Text

License Amendment Request - LAR 05-0677 On-Line Monitoring of Instrument Channel Performance
	ML060400220
Person / Time
Site:	Summer
Issue date:	02/06/2006
From:	Archie J; South Carolina Electric & Gas Co
To:	Martin R; Document Control Desk, Office of Nuclear Reactor Regulation
References
	LAR-05-0677, RC-06-0024
	Download: ML060400220 (74)
	v • d • e

Jeffrey Archie Vice President, Nuclear Operations 803.345.4214 February 6, 2006 RC-06-0024 A SCANA COMPANY Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTN: Mr. Robert E. Martin

Dear Sir / Madam:

Subject:

VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12

/

LICENSE AMENDMENT REQUE;T -I 05-0677 ON-LINE MONITORING OF INSTRU ENT CHANNEL PERFORMANCE Pursuant to 10 CFR 50.90, South Carolina Electric & Gas Company (SCE&G), acting for itself and as agent for South Carolina Public Service Authority, hereby requests an amendment to the Virgil C. Summer Nuclear Station (VCSNS) Technical Specifications (TS).

The proposed amendment will revise the Technical Specifications to incorporate changes to the TS to utilize the guidance from the Electric Power Research Institute's (EPRI) Technical Report TR-104965, for implementation of en On-Line Monitoring (OLM) System.

The changes involve the addition of a definition for on-line monitoring, changes to Tables 4.3-1, 4.3-2, 4.3-5, and 4.3-6 and Surveillance Requirements 4.3.3.4, 4.3.3.5, and 4.3.3.6.

The actual changes are to the channel calibration column of these tables with the addition of a note for those channels evaluated by the OLM System. The associated Bases sections are also provided for information. Additionally, several administrative changes are included that modify the identified tables as well as Table 3.3-3.

The VCSNS Final Safety Analysis Report has been reviewed and required revisions to Section 7.1 will occur after implementation of this LAR.

Another License Amendment Request (UkR), LAR 05-2926 - Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, affecting one or more of the pages in this LAR has been submitted on November 5, 2005. Revised pages will be resubmitted should the other LAR be approved first.

The proposed amendment has been reviewed by the VCSNS review committees. SCE&G has notified the State of South Carolina in accordance with 10 CFR 50.92(b).

SCE&G requests approval of the proposed amendment by January 31, 2007, with a 60-day implementation period to permit plant program changes and training.

A4-oo SCE&G I Virgil C. Summer Nuclear Station

P. 0. Box 88. Jenkinsville, South Carolina 29065

T (803) 345.5209. www.scano.om

Document Control Desk LAR 05-0677 RC-06-0024 Page 2 of 2 I certify under penalty of perjury that the foregoing is true and correct.

G Executed on effrey Arc PR/JBA/dr

Enclosures:

Evaluation of the proposed change Attachment(s): 5

1. Proposed Technical Specification Change - Mark-up

2. Proposed Technical Specification Change - Retyped

3. List of Regulatory Commitments

4. EPRI Technical Report 1003361, On-Line Monitoring of Instrument Channel Performance, Volume 1: Guidelines< for Model Development and Implementation Non-Proprietary Version

5. EPRI Technical Report 1007930, On-Line Monitoring of Instrument Channel Performance, Volume 3: Applications to Nuclear Power Plant Technical Specification Instrumentation Non-Proprietary Version c:

N. 0. Lorick S. A. Byrne N. S. Carns T. Eppink (w/o Attachments)

R. J. White W. D. Travers R. E. Martin NRC Resident Inspector P. Ledbetter K. M. Sutton T. P. O'Kelley RTS (LAR 05-0677)

File (813.20)

DMS (RC-05-0024)

Document Control Desk Enclosure I LAR 05-0677 RC-06-0024 Page 1 of 11

Subject:

LICENSE AMENDMENT REQUEST - LAR 05-0677 On-Line Monitoring of Instrument Channel Performance

1.0 DESCRIPTION

South Carolina Electric & Gas Company (SCE&G) proposes an amendment to the Virgil C.

Summer Nuclear Station (VCSNS) Technical Specifications (TS) to revise TS 3/4.3, Instrumentation, and the associated Bases.

The proposed amendment directly affects the calibration frequency of the selected instrument channels. Application of this program will require an additional surveillance for each of the transmitters included in the program. This additional verification of channel performance will allow extension of the channel calibration from its current "every refueling cycle" up to "once every 6 years". This extension is based on the number of instrument channels for the specific parameter on a staggered test basis, with no instrument allowed to exceed six years between channel calibrations. At least one of the redundant instruments will have a channel calibration performed each refueling outage. The basis for the channel calibration extension is the use of on-line monitoring to verify the performance of the instrument periodically during plant operation. The On-Line Monitoring (OLM) System consists of qualified software operating on existing plant computerware.

Additionally, several administrative changes to Tables 3.3-3 and 4.3-1 are being made to correct typographical items.

2.0 PROPOSED CHANGE

Specifically, the proposed changes would revise the following:

2.1 TS 1.18, Adding the definition of on-line monitoring (new) 2.2 Table 3.3-3, Engineered Safety Feature Actuation System Instrumentation 2.3 Table 4.3-1, Reactor Trip System Instrumentation Surveillance Requirements 2.4 Table 4.3-2, Engineered Safety Feature Actuation System Instrumentation Surveillance Requirements 2.5 Surveillance Requirement 4.3.3.4 and Table 4.3-5, Meteorological Monitoring Instrumentation Surveillance Requirements 2.6 Surveillance Requirement 4.3.3.5 and Table 4.3-6, Remote Shutdown Monitoring Instrumentation Surveillance Requirements 2.7 Surveillance Requirement 4.3.3.6, Accident Monitoring Instrumentation

Document Control Desk Enclosure I LAR 05-0677 RC-06-0024 Page 2 of 11 The Functional Units/Channels being included in the on-line monitoring program are the following:

Reactor Building Narrow Range Pressure Pressurizer Pressure Pressurizer Level Reactor Coolant System Flow Steam Generator Narrow Range Level Steam Generator Pressure Feedwater Flow Steam Flow Turbine Impulse Pressure Meteorological Tower Wind Speed Meteorological Tower Wind Direction Meteorological Tower Delta Temperature The majority of these Functional Units are within the scope of the approved Technical Report (TR). Those Functional Units that are not within the scope are the Reactor Building Pressure and the Meteorological Tower Instrumentaltion. Justification for the inclusion of the Reactor Building Pressure (Narrow Range) Functional Units into the LAR is based on the fact that the Narrow Range Instrument is scaled from negative 5 psig to positive 15 psig.

