margin of safety as defined in the Technical Specifications.

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WOG-166, Rev. 0 TSTF-444-T, Rev. 1

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5.2 Applicable Remlatory Reauirements/Criteria The regulatory bases and guidance documents associated with the systems discussed in this proposed change include:

GDC-13 requires that instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems.

GDC-20 requires that the protection system(s) shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.

GDC-21 requires that the protection system(s) shall be designed for high functional reliability and testing.

GDC-22 through GDC-25 and GDC-29 require various design attributes for the protection system(s),

including independence, safe failure modes, separation from control systems, requirements for reactivity control malfunctions, and protection against anticipated operational occurrences.

Regulatory Guide 1.22 discusses an acceptable method of satisfying GDC-20 and GDC-2 1 regarding the periodic testing of protection system actuation functions. These periodic tests should duplicate, as closely as practicable, the performance that is required of the actuation devices in the event of an accident.

10 CFR 50.55a(h) requires that the protection systems meet IEEE 279-1971. Section 4.9 - 4.1 1 of IEEE 279- 1971 discuss testing provisions for protection systems.

There have been no changes to the ESFAS instrumentation design such that any of the regulatory requirements and guidance documents discussed above would come into question. This TSTF revises surveillance testing requirements on the ESFAS instrumentation consistent with those requirements and guidance documents. The evaluation performed in Section 4.0 concludes that licensees will continue to comply with the applicable regulatory requirements.

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

6.0 ENVIRONMENTAL CONSIDERATION

S A review has determined that the proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 5 1.22(~)(9).Therefore, pursuant to 10 CFR 5 1.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Revision History I 7-Jun- 04 Traveler Rev. 3. Copyright (C) 2004, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-166, Rev. 0 TSTF-444-T, Rev. 1

~~

OG Revision 0 Revision Status: Active Revision Proposed by: WOG Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 26-Mar-02 Owners Group Comments (No Comments)

Owners Group Resolution: Approved Date: 20-May-02 TSTF Review Information TSTF Received Date: 20-May-02 Date Distributed for Review 21 -Jun-02 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 01-Aug-02 NRC Review Information NRC Received Date: 07-Aug-02 Final Resolution: TSTF Withdraws Final Resolution Date: 3 1-0ct-03 TSTF Revision 1 Revision Status: Active Revision Proposed by: WOG Revision

Description:

TSTF not willing to pay review fees for this change. The TSTF withdrew the change from NRC review and made it a "T" Traveler.

TSTF Review Information TSTF Received Date: 15-Oct-03 Date Distributed for Review 15-Oct-03 OG Review Completed: @ BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved for Use Date: 15-Oct-03 Affected Technical Specifications

~~ ~ ~ ~ ~ _ _ _ _ _ _ ~

LCO 3 3 2 ESFAS Instrumentation 17-Jun-04 Traveler Rev 3 Copynght (C) 2004, EXCEL Services Corporation Use by EXCEL Services associates, utility clients, and the U S. Nuclear Regulatory Commission is granted All other use without written permission is prohibited

WOG-166, Rev. 0 TSTF-444-T, Rev. 1

_ ~ _ ~~ __ ~~ _ _ _ ~ _ _ _ _ ~- _ .

Change Description Table 3 3 2-1 LCO 3.3 2 Bases ESFAS Instrumentation Action 3.3.2.C Bases ESFAS Instrumentation Action 3.3.2.F Bases ESFAS Instrumentation Action 3.3.2.L ESFAS Instrumentation Action 3.3.2.L Bases ESFAS Instrumentation Action 3.3.2.M ESFAS Instrumentation Change

Description:

New Action 3.3.2.M Bases ESFAS Instrumentation Change

Description:

New SR 3.3.2.2 Bases ESFAS Instrumentation

.~ -~~ ~ ~ - _.

SR 3.3.2.5 Bases ESFAS Instrumentation SR 3.3.2.8 ESFAS Instrumentation SR 3.3.2.8 Bases ESFAS Instrumentation SR 3.3.2.11 ESFAS Instrumentation Change

Description:

Deleted SR 3.3.2.1 1 Bases ESFAS instrumentation Change

Description:

Deleted 17-Jiin-04 Traveler Rev. 3. Copyright (C) 2004, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-444-T, Rev. 1 ESFAS Instrumentation 3.3.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME K. One channel inoperable.

