NL-05-0237, Request to Revise Technical Specifications Reactor Trip System Instrumentation

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Request to Revise Technical Specifications Reactor Trip System Instrumentation
ML052620463
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 09/19/2005
From: Grissette D
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-05-0237
Download: ML052620463 (26)
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Text

Don E. Grissette Southern Nuclear Vice President Operating Company, Inc.

40 lnverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.6474 Fax 205.992.0341 September 19, 2005 Energy to Serve Your World" Docket Nos.: 50-424 NL-05-0237 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Request to Revise Technical Specifications Reactor Triv System Instrumentation Ladies and Gentlemen:

In accordance with the requirements of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposes to revise the Vogtle Electric Generating Plant (VEGP) Unit 1 and Unit 2 Technical Specifications (TS). The proposed change would revise TS Limiting Conditions for Operation (LCO) 3.3.1, "Reactor Trip System (RTS)

Instrumentation" and TS Surveillance Requirements (SR) 3.2.4.2, "Quadrant Power Tilt Ratio (QPTR)." The proposed change would revise TS 3.3.1, Condition D and the NOTE in SR 3.2.4.2 in order to avoid confusion as to when a flux map for QPTR is required.

The basis for this proposed change is described in Enclosure 1. A Significant Hazard Consideration Evaluation is provided in Enclosure 2. A Regulatory Safety Analysis is provided in Enclosure 3. Marked-up TS and Bases pages are provided in Enclosure 4, and clean-typed pages are provided in Enclosure 5.

SNC requests approval of the proposed license amendment by October 1,2006. The proposed change would be implemented within 90 days of issuance of the amendment.

(Affirmation and signature are provided on the following page.)

U. S. Nuclear Regulatory Commission NL-05-0237 Page 2 Mr. D. E. Grissette states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

This letter contains no NRC commitments. If you have any questions, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Don E. Grissette Sworn to and subscribed before me this of- , 2005.

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Enclosures:

Enclosure 1: Basis for Proposed Changes Enclosure 2: Significant Hazard Evaluation and Environmental Assessment Enclosure 3: Regulatory Safety Analysis Enclosure 4: Marked-up TS and Bases Pages Enclosure 5: Clean-typed TS and Bases Pages cc: Southern Nuclear Operating Comvany Mr. J. T. Gasser, Executive Vice President Mr. T. E. Tynan, General Manager - Plant Vogtle RType: CVC7000 U. S. Nuclear Regulatorv Commission Dr. W. D. Travers, Regional Administrator Mr. C. Gratton, NRR Project Manager - Vogtle Mr. G. J. McCoy, Senior Resident Inspector - Vogtle

Enclosure 1 Vogtle Electric Generating Plant Request to Revise Technical Specifications Reactor Trip Setpoint Instrumentation Basis for Proposed Changes

Enclosure 1 Vogtle Electric Generating Plant Request to Revise Technical Specifications Reactor Trip Setpoint Instrumentation Basis for Proposed Chanpes Southern Nuclear Operating Company (SNC) proposes to revise the Vogtle Electric Generating Plant (VEGP) Unit 1 and Unit 2 Technical Specifications (TS). The proposed amendment would modify Technical Specification (TS) Limiting Condition for Operation (LCO) 3.3.1 and Surveillance Requirements (SR) 3.2.4.2. The proposed amendment will better align the requirement to perform a flux map once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with LC0 3.2.4.

The following is a detailed description of the proposed changes.

LC0 3.3.1, "RTS Instnunentation," a Note is added to refer to LC0 3.2.4 for an inoperable Power Range Channel. The existing Note becomes Note 1 and the new Note is Note 2.

LC0 3.3.1, "RTS Instrumentation," Required Actions D. 1.2, D.2.1 and D.2.2 are deleted. The remaining Required Actions are renumbered accordingly.

SR 3.2.4.2, "QPTR," the Note is revised to be consistent with the changes to LC0 3.3.1.