Normal operational readings are close to 0 psig and are at approximately 25 percent of span. This is the instrumentation that performs the safety function and is an Engineered Safeguard Feature of the plant as is most of the other instrumentation included in this submittal.

The other addition is the Meteorological Tower instrumentation. This instrumentation is not Engineered Safety Feature Actuation System equipment and is used to provide information such that recommendations for protective actions can be made after a design basis accident (DBA). The justification for the inclusion into this submittal is that the methodology provided in the TR is directly applicable to this instrumentation.

Multiple instrument channels of this instrumentation are available for comparison by the OLM System using the process parameter estimate or redundant channels.

The instrumentation has a higher level of stability, repeatability, and reliability than the instrumentation originally used for meteorological data collection. The original wind speed/direction instrumentation was electromechanical, while the new instrumentation is of digital electronic design. The environment is generally mild and the equipment has been designed for most extremes in temperature, humidity/precipitation and wind expected on site.

Calibration for the meteorological instrumentation circuitry normally involves verification that a specified output is received for a specified input. The vendor recommends periodic testing

Document Control Desk Enclosure I LAR 05-0677 RC-06-0024 Page 3 of 11 (calibration verification) of the instrumentation but does not establish the frequency.

The current calibration frequency was established based on instrumentation available during plant licensing (electromechanical) and the vendor recommended frequencies. Therefore, SCE&G proposes to adopt the on-line monitoring methodology and program requirements for the Meteorological Tower instrumentation with the following exception, there will be 7 temperature instruments, 4 differential temperature measurements, and 4 wind speed/direction instruments and all comparisons will be between the redundant instrumentation.

All meteorological instrumentation will be calibrated at least every 36 months.

3.0 BACKGROUND

On-line monitoring evaluates instrument channel performance by assessing its consistency with other plant indications compared to pre-established acceptance criteria. Industry and Electric Power Research Institute (EPRI) experience at several plants has shown this overall approach to be very successful in identifying instrument channels that are exhibiting degrading or inconsistent performance characteristics.

Current calibration processes use intrusive monitoring techniques to periodically determine the as-found performance characteristics, whereas on-line monitoring employs non-intrusive techniques to determine instrument channel performance on a much more frequent basis. On-line monitoring of instrument channels provides information about the condition of the monitored channels through accurate, more frequent monitoring of each channel's performance over time. This type of performance monitoring is a methodology that offers an alternative approach superior to traditional time-directed calibration. On-line monitoring of these channels can provide an assessment of instrument performance and provide a basis for determining when adjustments are necessary. Elimination or reduction of unnecessary field calibrations can reduce personnel radiation exposures and reduce the potential for mis-calibration, handling damage or leaks.

This methodology is described in EPRI Technical Report TR-104965, and was approved for use provided specific requirements are satisfied. The NRC Safety Evaluation for this TR is dated July 24, 2000 (TAC NO. M93653; ADAMS Accession Number ML003734509).

Additionally, several administrative changes are being made to correct a typographical mistake from initial issue of the TS and to remove reference to a note that was deleted by Amendment 101. Table 3.3-3, Functional Unit 1.f, Channels to Trip states "1 pressure and 2 loops". These words have been present since the initial issue of the VCSNS TS. This has been determined to be a typographical error and should state "1 pressure any 2 loops". This is consistent with other Functional Units, specifically 4.e.

Document Control Desk Enclosure I LAR 05-0677 RC-06-0024 Page 4 of 11

4.0 ASSESSMENT

4.1 Technical Basis This extension of surveillance frequencies for specific plant instrumentation is based on the principle that evaluating the performance on a more frequent basis and comparing the results against pre-established acceptance criteria provides better confidence of operability than performing invasive checking and testing once every 18 months.

On-line monitoring of instrument channels is possible and practical owing to the ease with which data acquisition and analysis of instrument channel data can be performed using modern computers in combination with mathematical modeling techniques.

In essence, on-line monitoring provides a proactive and beneficial approach to performing periodic instrument surveillance; it accomplishes the surveillance or monitoring aspect of calibration by inter-comparison between redundant or correlated instrument channels and with independent estimates of the plant parameter of interest. It does not replace the process of instrument adjustments; it provides a performance basis for determining when instrument adjustment is necessary.

On-line monitoring acquires its data from the plant computer.

The issues raised by NRC Information Notice 95-13, Potential for Data' Collection Equipment to Affect Protection System Performance, have been considered in assuring that the data acquisition isolation and independence is maintained. At VCSNS, data for the OLM System will be obtained from the plant computer, and the results analyzed and assessed on a quarterly interval. The quarterly analysis frequency is deemed acceptable based on the daily channel checks to identify any gross changes in channel performance, engineering experience, and is consistent with the Maintenance Rule evaluation frequency.

On-line monitoring will be used to determine if field calibration of specific instrumentation is required and, because of its ability to identify degraded channels, can initiate the operability assessment process. Although the OLM System software is not safety-related, it will require formal evaluation in accordance with plant software acceptance procedures.

The actual process involved in the analysis consists of an evaluation of the deviation of the instrument data with reference to its process parameter estimate. The process parameter estimate is a calculated value that is the instantaneous expected value of the process variable at the monitored operating point. The acceptable limits of deviation are pre-established ranges around the process parameter estimate that will be used to validate performance and initiate adjustment, corrective action and/or an operability determination.

When a plant operates at nearly constant power for an extended period of time, the process variations for many parameters tend to be relatively small. As such, there is a concern with single-point monitoring (determining from a single point on the calibration curve whether the channel is still calibrated elsewhere in the span). EPRI TR-104965, Revision 1, discusses the various types of drift and concludes that it !is unlikely that one or more calibration checkpoints

Document Control Desk Enclosure I LAR 05-0677 RC-06-0024 Page 5 of 11 would be significantly out of calibration when the monitored point was within calibration. To remain conservative, a statistically determined allowance is used to account for the calibration uncertainty at points away from the monitored point.