- NOTE -

One additional channel may be bypassed for up to

[4] hours for surveillance testing.

K. I Place channel in bypass. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> K.2.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> K.2.2 Be in MODE 5. 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />

~

L. One or more channels L.l Verify interlock is in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. required state for existing unit condition.

OR L.2.1 Be in MODE 3. 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> L.2.2 Be in MODE 4. 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> I

SR -3.3.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> WOG STS 3.3.2 - 5 Rev. 2, 04/30/01

TSTF-444-T, Rev. 1 INSERT I M. One train inoperable. M.l Verify interlock is in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> required state for existing unit conditions.

OR M.2 I------...------------

- NOTE -

One train my be bypassed for up to [4] hours for Surveillance testing, provided the other train is OPERABLE.

Restore train to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> OPERABLE status.

OR M.3.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND M3.2 Be in MODE 5. 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />

TSTF-444-T, Rev. 1 ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS (continued) -

SURVElLLANCE FREQUENCY SR 3.3.2.2 Perform ACTUATION LOGIC TEST. 31 days on a

~

STAGGERE0 TEST BASIS SR 3.3.2.3 31 days on a STAGGERED TEST BASIS

~

SR 3.3.2.4 Perform MASTER RELAY TEST. 31 days on a STAGGERED TEST BASIS

~

SR 3.3.2.5 Perform COT. 92 days SR 3.3.2.6 Perform SLAVE RELAY TEST. 1921days SR 3.3.2.7

[92] days

[I81 months SR 3.3.2.9 Perform CHANNEL CALI.BRATI ON. [I81 months WOG STS 3.3.2 -6 Rev. 2,04/30/01

TSTF-444-T, Rev. 1 ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY Verify ESFAS RESPONSE-TIMESare within limit. [48rmonths on a STAGGERED TEST BASIS WOG STS 3.3.2- 7 Rev. 2, 04/30/01

TSTF-444-T, Rev. 1 ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 8 of 8)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

7. Automatic Switchover to Containment Sump

c. RWST Level - 1,2,3,4 4 K SR 3.3.2.1 2 [15]% [18]%

Low Low SR 3.3.2.5 SR 3.3.2.9 SR 3.3.2.10 Coincident with Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

Safety Injection and Coincident with 1,2,3,4 4 K SR 3.3.2.1 2 [30] in. above [ ] in. above Go?tainment SR 3.3.2.5 - el. [703]ft el. I ]ft Sump Level - SR 3.3.2.9 High SR 3.3.2.10

\w#?T 2

8. ESFAS Interlocks Reactor Trip, 1.23 1 per train, SR 3.3.2:@ NA NA 2 trains Pressurizer Pressure, P-I 1

[553]"F SR 3.3.2.9 WOG STS 3.3.2- 15 Rev. 2, 04/30/01

TSTF-444-T, Rev. 1 INSERT 2

a. AutomaticActuation 1.2.3,4 2 trains M SR 3.3.2.2 NA NA Logic and Actuation SR 3.3.2.4 Relays SR 3.3.2.6

TSTF-444-T, Rev. 1 ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

These Functions must be OPERABLE in MODES 1,2,3, and 4 when there is a-potential for a LOCA to occur, to ensure a continued supply of water for the ECCS pumps. These Functions are not required to be OPERABLE in MODES 5 and 6 because there is adequate time for the operator to evaluate unit conditions and respond by manually starting systems, pumps, and other equipment to mitigate the consequences of an abnormal condition or accident. System pressure and temperature are very low and many ESF components are administratively locked out or otherwise prevented from actuating to prevent inadvertent overpreswri-zation of unit systems. - -

8. Enqineered Safetv Feature Actuation Svstem Interlocks To allow some flexibility in unit operations, several interlocks are included as part of the ESFAS. These interlocks permit the operator to block some signals, automatically enable other signals, prevent some actions from occurring, and cause other actions to occur. The interlock Functions back up manual actions to ensure bypassable functions are in operation under the conditions assumed in the safety analyses.