Background

Amendment No. 1 16/94 approved the incorporation of WCAP-14333. In this application, LC0 3.3.1, Condition D was revised to allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to place a channel in trip as opposed to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, but the requirement to perform SR 3.2.4.2 in Required Action D.2.2 remained once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. As a result, there is a potential for confusion with the layout of the current TS 3.3.1, Condition D. TS LC0 3.3.1, Condition D could incorrectly lead an operator to believe that he could pursue the option of Required Actions D. 1.1 and D. 1.2, potentially overlooking the requirement to do a flux map for QPTR within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. In addition, Required Actions with shorter Completion Times (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) should appear before Required Actions with longer Completion Times (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) in the D.2.1 and D.2.2 option. Deleting Required Action D. 1.2, D.2.1 and D.2.2 from LC0 3.3.1, Condition D eliminates requirements that are duplicative to LC0 3.2.4, thereby eliminating the potential for confusion. Finally, SR 3.2.4.2 is revised to be consistent with the proposed changes to LC0 3.3.1, Condition D.

Technical Analysis Amendment No. 116/94 approved relaxation of allowed bypass test times and Completion Times for Limiting Conditions for Operation (LCO) 3.3.1, "Reactor Trip System (RTS)

Instrumentation." These relaxations are those that were generically approved in WCAP-14333-P-A, Revision 1, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times."

Specifically, the amendment allowed, in part:

Completion Times of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for inoperable analog instruments, and Bypass times of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing of analog channels.

Enclosure 1 Vogtle Electric Generating Plant Request to Revise Technical Specifications Reactor Trip Setpoint Instrumentation Basis for Pro~osedChanges Condition D applies to the Power Range Neutron Flux-High Function. If one channel is inoperable, then the channel must be placed in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as stated in Required Action D. 1.1. In addition to placing the inoperable channel in the tripped condition, the Required Action in D. 1.2 requires the thermal power reduced to 5 75% RTP within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />. An alternate to D. 1.1 and D. 1.2 is to place the inoperable channel in the tripped condition and perform SR 3.2.4.2 once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

On the other hand, LC0 3.2.4, SR 3.2.4.2 requires a flux map to be performed whenever a power range channel is inoperable with power 2 75% RTP. This flux map must be performed once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. The existing layout of LC0 3.3.1, Condition D could incorrectly lead an operator to believe that he could pursue just the option of D.l.l and D. 1.2, potentially overlooking the requirement to do a flux map for QPTR within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The proposed amendment would revise TS 3.3.1 Condition D to avoid confusion as to when a flux map for QPTR is required.

The revised Condition D inserts a NOTE to refer to LC0 3.2.4 for an inoperable power range channel. In addition, Required Actions D. 1.2, D.2.1 and D.2.2 are deleted. The requirement to perform SR 3.2.4.2 is defined in LC0 3.2.4. The Note to existing SR 3.2.4.2 is revised to state that SR 3.2.4.2 is only required when the Power Range Neutron Flux input to QPTR is inoperable. If the otherwise inoperable power range channel remains capable of providing a valid input to QPTR, there is no need to perform SR 3.2.4.2. This is consistent with the existing requirements of LC0 3.3.1, Condition D that are proposed for deletion. This proposed change will help eliminate potential confusion regarding the completion time to perform SR 3.2.4.2.

Enclosure 2 Vogtle Electric Generating Plant Request to Revise Technical Specifications Reactor Trip Setpoint Instrumentation S i d c a n t Hazards Evaluation and Environmental Assessment

Enclosure 2 Vogtle Electric Generating Plant Request to Revise Technical Specifications Reactor Trip Setpoint Instrumentation 10 CFR 50.92 SIGNIFICANT HAZARDS EVALUATION AND ENVIRONMENTAL ASSESSMENT Proposed Change Southern Nuclear Operating Company (SNC) proposes to revise the Vogtle Electric Generating Plant (VEGP) Unit 1 and Unit 2 Technical Specifications (TS). The proposed amendment would modify Technical Specification (TS) Limiting Condition for Operation (LCO) 3.3.1 and Surveillance Requirements (SR) 3.2.4.2. The proposed amendment will better align the requirement to perform a flux map once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with LC0 3.2.4.

The following is a detailed description of the proposed changes.

LC0 3.3.1, "RTS Instrumentation," a Note is added to refer to LC0 3.2.4 for an Inoperable Power Range Channel. The existing Note becomes Note 1 and the new Note is Note 2.

LC0 3.3.1, "RTS Instrumentation," Required Actions D. 1.2, D.2.1 and D.2.2 are deleted. The remaining Required Actions are renumbered accordingly.

SR 3.2.4.2, "QPTR," the Note is revised to be consistent with the changes to LC0 3.3.1.

Evaluation

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

No. The proposed changes do not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, or configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes do not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed changes do not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated.