Processes that are essentially always at the high end or low end of their span may not be suitable for on-line monitoring due to the possibility of undetected span shift when monitoring only a single-point (e.g., RWST water level). Also, on-line monitoring will not be utilized for process variables that are normally off (e.g., Engineered Safety Feature Actuation System, Emergency Feedwater). In these cases, the statistically determined allowance would likely be so large as to eliminate the possible utility of on-line monitoring.

The Meteorological Tower instrumentation was not included in the analysis performed for EPRI during the development of EPRI TR-1049'35, Revision 1, since it is not considered safety-related instrumentation required to mitigate the effects of an accident. However, this TR and the associated methodology are being considered applicable to the Meteorological Tower instrumentation as multiple redundant instrument channels are available for comparison.

Environmental parameters monitored by the meteorological instrumentation are not expected to change quickly enough to create conditions that would cause any of the instrumentation to incorrectly indicate failure or excessive drift.

On-line monitoring is proposed as a method to extend calibration frequency; it is not proposed as an unconditional replacement for field calibrations.

Therefore, periodic calibrations will continue to validate sensor performance and will also identify any unusual common mode sensor failures.

4.2 Safety Evaluation Periodic calibration of instrument channels is required to help ensure safe, efficient, and economical operation of nuclear plants. Many calibrations are required to be performed at a frequency prescribed in the plants Technical Specifications (TS) to provide assurance that the instruments are performing within their specified limits and will detect and react to plant parameter changes within the time limits assumed in the safety analyses. These channels include the instrumentation of the Reactor Trip System, Engineered Safety Feature Actuation System, and Remote Shutdown Monitoring System. Accident monitoring instrumentation and meteorological instrumentation do not directly perform reactor protection or accident mitigation functions and as such do not directly affect the safety analysis.

Although conducting calibrations at a prescribed frequency, irrespective of instrument performance, satisfies TS requirements, this type of calibration approach does not make optimum use of the data collection and analysis capabilities currently available to assess channel performance prior to calibration.

Furthermore, time-directed calibration contributes to increased plant operational costs through increased maintenance labor, the potential impact on instrument availability, increased radiation exposure, and increased potential for damage to equipment, leaks or mis-calibration events.

Performance-based regulations, such as the Maintenance Rule, have helped establish the precedence of using performance monitoring as a basis for satisfying regulatory requirements.

Document Control Desk Enclosure I LAR 05-0677 RC-06-0024 Page 6 of 11 Performance monitoring is defined as the quantitative assessment of the degree to which a component is fulfilling its required function. Accurate, periodic performance monitoring has the potential to increase safety.

Current calibration processes use intrusive techniques to periodically determine the as-found performance characteristics, adjust the instrument back into the acceptance range if needed, and use the same techniques to determine the as-left performance characteristics.

Alternatively, on-line monitoring utilizes non-intrusive techniques to determine channel performance on a more frequent basis. The on-line monitoring process involves obtaining real-time instrument channel performance data and using on-line monitoring techniques to verify that the monitored instruments performance characteristics are within acceptable limits. On-line monitoring can provide a more detailed assessment of performance and can provide a basis for determining when a field calibration will be necessary. This proactive technique will permit detection of and correction of channel degradation well before other techniques can, allowing for scheduling adjustment or corrective action for a more optimal time.

Specific instrument channels were determined during the NRC approval of EPRI TR-104965, Revision 1, to not be suitable for inclusion into the population of instrumentation that will receive on-line monitoring.

One example is instrumentation that is always at one extreme of the instrument span. In the EPRI TR, the Reactor Building Pressure indication is not considered suitable for on-line monitoring for this reason. However, VCSNS utilizes narrow range pressure transmitters as the protection channels for Reactor Building pressure. These narrow range instruments are set such that at normal operating conditions, the indication is approximately 25 percent of span. This value is sufficiently far enough from the extreme low or high end of the instruments calibrated span that it is suitable for on-line monitoring. In addition, the operating or monitored point is approximately 15% of span from the initial setpoint for Reactor Building pressure.

At least one redundant channel will receive a field calibration at least once per 18 months with no instrument going longer than 6 years between calibrations. This maximum frequency is less than the maximum frequency stated in EPRI TR-104965, Revision 1, as the TR was written for a generic application which could, depending on refueling cycle length and number of redundant Instruments, justify a maximum frequency of 8 years between channel calibrations for a specific instrument.

The field calibration will improve the average time any group of instruments are traceable back to national calibration standards. Should a monitored channel be evaluated as needing calibration during the scheduled maintenance period, the affected channel will be calibrated in addition to the scheduled redundant instrument channel.

The OLM System will not be connected to plant instrumentation. The data collection for the OLM System will be extracted and stored daily from existing data files on the plant computer. A formal surveillance will be conducted quarterly to evaluate instrument channel performance against pre-established limits. The analysis of the data will be performed off line. As a minimum, the results will be evaluated by the plant technical staff quarterly to assure the instrument channels are performing satisfactorily. In this mode of operation, the OLM System will be used as a performance assessment tool to monitor calibration and verify the operational status of specific safety-related and quality-related instrument channels.

Document Control Desk Enclosure I LAR 05-0677 RC-06-0024 Page 7 of 11 The Meteorological Tower instrumentation was not included in the analysis performed for EPRI during the development of TR-104965, Revision 1, since it is not considered as instrumentation that is required to mitigate the effects of an accident. However, this TR and the associated methodology are considered applicable to the Meteorological Tower instrumentation as multiple instrument channels at VCSNS are available for comparison.

Environmental parameters monitored by the meteorological instrumentation are not postulated to change quickly enough between instruments to create conditions that would cause any of the redundant instrumentation to incorrectly indicate failure or excessive drift.

On-line monitoring techniques are capable of providing parameter estimates for virtually any set of redundant or well correlated signals, including Meteorological Tower instrumentation signals.

The wind speed/direction instrumentation utilizes ultrasonic signals and digital processing that measure the time for the signals to travel from transmitters to receivers. The sensors accuracy depends only on two factors: the distance between the transmitter and receiver and the time-of-flight measurement circuit. The measurement between the transmitter and receiver is verified during calibration and verifies the transmitter arm trueness. The time-of-flight circuit uses a crystal oscillator for time reference and as the bit rate generator in the communication circuit.