Enqineered Safetv Feature Actuation Svstem Interlocks -

Reactor Trip. P-4 The P-4 interlock is enabled when a reactor trip breaker (RTB) and its associated bypass breaker is open. Once the P-4 interlock is enabled, automatic SI initiation is blocked after a

[ 3 second time delay. This Function allows operators to take manual control of SI systems after the initial phase of injection is complete. Once SI is blocked, automatic actuation of SI cannot occur until the RTBs have been manually closed. The functions of the P-4 interlock are:

I */ PreveMeactuation OHI after a mangdreset of SI/ 1

~~

WOG STS 6 3.3.2 - 34 Rev. 2, 04/30/01

TSTF-444-T, Rev. 1 INSERT I B

a. Engineered Safety Feature Actuation System Interlocks - Automatic Actuation Loqic and Actuation Relays Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.

INSERT 2 8 Function Purpose Required MODES 0 [Isolate MFW with coincident Feedwater isolation 1, 21 Ta, 0 Trip the main turbine Prevents excessive cooldown, 1, 2 thereby Condition II event does not propogate to Condition Ill event.

Prevent re-actuation of SI Allows alignment of ECCS for 1, 2, 3, 4 (required to support SI after a manual reset of SI recirculation mode; prevents function in MODE 4) subsequent inadvertent alignment to injection mode by auto SI.

0 [Reset hkh steam flow Ensures setpoint is reset to 1, 2, 3 (function not required if setpoint to no-load value low/zero power reference MSlVs are closed)]

value following plant trip, I - HighSteam in regardless of turbine first Two Steam Lines stage pressure indication Coincident With Steam Line Pressure - Low

2) SI - High Steam Flow in Two Steam Lines Coincident With Tavg -

Low Low

3) Main Steam Line Isolation (MSLI) - High Steam Flow in Two Steam Lines Coincident With Tavg - Low Low

4) MSLI - High Steam Flow in Two Steam Lines Coincident With Steam Line Pressure - Low Prevent opening of the MFW Seal-in feedwater isolation to 1, 2, 3 isolation valves if they were prevent inadvertent feeding of closed on SI or SG Water de-pressurized SG.

Level - High High

TSTF-444-T, Rev. 1 ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

~ c c

-c a Each of the above Functions is interlocked with P-4 to avert or s t e r n gen-tor associ reduce the continued cooldown of the RCS following a reactor

@&-\,r;c w.fc&\,ne trip. An excessive cooldown of the RCS following a reactor trip ive reactivity with a s u b f e q m t resalt k eessivc Ur\tA\hmcnt To avoid such a situation, the n interlocked with P-4as part of the design of the unit control and protection system.

The RTB position switches that provide input to the P-4 C t ? W \A+kOv\ mdc. interlock only function to energize or de-energize or open or close contacts. Therefore, this Function has no adpstable trip setpoint with which to associate a Trip Setpoint and Allowable Value.

This Function must be the reactor may be critical or Function does not have to be OPERABLE in MODE@& 6 because the main turbine, the MFW System, and the Steam Dump System are not in operation.

Enqineered Safetv Feature Actuation System Interlocks -

Pressurizer Pressure, P-I 1 The P-11 interlock permits a normal unit cooldown and depressurization without actuation of SI or main steam line isolation. With two-out-of-three pressurizer pressure channels (discussed previously) less than the P - I 1 setpoint, the operator can manually block the Pressurizer Pressure - Low and Steam Line Pressure - Low SI signals and the Steam Line Pressure -

Low steam line isolation signal (previously discussed)?When the Steamline Pressure - Low steam line isolation signal is manually blocked, a main steam isolation signal on Steam Line WOG STS B 3.3.2 - 35 Rev. 2, 04/30/01

TSTF-444-T, Rev. 1 ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

Pressure - Negative Rate - High is enabled. This provides

- - ~ protection for an SLB by closure of -the MSIVs. With- - -

two-out-of-three pressurizer pressure channels above the P-11 setpoint. the Pressurizer Pressure - Low and Steam Line Pressure - Low SI signals and the Steam Line Pressure - Low steam line isolation siqnal are automatically enabled. The operator can also e n a b l e w* m by use of the respective manual res&$BE$ When the Steam Line Pressure - Low steam line isolation signal is enabled, the main steam isolation on Steam Line Pressure - Negative Rate High is disabled.