Further, the proposed changes donot increase the types or amounts of radioactive effluent that may be release offsite, nor significantly increase individual or cumulative occupational/public radiation exposures. The proposed changes are consistent with safety analysis assumptions and resultant consequences.

Therefore, the proposed changes do not increase the probability or consequences of an accident previously evaluated.

2. Do the proposed changes create the possibility of a new or different kind of accident from any previously evaluated?

Enclosure 2 Vogtle Electric Generating Plant Request to Revise Technical Specifications Reactor Trip Setpoint Instrumentation 10 CFR 50.92 SIGNIFICANT HAZARDS EVALUATION AND ENVIRONMENTAL ASSESSMENT No. The proposed changes do not result in a change in the manner in which the RTS and ESFAS provide plant protection. The RTS and ESFAS will continue to have the same setpoints after the proposed changes are implemented. There are no design changes associated with the license amendment.

The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements or eliminate any existing requirements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice.

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

3. Do the proposed changes involve a significant reduction in a margin of safety?

No. The proposed changes do not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not impacted by these changes. Redundant RTS and ESFAS trains are maintained, and diversity with regard to the signals that provide reactor trip and engineered safety features actuation is also maintained. All signals credited as primary or secondary, and all operator actions credited in the accident analyses will remain the same. The proposed changes will not result in plant operation in a configuration outside the design basis.

Therefore, the proposed changes do not involve a significant reduction in the margin of safety.

Conclusion Based on the preceding evaluation, Southern Nuclear has determined that the proposed changes meet the requirements of 10 CFR 50.92(c) and do not involve a significant hazards consideration.

Environmental Assessment Southern Nuclear has evaluated the proposed changes and determined the changes do not involve (1) a significant hazards consideration, (2) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) a significant increase in the individual or cumulative occupational exposure. Accordingly, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10 CFR 5 1.22(~)(9),and an environmental assessment of the proposed change is not required.

Enclosure 3 Vogtle Electric Generating Plant Request to Revise Technical Specifications Reactor Trip Setpoint Instrumentation Reeulatorv Safetv Analysis

Enclosure 3 Vogtle Electric Generating Plant Request to Revise Technical Specifications Reactor Trip Setpoint Instrumentation Reeulatorv Safety Analvsis Applicable Remlatorv Reauirements/Criteria The regulatory bases and guidance documents associated with the system discussed in this amendment applications included:

GDC-2 requires that structures, systems, and components important to safety be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without the loss of the capability to perform their safety functions.

GDC-4 requires that structures, systems, and components important to safety be designed to accommodate the effects of, and to be compatible with, the environmental conditions associated with the normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. These structures, systems, and components shall be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, discharging fluids that may result from equipment failures, and from events and conditions outside the nuclear power unit. However, dynamic effects associated with postulated pipe ruptures in nuclear power units may be excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that the probability of fluid system piping rupture is extremely low under conditions consistent with the design basis for the piping.

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 testability.

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.

Enclosure 3 Vogtle Electric Generating Plant Request to Revise Technical Specifications Reactor Trip Setpoint Instrumentation Reeulatory Safety Analysis 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 4.2 of IEEE 279-1971 discusses the general functional requirement for protection systems to asswe they satisfy the single failure criterion.

There will be no changes to the RTS instrumentation design such that compliance with any of the regulatory requirements and guidance documents above would come into question. The above evaluations confirm that the plant will continue to comply with all applicable regulatory requirements.

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

Enclosure 4 Vogtle Electric Generating Plant Request to Revise Technical Specifications Reactor Trip Setpoint Instrumentation Marked-up TS and Bases Pages

QPTR 3.2.4 SURVEILLANCE REQUlREMENTS SR 3.2.4.1 ........................... NOTE..............................

With one power range channel inoperable, the remaining three power rarlge channels can be used for calculating QPTR.

Verify QPTR is within limit by calculation. 7 days AND Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter with the QPTR alarm inoperable performed if in[

- I . . II I R one or I

~ P T from

................................................................. I more Power Range Confirm that the normalized symmetric power Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Neutron Flux distribution is consistent with QPTR.

channels is inoperable with -

AND THERMAL POWER 2 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter 750h RTP.

Vogtle Units 1 and 2 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

RTS Instrumentation 3.3.1 ACTIONS (continued) I CONDITION COMPLE-I-IONTIME I

1.

f I

- A channel may be bypassed for up I channel inoperable. to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing and setpoint adjustment.