Any degradation of the oscillator accuracy will stop the device from communicating and will be detected as channel failure. The temperature measurements are standard resistance temperature devices that are fed directly into analog to digital converters and then all signals are processed on a digital platform. The data is then stored on the plant computer historical files for extraction and processing by the OLM program. Due to the high degree of redundancy in the measurements and the digital format., these instruments are qualified for the application of on-line monitoring.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Determination In accordance with the criteria set forth in 10 CFR 50.92, SCE&G has evaluated these proposed Technical Specification changes and determined they do not represent a significant hazards consideration. The following is provided to support this conclusion.

1.

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

The proposed change will permit extension of the TS required 18 month calibration interval for specific instrumentation based on the use of a quarterly calibration evaluation using the OLM System.

The OLM System consists of qualified software operating on existing plant computerware. This system will not be directly connected to the instrument loops. The data will be gathered from an existing computerized database that is connected through the plant computer to the instrument loops via isolator circuits. The instrumentation will be operable at the time of the data collection and the plant will be in a stable condition to allow for parameter stabilization. *This system will detect very small changes in the

Document Control Desk Enclosure I LAR 05-0677 RC-06-0024 Page 8 of 11 performance level of monitored instrument channels. Significant changes can also be detected with the daily channel checks required by TS.

The OLM System will be utilized as a tool for performance verification and is capable of determining small changes in instrument performance. Most of the instrumentation subject to this calibration extension is used to detect and initiate mitigation for abnormal and accident conditions, and any failure mode is already bounded by current accident analysis. A maximum time between calibrations will be established with at least one instrument loop per monitored parameter being calibrated once every 18 months. The recently calibrated channel will also be used as a reference to verifly the absence of any postulated common mode failures and the relative performance of the redundant channels being monitored.

A more frequent evaluation of channel performance is not an accident precursor and will not affect the consequences of any accident. One of the significant effects that contribute to instrument calibration is drift and minute amounts of drift are detectable with this system. Acceptance criteria for instrument error will be established that will determine the level of attention required, from more frequent monitoring of the channel to scheduling a channel calibration at the next available opportunity. Significant channel degradation will be detected during the daily channel checks performed via comparison to the redundant instrument channels. The extension of Calibration frequency has no adverse affect on the probability or consequences of an accident since a more frequent calibration assessment of instrument channel performance will be performed. A more sensitive and frequent determination of instrument performance and operability using on-line monitoring may in fact reduce the probability of an accident precursor event.

2.

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

The proposed change has no impact on the operation of the plant or changes to plant configuration. Quarterly performance evaluations of the instrumentation monitored by the OLM System will be conducted using normal plant computer data collection techniques and hardware to collect the raw data, using isolation circuits, and the comparisons/analysis will be conducted off line. All limiting values of drift or malfunction are bounded by the proposed monitoring process and/or current TS required surveillances.

Channel calibrations will still be conducted at a reduced frequency to provide additional assurance of the operability of the channel. Failure modes for the safety-related instrumentation have been evaluated during initial plant licensing for impacts on the safety analysis. Therefore, there is no possibility of this change creating a new or different kind of accident from any previously evaluated.

3.

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

Document Control Desk Enclosure I LAR 05-0677 RC-06-0024 Page 9 of 11 Revising the calibration frequency while establishing on-line monitoring to provide a more frequent performance evaluation will provide a greater level of confidence in the performance level of the instrument loops being monitored.

The accuracy of the system and the uncertainties inherent in this type of application are compensated for in the acceptance criteria derived from the setpoint calculations, and in the calculation for the allowable limits. Therefore, there is no significant reduction in any margin of safety.

5.2 Applicable Regulatory Requirements/Criteria 10 CFR 50 Appendix A, Criterion 20, Protection System Functions The protection system "shall be designed to (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) sense accidents and initiate the operation of systems and components important to safety."

The OLM System will support this requirement by providing for more frequent performance monitoring of selected instrumentation; thereby assuring that any instrument channel degradation will be discovered prior to the scheduled calibration. The channel performance can be trended with adjustment scheduled and performed before operability becomes an issue.

This assures that Appendix A Criterion 20 remains satisfied.

10 CFR 50 Appendix A, Criterion 21, Protection System Reliability and Testability "The protection system shall be designed to permit periodic testing of its functioning when the reactor is in operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred."

The use of the OLM System will provide a more frequent critical assessment of the status of the instrument channels being monitored. This assessment will occur during plant operation and is non-intrusive such that the monitoring cannot create a condition where the channel would be unable to perform its design function. Separate acceptance limit calculations that are derived from the existing instrument setpoint calculations will be performed for each channel to maintain independence.

Document Control Desk Enclosure I LAR 05-0677 RC-06-0024 Page 10 of 11 10 CFR 50 Appendix A, Criterion 23, Protection System Failure Modes The protection system must fail in the safe state if conditions such as loss of power or postulated adverse environments are experienced.

The OLM System does not interact with the instrument channels being monitored. An isolator circuit is used to maintain the required independence and redundancy between the instrument loop and the plant computer. Any plausible failure of the channel being monitored is accounted for or bounded by existing accident analysis; therefore, a failure of the data collection equipment has no impact on the operability of the monitored instrument channels. Once the data is collected, the OLM System perfornis the instrumentation channel analysis off line, followed by a documented quarterly review.

10 CFR 50 Appendix B, Criterion XII, Control of Measuring and Test Equipment Measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.

The OLM System is not intended to be measuring or test equipment.

The OLM System provides analysis of instrument performance such that the calibration of the monitored instruments maintains the required accuracy by performing more frequent performance verifications. The instrument monitoring process establishes internal accuracies through application of acceptable numerical analysis methods. The identified uncertainties are then controlled through approved plant procedures and integrated into the acceptance criteria in the setpoint analysis for each instrument. This process can detect small changes in the performance level of the instrumentation and be used to establish adverse trends.

All necessary adjustments will be performed using established plant measuring and test equipment that is traceable to NIST standards. At least one of each redundant instrument channel will be calibrated every 18 months and each channel will be calibrated at least once every 6 years.

Regulatory Guide 1.22, Periodic Testing of Protection System Actuation Functions Regulatory Guide 1.22 implements the requirements of 10 CFR 50 Appendix A, Criteria 20 and 21, although this Regulatory Guide is mostly applicable for the design phase of building a nuclear power plant.