The Trip Setpoint reflects only steady state instrument uncertainties. - _ _

This Function must be OPERABLE in MODES 1,2, and 3 to allow an orderly cooldown and depressurization of the unit without the actuation of SI or main steam isolation. This

~ -~

Ftlnction-does not h a w to-beOPERABLE in MODE 4,5, or 6 because system pressure mustalready be below the P-I 1 setpoint for the requirements of the heatup and cooldown On increasing rea reactor coolant temperature, the P-12 interlock allows the operator to manually block SI High Steam Flow Coincident With Steam Line Pressure - Low or Coincident with T ,,, - Low malfunctioning Steam Dump System3 .t Since Tavg. is used as an-indicatbnofbulk RCS temperature, this Function meets redundancy requirements with one OPERABLE channel in each loop. In three loop units, these channels are used in two-out-of-three logic. In four loop units, WOG STS B 3.3.2 - 36 Rev. 2, 04/30/01

TSTF-444-T, Rev. 1 INSERT 38

[On decreasing temperature with [two-out-of-three][two-out-of-four] nnels below the setpoint, the P-12 interlock function is to provide MSLl on High Steam Flow i team Lines Coincident

, - Low Low or SI and MSLl on Stea ine ipressure - L With T ent With TW - Low Low.]

Another P-I 2 function on decreasing temperature is

TSTF-444-T, Rev. 1 ESFAS Instrumentation B 3.3.2 BAEs. .. ~~ . ~ -- - . . .. .. .. . ........ ~ .......

GGGG& reinstae 51 r APPLICABLE SAFETY ANALYSES, LCO, and APPLtCABILITY (continued) n ~ be OPERABLE in MODES 1,2, and A h e n 1 MSL\ an stc9vnLi ak or stuck open valve codd result in the or qi+ S k ~ m F\OW c~k~r\C;dwt rapid depressurizationof the steam lines. This Function does not have to be OPERABLE in MODE 4,5, or 6 because there is s* bnc insufficient energy in the secondary side of the unit to have an accident.

The ESFAS instrumentationsatisfies Criterion 3 of 10 CFR 50.36(~)(2)(ii).

ACT1ONS A Note has been added in the the application of Completion Time rules. The ecification may be entered independently for ea Table 3.3.2-1.

In the event a channel's nservative with respect to the Allowable trument Loop, signal processing electronics, ble, the.n.all_affected Functions provided by tha . operable and the LCO Condition(s) entered affected. When the Required Channels in steam tine, per loop, pe entered separately for When the number of ino in a trip function exceed those specified in one or other s associated with a trip function, then the unit is o ty analysis. Therefore, LCO 3.0.3 should be im d if applicable in the current MODE of operation.

A.1 ~

Condition A applies to all ESFAS protection functions.

Condition A addresses the situation where one or more channels or trains for one or more Functions are inoperable at the same time. The

- Required Action is to refer to Table 3.3.2-1and to take the Required WOG STS B 3.3.2 - 37 Rev. 2, 04/30/01

TSTF-444-T, Rev. 1 ESFAS Instrumentation B 3.3.2 BASES ACTIONS (continued)

Actions for the protection functions affected. The Completion Times are those from the referenced Conditions and RequiredActions.

B.1. B.2.1 and 8.2.2 Condition B applies to manual initiation of:

SI, Containment Spray, PhaseAtsehtien;and - ~ - - -

Phase B Isolation.

This action addresses the train orientation of the SSPS for the functions listed above. If a return it to an OP Phase B isolation mpasses both situations.

nsidering that there are two automatic actuation trains anual initiationitrain a b i t i of an event occurring during this int nnot be restored to in a MODE in which the LCO does not a DE 5 within an required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

C.1. C.2.1 and C.2.2 Condition C applies to the automatic actuation logic and actuation relays for the following functions:

Containment Spray, Phase A Isolation, WOG STS B 3.3.2 - 38 Rev. 2, 04/30/01

TSTF-444-T, Rev. 1 ESFAS Instrumentation B 3.3.2 BASES ACTiO NS (continued)

Loss of Offsite Power, 0&

ater Pump Sctcain Transfer on Suction Pressure -

For the Manual lnitiat addresses the train o Power Function, this a for a failed channel. F during operation is ature of these and without challenging u any analyzed transients or protection functions noted