I ' /

D.18 Place channel in trip. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> I I

2. Refer to LC0 3.2.4 for an inoperable power range . .-

0 EaiEEl channel.

. Be in MODE 3. I I 1 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> I (continued)

Vogtle Units 1 and 2 Amendment No. 116 (Unit 1)

Amendment No. 94 (Unit 2)

QPTR B 3.2.4 BASES SURVEILLANCE SR 3.2.4.1 (continued)

REQUIREMENTS This Surveillance verifies that the QPTR, as indicated by the Nuclear Instrumentation System (NIS) excore channels, is within its limits.

The Frequency of 7 days when the QPTR alarm is OPERABLE is acceptable because of the low probability that this alarm can remain inoperable without detection. Valid inputs to the detector current comparator from the upper and lower sections from 3 or 4 power range channels are required for the QPTR alarm to be OPERABLE.

When the QPTR alarm is inoperable, the Frequency is increased to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This Frequency is adequate to detect any relatively slow changes in QPTR, because for those causes of QPTR that occur the surveillance is only required to be performed if input to QPTR from one or more Power Range Neutron Flux channels is SR 3.2.4.2 inoperable with This Surveillance is modified by a . . THERMAL POWER k 175% RTP.

With an NIS power range channel inoperable, tilt monitoring for a portion of the reactor core becomes degraded. Large tilts are likely detected with the remaining channels, but the capability for detection of small power tilts in some quadrants is decreased. Performing SR 3.2.4.2 at a Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provides an acceptable means for confirming the accuracy of the QPTR measurement via the excore detectors.

When one power range channel is inoperable, the incore detectors are used to confirm that the normalized symmetric power distribution is consistent with the indicated QPTR. The incore detector monitoring is performed with a full incore flux map or two sets of four thimble locations with quarter core symmetry. The two sets of four symmetric thimbles is a set of eight unique detector locations. These locations are C-8, E-5, E-11, H-3, H-13, L-5, L-11, and N-8.

(continued)

Vogtle Units 1 and 2 B 3.2.4-7 Revision No. 0

RTS Instrumentation B 3.3.1 BASES ACTIONS C.l and C.2 (continued)

Manual Reactor Trip; RTB Undervoltage and Shunt Trip Mechanisms; and Automatic Trip Logic.

This action addresses the train orientation of the SSPS for these Functions. With one channel or train inoperable, the inoperable channel or train must be restored to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. If the affected Function(s) cannot be restored to OPERABLE status within the allowed 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Completion Time, the unit must be placed in a MODE in which the requirement does not apply. To achieve this status, the RTBs must be opened within the next hour. The additional hour provides sufficient time to accomplish the action in an orderly manner. With the RTBs open, these Functions are no longer required. This Condition is modified by a Note that prohibits closing the RTBs in MODE 5 if any of the above Functions (Function 1, 17, 18, or 19 of Table 3.3.1-1) are not met. Closing the RTBs in MODES 3 or 4 with any of these Functions not met is prohibited by LC0 3.0.4.

The Completion Time is reasonable considering that in this Condition, the remaining OPERABLE channel or train is adequate to perform the safety function, and given the low probability of an I

event occurring during this interval.

D.lI.?, E.?.2?A&&ES4, and D.4 4

a Condition D applies to the Power Range Neutron Flux- High Function. This Condition contains bypass times and Completion Times that are risk-informed. The Configuration Risk Management Program (CRMP) is used to assess changes in core damage frequency resulting from applicable plant configurations.

The CRMP uses the equipment out of service risk monitor, a computer based tool that may be used to aid in the risk assessment of on-line maintenance and to evaluate the change in risk from a component failure. The equipment out of service risk monitor uses the plant probabilistic risk assessment model to evaluate the risk of removirrg equipment from service based on current plant configuration and equipment condition.

(continued)

Vogtle Units 1 and 2 B 3.3.1 -42 Rev. 2-1101

BASES

-2 RTS Instrumentation B 3.3.1 Ic ACTIONS D.I.!, D.! 2,5.2.1, &&21 and D.U (continued)

The NIS power range detectors provide input to the CRD System and the SG Water Level Control System and, therefore, have a two-out-of-four trip logic. A known inoperable channel must be placed in the tripped condition. This results in a partial trip condition requiring only one-out-of-three logic for actuation. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the inoperable channel in the tripped v k n d i t i o n is justified in WCAP-14333-P-A (Ref. 12).