The OLM System will provide an assessment of the health of the monitored instrumentation while at power.

The plant parameters should be essentially unchanging during the period the monitored values will be compared to a calculated parameter estimate to determine any trends in the amount of deviation. This assessment is performed quarterly and is in addition to the daily channel checks that will detect significant degradation or failure. The proposed change does not impact our commitment to this Regulatory Guide.

Document Control Desk Enclosure I LAR 05-0677 RC-06-0024 Page 11 of 11

6.0 ENVIRONMENTAL CONSIDERATION

SCE&G has determined that the proposed amendment would change requirements with respect to the 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. SCE&G has evaluated the proposed change and has determined that the change does not involve, (i) a significant hazards consideration, (ii) a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. As discussed above, the proposed change does not involve a significant hazards consideration. Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51, specifically 10 CFR 51.22(c)(9).

Therefore, pursuant 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.

7.0 REFERENCES

7.1 EPRI Technical Report, TR-104965, Rev 1, 9/2000- Application of On-Line Performance Monitoring to Extend Calibration Intervals of Instrument Channel Calibrations.

7.2 Safety Evaluation by the Office of Nuclear Reactor Regulation, Application of On-Line Performance Monitoring to Extend Calibration Intervals of Instrument Channel Calibrations, EPRI Technical Report TR-1 04965.

7.3 EPRI Technical Report 1007930, On-Line Monitoring of Instrument Channel Performance, Volume 3: Applications to Nuclear Power Plant Technical Specification Instrumentation, dated 12/2004.

7.4 EPRI Technical Report 1003661, Plant Systems Modeling Guidelines to Implement On-Line-Monitoring, dated 12/2004.

7.5 On-Line Monitoring of Instrument Channel Performance Volume 1: Guidelines for Model Development and Implementation, EPRI Report No. 1003361, December 2004.

7.6 On-Line Monitoring of Instrument Channel Performance Volume 2: Model Examples, Algorithm Descriptions, and Project Results, EPRI Report No.

1003579. December 2004.

Document Control Desk Attachment I LAR 05-0677 RC-06-0024 Page 1 of 27 SCE&G -- EXPLANATION OF CHANGES ATTACHMENT I PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Attachment to License Amendment No. XXX To Facility Operating License No. NPF-12 Docket No. 50-395 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Paaes Index Page I 1-4 1-5 1-6 3/4 3-11 3/4 3-12 3/4 3-13 3/4 3-14 3/4 3-17 3/4 3-35 3/4 3-36 3/4 3-37 3/4 3-38 3/4 3-39 3/4 3-40 3/4 3-50 3/4 3-52 3/4 3-53 3/4 3-55 3/4 3-56 B 3/4 3-1 B 3/4 3-3 Insert Paaes Index Page I 1-4 1-5 1-6 3/4 3-11 3/4 3-12 3/4 3-13 3/4 3-14 3/4 3-17 3/4 3-35 3/4 3-36 3/4 3-37 3/4 3-38 3/4 3-39 3/4 3-40 3/4 3-50 3/4 3-52 3/4 3-53 3/4 3-55 3/4 3-56 B 3/4 3-1 B 3/4 3-3

Document Control Desk Attachment I LAR 05-0677 RC-06-0024 Page 2 of 27 SCE&G -- EXPLANATION OF CHANGES Page Affected Bar Descripl:ion of Chanae Reason for Change Section Index I 1.18, et.al.

I Added new 1.18, New 1.18.

renumbered remaining Definitions, Revised applicable Page numbers.

1-4 1.18 1

Add new definition for On-line Incorporate guidance from monitoring insert 1).

EPRI Technical Report TR-104965.

1-4 1.18-1.22 2-5 Renumber Definitions.

Administrative change.

1-5 1.23-1.31 1-9 Renumber Definitions.

Administrative change.

1-6 1.32-1.38 1-2 Renumber Definitions.

Administrative change.

4-8 1-6 1.33 3

Additional words added to Incorporate guidance from Definition of Staggered Test EPRI Technical Report TR-Basis (Insert 6).

104965.

3/4 3-11 Table 4.3-1 1

Add reference to Note 15.

Incorporate guidance from EPRI Technical Report TR-Added a new column for On-104965.

Line Monitoring Evaluation Frequency.

Removed comma from Editorial error not corrected Functional Unit 5 CS/U(1),]

in Amendment 101.

3/4 3-12 Table 4.3-1 1

Add reference to Note 15.

Incorporate guidance from EPRI Technical Report TR-Added a new column for On-104965.

Line Monitoring Evaluation Frequency.,

Note 8 was deleted by Amendment 101.

Remove Note 8 from 19.B and 19.C.

3/4 3-13 Table 4.3-1 1

Added reference to Note 15.

Incorporate guidance from EPRI Technical Report TR-Added a new column for On-104965.

Line Monitoring Evaluation Frequency.

Document Control Desk Attachment I LAR 05-0677 RC-06-0024 Page 3 of 27 SCr.Fr.G

-- FXPL ANATION OF CHANGFS Paae Affected Bar DescriDtion of Chanae Reason for Chanae Section 3/4 3-14 Table 4.3-1 1

Add Note 15 for on-line Incorporate guidance from monitoring (Insert 2).

EPRI Technical Report TR-104965.

3/4 3-17 Table 3.3-3 1

Change "and" to "any".

Correction of typographical

.ferror.

3/4 3-35 Table 4.3-2 1

Add reference to Note 3.

Incorporate guidance from EPRI Technical Report TR-Added a new column for On-104965.

Line Monitoring Evaluation Frequency.

3/4 3-36 Table 4.3-2 1

Add reference to Note 3.

Incorporate guidance from EPRI Technical Report TR-Added a new column for On-104965.

Line Monitoring Evaluation Frequency.

3/4 3-37 Table 4.3-2 1

Add reference to Note 3.

Incorporate guidance from EPRI Technical Report TR-Added a new column for On-104965.

Line Monitoring Evaluation Frequency.

3/4 3-38 Table 4.3-2 1

Add reference to Note 3.

Incorporate guidance from II EPRI Technical Report TR-Added a new column for On-104965.

Line Monitoring Evaluation Frequency.

3/4 3-39 Table 4.3-2 1

Add reference to Note 3.

Incorporate guidance from EPRI Technical Report TR-Added a new column for On-104965.