~

G.1, G.2.1 and G.2.2 Condition G applies to the automatic actuation logic and actuation relays for the Steam Line Isolation !,Turbine Trip and Feedwater Isolation,] and AFW actuation Functions.

and slave relays forth rain is inoperable, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> are allowed to restore E status. The Completion Time for restorin to MODE 3 within the next Completion Time reach the required unit con WOG STS B 3.3.2 - 42 Rev. 2, 04/30/01

TSTF-444-T, Rev. 1 ESFAS Instrumentation B 3.3.2 ACTIONS (continued)

L.1, L.2.1 and L.2.2 interlock is in the requir ition. This action maMIalCy accomplishes be made within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

state (or placed in the required state) for the ,existing unit condition, the unit must be placed-iR-MQDE 3 within thenext6 hours and MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.' The allowed Completion Times are reasonable, based on operating experience, to reach the required unit SURVEILLANCE The SRs for each ESFAS Function are identified by the SRs column of REQUIREMENTS Table 3.3.2-1.

. - -~~~ -

A Note has been added to the SR Ta to cldrify that Table 3.3.2-1 determines which SRs apply to whic FAS Functions.

Note that each channel of process protection supplies both trains of the ESFAS. -When testing channel I, train A and train B must be examined.

Similarly, train A and train B must be n testing channel II, channel Ill, and channel IV (if applica CALIBRATION and COTSare performed in a manner that is consistent with the assumptions used in analytically calculating the required channel accuracies.

SR 3.3.2.1 Performance of the CHANNEL-CHECK once every 12 hows 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 WOG STS B 3.3.2- 46 Rev. 2,04/30/01

TSTF-444-T, Rev. 1 INSERT 4B Condition M applies to the automatic actuation logic and actuation for the P-4, P-I 1 and P-12 interlocks. This Condition is applicable whe o that extent that an ESFAS Function which should Rot-BebkxkedWke-With one train inoperable, the operator must ve required state for the existing unit condition. This action manually a f the interlock. Determination must be made within Ihour. If the interlock is aced in the required state) for the existing unit condition, the intertock must be LE status within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or the unit must be placed in MODE 3 within the ODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power condition$ in an orderly manner unit systems. Placing the unit in MODE 5 removes all interlocks and the automatic actuation logic, SI actuati This Condition is intended to address an inoperability of the actuation logic or relays associated with a given train which affects the integrated ESFAS a pressurizer pressure low Sl (P-11),

steam line low pressure SliMSLl (P-I 1 or P-l2), H am Flow Coincident With Steam Line Pressure - Low or Coincident With Tava- Low L uation signal. The relatively short Completion Time of this action (6h fact that multiple ESF components (systems or equipment) within a train ilure of the actuation logic or relays. This Condition is applicable whenever tem is affected by the inoperable train of logic or relays. However, if ation relay(s) in a train affect only a single ESF System, then the AC pplicable to the affected ESF component or system should be entere This action addresses the train orientation of the e master and slave relays. Ifone train is inoperable, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> are allowed to restore the E status. _Thespecified ~

Completion Time is reasonable considering that another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> total time) and in MODE 5 within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> total time). The CompletionTimes are reasonable; based OR operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

The Required Actions are modified by a Note that allows one train to be bypassed for up to [4] hours for surveillance testing, provided the other train is OPERABLE. This allowance is based on the reliability analysis (Ref. 8) assumption that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the average time required to perform channel surveillance.

TSTF-444-T, Rev. 1 ESFAS Instrumentation 6 3.3.2

- -~

SURVEILLANCE REQUIREMENTS (continued) similar parameter on ot ased on the assumption that instrument channels mom meter should read - -

CHECK will detect g s key to verifying the instrumentation -emhCHANNEL CALIBRATION.

Agreement criteria are dete unit staff, based on a combination of the channel certainties, including indication and reliability.- If a channeb FiteFia, it msty beanhdicatbn that the sensor or the signal processing equipment has drifted outside its limit.

The Frequency is base rience that demonstrates channel failure is rare. ECK supplements less formal, but more frequent, check ng normal operational use of the displays associated WI ired channels.

SR 3.3.2.2

__ ~ _._ - . .

SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST. The signal path to the master relay coils. The Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based on industry operating experience, considering instrument reliability and operating history data.