If the Required ~ctionmD.l -annot be met within the specified Completion Times, the unit must be placed in a MODE where this Function is no longer required OPERABLE.

An additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> beyond the Completion Time for Required Action D.1. .. is allowed to place the unit in l i e time, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging unit systems. Cf (continued)

Vogtle Units 1 and 2 B 3.3.1 -43 Rev. 1-1/01

INSERT A The Required Actions have been modified by two Notes. Note 1 allows a channel to be placed in the bypassed condition for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing. With one channel inoperable, the Note also allows routine surveillance testing of another channel with a channel in bypass. The Note also allows placing a channel in the bypass condition to allow setpoint adjustments when required to reduce the Power Range Neutron Flux-High setpoint in accordance with other Technical Specifications. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 12.

Note 2 refers the user to LC0 3.2.4 for additional requirements that may apply for an inoperable power range channel.

RTS Instrumentation B 3.3.1 2

BASES ACTIONS D.IC.!, D.! .2, E.2.1. 2.2.21,and D . u (continued)

E.l and E.2 Condition E applies to the following reactor trip Functions:

Power Range Neutron Flux- Low; Overtemperature AT; Overpower AT; Power Range Neutron Flux - High Positive Rate; Pressurizer Pressure-High; and SG Water Level -Low Low.

This Condition contains bypass times and Completion Times that are risk-informed. The Configuration Risk Management Program (CRMP) is used to assess changes in core damage frequency resulting 'from applicable plant configurations. The CRMP uses the equipment out of service risk monitor, a computer based tool that may be used to aid in the risk assessment of on-line maintenance and to evaluate the change in risk from a component failure. The equipment out of service risk monitor uses the plant probabilistic risk assessment model to evaluate the risk of removing equipment from service based on current plant configuration and equipment condition.

(continued)

Vogtle Units 1 and 2 B 3.3.1-44 Rev. 1-1/01

Enclosure 5 Vogtle Electric Generating Plant Request to Revise Technical Specifications Reactor Trip Setpoint Instrumentation Clean-tv~edTS and Bases P a ~ e s

QPTR 3.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.4.1 ........................... NOTE..............................

With one power range channel inoperable, the remaining three power range channels can be used for calculating QPTR.

Verify QPTR is within limit by calculation. 7 days Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter with the QPTR alarm inoperable SR 3.2.4.2 ............................ NOTE.............................

Only required to be performed if input to QPTR from one or more Power Range Neutron Flux channels is inoperable with THERMAL POWER 2 75% RTP.

Confirm that the normalized symmetric power Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> distribution is consistent with QPTR.

AND 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter Vogtle Units 1 and 2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQLllRED ACTION COMPLETION TIME D. One Power Range ..................... NOTES-----------------

Neutron Flux- High 1. A channel may be bypassed channel inoperable. for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing and setpoint adjustment.

2. Refer to LC0 3.2.4 for an inoperable power range channel.

D.l Place channel in trip. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> I OR I D.2 Be in MODE 3. 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> (continued)

I Vogtle Units 1 and 2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

QPTR B 3.2.4 BASES SURVEILLANCE SR 3.2.4.1 (continued)

REQUIREMENTS This Surveillance verifies that the QPTR, as indicated by the Nuclear Instrumentation System (NIS) excore channels, is within its limits.

The Frequency of 7 days when the QPTR alarm is OPERABLE is acceptable because of the low probability that this alarm can remain inoperable without detection. Valid inputs to the detector current comparator from the upper and lower sections from 3 or 4 power range channels are required for the QPTR alarm to be OPERABLE.

When the QPTR alarm is inoperable, the Frequency is increased to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This Frequency is adequate to detect any relatively slow changes in QPTR, because for those causes of QPTR that occur quickly (e.g., a dropped rod), there typically are other indications of abnormality that prompt a verification of core power tilt.

This Surveillance is modified by a Note, which states that the surveillance is only required to be performed if input to QPTR from one or more Power Range Neutron Flux channels is inoperable with THERMAL POWER 275% RrP.

With an NIS power range channel inoperable, tilt monitoring for a portion of the reactor core becomes degraded. Large tilts are likely detected with the remaining channels, but the capability for detection of small power tilts in some quadrants is decreased. Performing SR 3.2.4.2 at a Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provides an acceptable means for confirming the accuracy of the QPTR measurement via the excore detectors.