Line Monitoring Evaluation Frequency.

3/4 3-40 Table 4.3-2 1

Added Note 3 to Table Incorporate guidance from Notations.

EPRI Technical Report TR-104965.

3/4 3-50 4.3.3.4 1

Added reference to new Incorporate guidance from Surveillance Requirement.

EPRI Technical Report TR-104965.

Document Control Desk Attachment I LAR 05-0677 RC-06-0024 Page 4 of 27 SCE&G -- EXPLANATION OF CHANGES Page Affected Bar Description of Change Reason for Change Section 3/4 3-52 Table 4.3-5 1

Added reference to Note 1.

Incorporate guidance from EPRI Technical Report TR-Added a new column for On-104965.

Line Monitoring Evaluation Frequency.

3/4 3-52 Table 4.3-5 2

Added Table Notation and Incorporate guidance from Note 1.

EPRI Technical Report TR-104965.

3/4 3-53 4.3.3.5 1

Added reference to new Incorporate guidance from Surveillance Requirement.

EPRI Technical Report TR-104965.

3/4 3-55 Table 4.3-6 1

Added reference to Note 1.

Incorporate guidance from EPRI Technical Report TR-Added a new column for On-104965.

Line Monitoring Evaluation Frequency.

Added Table Notation and Note 1.

3/4 3-56 3/4.3.6 1

Capitalized OPERABLE.

Administrative change.

3/4 3-56 3/4.3.6 2

Added Surveillance Incorporate guidance from Requirement (Insert 3).

EPRI Technical Report TR-104965.

B 3/4 3-1 B 3/4.3.1 1

Added discussion of on-line Providing reference to and B monitoring to Bases (Insert justification for change in 3/4.3.2 4).

Bases.

B 3/4 3-3 B 3/4.3.3.4 1

Added discussion of on-line Providing reference to monitoring to Bases (Insert justification for change in 5).

Bases.

Document Control Desk Attachment I LAR 05-0677 RC-06-0024 Page 5 of 27 SCE&G -- EXPLANATION OF CHANGES Insert I ON-LINE MONITORING 1.18 ON-LINE MONITORING is the assessment of channel performance and calibration while the channel is operating. ON-LINE MONITORING differs from CHANNEL CALIBRATION in that the channel is not adjusted by the process of ON-LINE MONITORING. Instead, ON-LINE MONITORING compares channel performance to established acceptance criteria to determine if a CHANNEL CALIBRATION is necessary.

Insert 2 (15) -

For Channels evaluated by ON-LINE MC)NITORING, a formal surveillance evaluation shall be performed to verify that no channels are outside the prescribed acceptance limits on a quarterly basis. At least one redundant transmitter will be calibrated every 18 months on a STAGGERED TEST BASIS, with each channel calibrated at least once per every 6 years.

Insert 3 For channels evaluated by ON-LINE MONITORING, a formal surveillance evaluation shall be performed to verify that no channels are outside the prescribed acceptance limits on a quarterly basis. At least one redundant transmitter will be calibrated every 18 months on a STAGGERED TEST BASIS, with each channel calibrated at least once per every 6 years.

Insert 4 EPRI Technical Report, TR-1 04965, Rev 1, provides an alternative methodology for extending the calibration interval for selected instrumentation. The maximum an instrument calibration can be extended is to 6 years with at least one of the redundant instruments calibrated every 18 months.

This methodology is based on the ON-LINE MONITORING system, which performs quarterly assessments of channel performance and can detect very small changes in instrument performance or drift.

Insert 5 The application of EPRI TR-104965 to the meteorological instrumentation is consistent with the intent of the EPRI report, although it is outside the scope of the published report. The extension of calibration frequencies for these instruments will be controlled by the same requirements as the safety-related instruments in 3.3.1 and 3.3.2.

Insert 6 (add to STAGGERED TEST BASIS)

Furthermore, for systems, subsystems, channels, or other designated components that are evaluated by ON-LINE MONITORING, all n systems, subsystems, channels, or other designated components will be tested at a frequency not to exceed 6 years, regardless of the size of n.

)

DEFINITIONS SECTION 1.0 DEFINITIONS PAGE 1.1 ACTION..................

1.2 ACTUATION LOGIC TEST...................................

1.3 ANALOG CHANNEL OPERATIONAL TEST.

1.4 AXIAL FLUX DIFFERENCE..................................

1.5 CHANNEL CALIBRATION....................................

1.6 CHANNEL CHECK............................................

1.7 CONTAINMENT INTEGRITY...................................

1.8 CONTROLLED LEAKAGE............

1.9 CORE ALTERATION..............

1.9a CORE OPERATING LIMITS REPORT............................

1.10 DOSE EQUIVALENT I-131...................................

1.11 E-AVERAGE DISINTEGRATION ENERGY 1.12 ENGINEERED SAFETY FEATURES RESPONSE TIME...............

1.13 FREQUENCY NOTATION.....................................

1.14 GASEOUS RADWASTE TREATMENT SYSTEM.......................

1.15 IDENTIFIED LEAKAGE.....................................

1.16 MASTER RELAY TEST.......................................

1.17 OFFSITE DOSE CALCULATI(ON MANUAL (ODCM) j,11,49 OPERABLE - OPERABILITY..................................

,.2l 4v9t OPERATIONAL MODE - MODE.................................

1 pe PHYSICS TESTS...

,.v 1,21 PRESSURE BOUNDARY LEAKAGE...............................

1.e-EZ PROCESS CONTROL PROGRAM (PCP)

I.-23 PURGE-PURGING....................................

,2

)'1,2¢ QUADRANT POWER TILT RATIO...............................

,.ia 1_25 RATED THERMAL POWER.....................................

/,V7 6 REACTOR TRIP SYSTEM RESPONSE TIME.......................

vo REPORTABLE EVENT........................................

-z

, SHUTDOWN MARGIN.........................................

1 soJri" SLAVE RELAY TEST........................................

srl'30 DELETE...................................................

l as.k31 SOURCE CHECK............................................

1siJ '.4 STAGGERED TEST BASIS....................................

Z THERMAL POWER...........................................

I(1.3¢ TRIP ACTUATING DEVICE OPERATIONAL TEST..................

&,les5 UNIDENTIFIED LEAKAGE....................................