SR 3.3.2.3 SR 3.3.2.3 is the performance of an ACT ION LOGIC TEST as described in SR 3.3.2.2, except that the semiautomatic tester is not used and the continuity chec have to be performed, as explained in the Note. This SR is ap e balance of plant relays that do not have S test circuits instaiie semiautomatic tester or perfprm the cQntinuitycheck. This test is also

~

WOG STS B 3.3.2 - 47 Rev. 2, 04/30/01

TSTF-444-T, Rev. 1 ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued) performed every 31 days on a STAGGERED TEST BASIS. The Frequency is adequate based on industry operating experience,-

considering instrument reliability and operating history data.

SR 3.3.2.4 SR 3.3.2.4 is the perf0 RELAY TEST. The MASTER RELAY TE e master relay, verifying contact operation an check of the slave relay coil. Upon master relay conta ,a low voltage is injected to the slave relay coil. This voltage i t to pick up the slave relay, but Iwge enough to de inuity. This test is performed every 31 days on a TEST BASIS. The time allowed for the testing (4 hou urveillance interval are justified in Reference 8.

_ _ SR..3325

... ~ ________ __ _ _ - ._

SR 3.3.2.5 is the performance of a COT. ..

must be found A successful test e all of l h e other required contacts of the relay are verified by other cal Specifications and non-Technical The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.

The "as found" and "as left" values must also be recorded and reviewed for consistency with the assumptions of the surveillance interval extension analysis (Ref. 8) when applicable.

The Frequency of 92- days . is justified in Reference 8.

WOG STS B 3.3.2 - 48 Rev. 2, 04/30/01

TSTF-444-T, Rev. 1 ESFAS *Instrumentation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.6

_ _ _ ~ _ - .

RELAY TEST. The SLAVE verified in one of two ways.

the design mitigation MUDE condition where t quipment that may not be the SLAVE RELAY TES case, contact operation is and operating history data.

SR 3.3.2.7 SR 3.3.2.7 is the perfor check of the Loss of Offsit Suction Transfer on Suctio ns. Each Function is ils. A successful because all of the other Technical Spe least once per refueling-intervarwith applicable extensions.

The test also includes trip devices th actuation signats directly to the SSPS. The SR is modified by that excludes verification of setpoints for relays. Relay setpoints elaborate bench calibration and are verified during CHANNEL CA ION. The Frequency is adequate. It is based on industry operating experience, considering instrument reliability and operating history data.

SR 3.3.2.8 SR 3.3.2.8 is the performan TADOT. This test is a check of the Manual Actuation Functi on trip of all MRN pump& It is performed ev Manual Actuation Function is tested up to, a aster relay coils. A .

successful test of the req a channel relay may be performed by the verification of the of state of a single contact of WOG STS B 3.3.2 - 49 Rev. 2,04/30/01

TSTF-444-T, Rev. 1 ESFAS lhstrumentation B 3.3.2 BASES ~~

T of a relay. This is SR 3.3.2.9 SR 3.3.2.9 is the performanice of a CHANNEL CALIBRATION.

A CHANNEL CALIB approximately at ev verifies that the necessary rang assumptions of the unit y. The difference between the current "as methodology.

- ~~

The Frequency of [ he assumption of an

[I81 month calibrati ination of the magnitude of equipment drift in t This SR is modified by a Note stating that this test should inctude verification that the time constants are adjusted to the prescribed values where applicable.

SR 3.3.2.10 SPONSE TIMES are less the accident analysis.

re included in the Technical Individual component

. The analyses model which the parameter WOG STS B 3.3.2 - 50 Rev. 2,04/30/01

TSTF-444-T, Rev. 1 ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued) response time provided the parts used for repair are of the same type and value. Specific cornporlentsidentifiedinthe WCAP may replaced without verification testing. One example where response time could be affected is replacing the sensing assembty of a trahsmitter.

ESF RESPONSE TIME tesk are conducted on an [I81 month STAGGERED T actuation- devices, which make up the bulk of th channel. The final act channel. There unit operating experience, This SR is modified byaNdte that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching11000]psig in the SGs.

REFERENCES 1. FSAR, Chapter [6].

2. FSAR, Chapter m.

3. FSAR, Chapter-[l-5].

4. IEEE-279-1971.

WOG STS - B 3.3.2 52 Rev. 2, 04/30/01