When one power range channel is inoperable, the incore detectors are used to confirm that the normalized symmetric power distribution is consistent with the indicated QPTR. The incore detector monitoring is performed with a full incore flux map or two sets of four thimble locations with quarter core symmetry. The two sets of four symmetric thimbles is a set of eight unique detector locations. These locations are C-8, E-5, E-11, H-3, H-13, L-5, L-11, and N-8.

(continued)

Vogtle Units 1 and 2 B 3.2.4-7

RTS Instrumentation B 3.3.1 BASES ACTIONS C.l and C.2 (continued)

Manual Reactor Trip; RTBs; RTB Undervoltage and Shunt Trip Mechanisms; and Automatic Trip Logic.

This action addresses the train orientation of the SSPS for these Functions. With one channel or train inoperable, the inoperable channel or train must be restored to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. If the affected Function(s) cannot be restored to OPERABLE status within the allowed 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Completion Time, the unit must be placed in a MODE in which the requirement does not apply. To achieve this status, the RTBs must be opened within the next hour. The additional hour provides sufficient time to accomplish the action in an orderly manner. With the RTBs open, these Functions are no longer required. This Condition is modified by a Note that prohibits closing the RTBs in MODE 5 if any of the above Functions (Function 1, 17, 18, or 19 of Table 3.3.1-1) are not met. Closing the RTBs in MODES 3 or 4 with any of these Functions not met is prohibited by LC0 3.0.4.

The Completion Time is reasonable considering that in this Condition, the remaining OPERABLE channel or train is adequate to perform the safety function, and given the low probability of an event occurring during this interval.

D.l and D.2 Condition D applies to the Power Range Neutron Flux- High Function. This Condition contains bypass times and Completion Times that are risk-informed. The Configuration Risk Management Program (CRMP) is used to assess changes in core damage frequency resulting from applicable plant configurations.

The CRMP uses the equipment out of service risk monitor, a computer based tool that may be used to aid in the risk assessment of on-line maintenance and to evaluate the change in risk from a component failure. The equipment out of service risk monitor uses the plant probabilistic risk assessment model to evaluate the risk of removing equipment from service based on current plant configuration and equipment condition.

(continued)

Vogtle Units 1 and 2 B 3.3.1-42

RTS Instrumentation B 3.3.1 BASES ACTIONS D.l and D.2 (continued) I The NIS power range detectors provide input to the CRD System and the SG Water Level Control System and, therefore, have a two-out-of-fourtrip logic. A known inoperable channel must be placed in the tripped condition. This results in a partial trip condition requiring only one-out-of-three logic for actuation. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the inoperable channel in the tripped condition is justified in WCAP-14333-P-A (Ref. 12).

The Required Actions have been modified by two Notes. Note 1 allows a channel to be placed in the bypassed condition for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing. With one channel inoperable, the Note also allows routine surveillance testing of another channel with a channel in bypass.

The Note also allows placing a channel in the bypass condition to allow setpoint adjustments when required to reduce the Power Range Neutron Flux-High setpoint in accordance with other Technical Specifications. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 12.

Note 2 refers the user to LOC 3.2.4 for additional requirements that may apply for an inoperable power range channel.

If Required Action D.l cannot be met within the specified Completion Time, the unit must be placed in a MODE where this Function is no longer required OPERABLE. An additional 6 I

hours beyond the Completion Time for Required Action D.l is I allowed to place the unit in MODE 3. Six hours is a reasonable time, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging unit systems. I (continued)

Vogtle Units 1 and 2 B 3.3.1-43

RTS Instrumentation B 3.3.1 BASES ACTIONS E.l and E.2 I (continued)

Condition E applies to the following reactor trip Functions:

Power Range Neutron Flux- Low; Overtemperature AT; Overpower AT; Power Range Neutron Flux - High Positive Rate; Pressurizer Pressure-High; and SG Water Level -Low Low.

This Condition contains bypass times and Completion Times that are risk-informed. The Configuration Risk Management Program (CRMP) is used to assess changes in core damage frequency resulting from applicable plant configurations. The CRMP uses the equipment out of service risk monitor, a computer based tool that may be used to aid in the risk assessment of on-line maintenance and to evaluate the change in risk from a component failure. The equipment out of service risk monitor uses the plant probabilistic risk assessment model to evaluate the risk of removing equipment from service based on current plant configuration and equipment condition.

(continued)

Vogtle Units 1 and 2 B 3.3.1 -44

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