37 1-36 VENTILATION EXHAUST TREATMENT SYSTEM..................

I.-Se 17 VENTING................................................

TABLE 1.1 OPERATIONAL MODES..................................

TABLE 1.2 FREQUENCY NOTATION.................................

1-1 1-1 1-1 1-1 1-1 1-1 1-2 1-2 1-2 1-2 1-2 1-3 1-3 1-3 1-3 1-3 1-3 1-4 1-4 1-4 1-5 1-5 1-5 1-5 1-5 1-5 1-6 1-6 1-6 1-6 1-6 1-6 1-7 1-8 I

SUMMER - UNIT I I

Amendment No.

as, 08,

DEFINITIONS p

OFFSITE DOSE CALCULATION MANUAL (0D00!

1.17 The OFFSITE DOSE CALCULATION MNUAL (ODCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm/Trip Setpoints, and in the conduct of the Environmental Radiological Monitoring Program.

The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs.required by Section 6.8.4 and (2) descriptions of the information that should be included In the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by

,ions 6.9.1.6 and 6.9.1.8.

ERABE -OPERABIL1TY.

______1____ A system, subsystem, train, comqonent or device shall be OPERABLE or L___---1ia~I~ OPERABILITY when it Is capable of performing its specified function(s),

and when all necessary attendant instiumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of perfMing their related support function(s).

OPERATIONAL MODE - NODE

({420 1. @ An OPERATIONAL MODE (i.e., MODE) shiall correspond to any one inclusive

'Cl'icimbination of core reactivity condition, power level and average reactor coolant temperature specified in Table 1.1.

PHYSICS TESTS

/*

.ISPHYSICS TESTS shall be those teits performed to measure the fundamental

(~1-V::ZAle-ar characteristics of the reactor core and related instrumentation and

1) described in Chapter 14.0 of the FSAR, 2) authorized under the provisions of 10 CFR 50.59, or 3) otherwise approved by the Comuission.

PRESSURE BOUNDARY LEAKAGE (3i7E 1 j PRESSURE BOUNDARY LEAKAGE shall tie leakage (except steam generator tube O--

kid&ge) through a non-isolable fault in a Reactor Coolant System component body, pipe wall or vessel wall.

PROCESS CONTROL PROGRAM (PCPI The PROCESS CONTROL PROGRAM (PCP) shall contain the current formulas,

-iutpling, analyses, tests, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes wil be accomplished in such a way as to assure compliance with 10 CFR Parts 20, 61, and 71, State regulations, burial ground requirements, and other requirements -governing the disposal of solid radioactive waste.

SUMMER

- UNIT I 1-4 Amendment No.

P09,R10

DEFINITIONS PURGE - PURGING PURGE or PURGING is the controlled process of discharging air or gas from a cni~ nement to maintain temperature, pressure, humidity, concentration or other operating condition, In such a manner that replacement air or gas is required to purify the confinement.

QUADRANT POWER TILT RATIO 9 32, QUADRANT POWER TiLT RAinO shall be the ratio of the maximum upper excore 4or calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater. With one excore detector inoperable, the remaining three detectors shall be used for computing the average.

RATED THERMAL POWER f iio > RATED THERMAL POWER shall be a total reactor core heat transfer rate to the 6or coolant of 2900 MWt.

REACTOR TRIP SYSTEM RESPONSE TIME

/dThe REACTOR TRIP SYSTEM RESPONSE TIME shall be the time Interval from ii~ n the monitored parameter exceeds its tip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps; so that the entire response time -is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC.

REPORTABLE EVEN CIIII>2;C A REPORTABLE EVENT shall be any of those conditions specified in Section 50.73 CFR Part 50.

SHUTDOWN MARGIN F9 SHUTDOWN MARGIN shall be the Instantaneous amount of reactivity by which the L-a e6tFor is subcritical or would be suberitkal from Its present condition assuming all full length rod cluster assemblies (shutdown and control) are fully inserted except for the single rod duster assembly of highest reactivity worth which Is assumed to be fully withdrawn.

SLAVE RELAY TEST i

A SLAVE RELAY TEST shall be Ithe energization of each slave relay and verification 0

,F-O1ERABILITY of each relay. The SLAVE RELAY TEST shall include a continuity check, as a minimum, of associated testable actuation devices.

6 I Not Used SOURCE CHECK

/J&

A SOURCE CHECK shall be the qualitative assessment of channel response when (E~ieiF annel sensor is exposed to a radioactive source.

SUMMER - UNIT 1 1-5 Amendment No. 35, 101, 147, 133, 346

DEFINITIONS STAGGERED TEST BASIS CK.-

) STAGGERED TEST BASIS shall c-onsist of:

a.

A test schedule for n systems, subsystems, trains or other designated components obtained by dividing the specified test interval into n equal subintervals,

b.

The testing of one system, subsystem, train or other designated component at the beginning of each subinterval.

L POWER (3

4'CIT iTHERMAL POWER shall be the total reactor core heat transfer rate to the

,_____rrartor coolant.

TRIP ACTUATING DEVICE OPERATIONAL TEST TRIP ACTUATING DEVICE OPERAT:IONAL TEST shall consist of operating the p 4Actuating Device and verifying OPERABILITY of alarm, interlock and/or trip functions.

The TRIP ACTUATING DEVICE OPERATIONAL TEST shall include adjustment, as necessary, of the Trip Actuating Device such that it actuates at the required setpoint within the required accuracy.

UNIDENTIFIED LEAKAGE UNIDENTIFIED LEAKAGE shall be ill leakage which is not IDENTIFIED LEAKAGE L____orCUN TROLLED LEAKAGE.

VENTILATION EXHAUST TREATMENT SYSTEM

((,17-1-r.FA VENTILATION EXHAUST TREATMENT SYSTEM is any system designed and installed

'--- voiSeduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and/or HEPA filters for the purpose of removing iodines or particulates from the gaseous exhaust stream prior to the release to the environment (such a system is not considered to have any effect on noble gas effluents).

Engineered Safety Feature (ESF) atmospheric cleanup systems are not considered to be VENTILATION EXHAUST TREATMENT SYSTEM components.

VENTING (TVENTING is the controlled process of discharging air or gas from a con-Q-..----f'Mi'ent to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTING.

Vent, used in system names, does not imply a VENTING process.

SUMMER - UNIT 1

]L-6

TABLE 4.3-1 REACIOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS CA a'3 I5 1.

2.

FUNCTIONAL UNIT Manual Reactor Trip Power Range, Neutron Flux High Setpoint CHANNEL CHECK N.A.

S TRIP ACTUATING DEVICE OPERATIONAL TEST R(11)

N.A.

ACTUATION LOGIC TEST N.A.

NA.

MODES FOR WHICH SURVEILLANCE IS REQUIRED 1, 2,3*, 4*, 5*

1,2

-S

3.

Power Range, Neutron Flux High Positive Rate

4.

Deleted 6

N.A.

1###, 2 1,2 S

m 0

rt 0

/

5.

Intermediate Range, Neutron Flux

6.

Source Range, Neutron Flux

7.

Overtemperature AT

8.

Overpower AT

9.

Pressurizer Pressure.-Low

10.

Pressurizer Pressure-High

11. Pressurizer Water Level-High

12.

Loss of Flow B

S S

S N.A.

N.A.

2##,3,4,5 1,2 1,2 1

1,2 1

1 N.A.

TABLE 4.3-1 (Continued)

'A

-4 H

TkIP AtTUATING DEVICE OPERATIONAL TtST CH FUNCTIONAL UNIT CH

13.

Steam Generator Water Level--

Low-Low

14.

Steam Generator Water Level -

Low Coincident with Steam/

Feedwater Flow Mismatch

15.

Undervoltage - Reactor Coolant Pumps i6. Underfrequency - Reactor Coolant Pumps

17.

Turbine Trip HANNEL CHANNES HECK CALIBR/

S R

S N.A.

R N.A.

R ACTUATION LOGIC TEST N.A.

MODES FOR WHICH SURVEILLANCE IS REQUIRED 1, 2 N.

A.

(

N. A.

N.A.

1, 2 N.A.

1 I

q

.h.

a I. M.

A. Low Fluid Oil Pressure B.

Turbine Stop Valve Closure

18.

Safety Injection Input from ESF

19.

Reactor Trip System Interlocks A.

Intermediate Range Neutron Flux, P-6 B. Low Power Reactor Trips Block, P-7 C. Power Range Neutron Flux, P-8 N.

A.

R R

N.

A.

S/U(1, 10)

N.A.

1 N.A.

1 N.

A.

N.

A.

R N.A 1, 2 N.

A.

R(4)

N. A.

N.A.

2##

N.A.

I N. A.

R(4)

N. A.

N.A.

R(4)

N.

A.

N. A.

1

TA8UE 4.3-1 (Continae)

'4n 9-4 OLa TRIP ACMIN~UG OPERATIMNL TEST C

FICTOIOtL UNIT

(

0.

Lw Setpoint Power Range Neutr" Flux, P-10 E.

Turbine Iupule Chaber Pressure. P-13 F.

Low Power Range Neutron flux, P-9

20.

Reactor Trip Breaker

21.

Automatic Trip Logic

22.

Reactor Trip Bypass Breaker MIECK P.A.

W.A.

N.A.

ACMAMON LOGIC TEST N. A.

A.s N.A.

N.A.

" (7)

4)

M. A.

NODES FOR WHICH SURVILLANC is gTQIRED 1, 2 1, 2, 3*, 4*,

1, 2, 3*, 4*,

1, 2, 3*, 4*.

N.A.

P.A.

N.A.

N. A.

l.A.

N.A.

N (7, 12)

N.A.

1(13), ft1 5* -

5*t 5* -r H.A.

i i

II I

I i

Iii i

i II Ii I

q.

90

TABLE 4.3-1 (Continued)

TABLE NOTATION

- With the reactor trip system breakers closed and the control rod drive system capable of rod withdrawal.

Below P-6 (Intermediate Range Neutron Flux Interlock) setpoint.

Below P-10 (Low Setpoint Power Range Neutron Flux Interlock) setpoint.

(1) -

If not performed in previous 31 days.

(2) -

Comparison of calorimetric to excore power indication above 15% of RATED THERMAL POWER.

Adjust excore channel gains consistent with calorimetric power if absolute difference is greater than 2 percent.

The provisions of Specification 4.0.4 are not applicable for entry into MODE 2 or 1.

(3)

Single point comparison of incore to excore AXIAL FLUX DIFFERENCE 4

above 15% of RATED THERMAL POWER. Recalibrate if the absolute difference is greater than or equal to 3 percent. The provisions of Specification 4.0.4 are riot applicable for entry into MODE 2 or 1.

(4) -

Neutron detectors may be excluded from CHANNEL CALIBRATION.

(5) -

Detector plateau curves shall be obtained evaluated and compared to manufacturer's data.

For the Power Range Neutron Flux Channels the provisions of Specification 4.0.4 are not applicable for entry into MODE 2 or 1.

)

(6) -

Incore - Excore Calibration, above 75% of RATED THERMAL POWER.

The provisions of Specification 4.0.4 are not applicable for entry into MODE 2 orl.

(7) -

Each train shall be tested at least every 62 days on a STAGGERED TEST BASIS.

(8) -

DELETED A

(9) -

Quarterly Surveillance in MODES 3*, 4* and 5* shall also include I

verification that permissives P-6 and P-10 are in their required state for existing plant conditions by observation of the permissive annunciator window.

(10)

Setpoint verification is not. required.

(11)

The TRIP ACTUATING DEVICE OPERATIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip circuits for the Manual Reactor Trip Function. The test shall also verify the OPERABILITY of the Bypass Breaker trip circuit(s).

(12) -

The TRIP ACTUATING DEVICE OPERATIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip attachments of She Reactor Trip Breakers.

(13) -

Local manual shunt trip prior to placing breaker in service.

(14) -

Automatic undervoltage trip.

SUMMER -

UNIT 1 3/4 3-14 Amendment No. 7Z,,71,_aer

TABLE 3.3-3 (Continued)

(hI I

'-6 t-A ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION TOTAL NO.

OF CHANNELS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE FUNCTIONAL UNIT

f. Steam Line Pressure-Low APPLICABLE MODES 1, 2, 3f ACTION 24*

l pressure/

ssure ssure loop loops ad loops t

2.

REACTOR BUILDING SPRAY

a.

Manual 2 sets - 2 switches/set 1 set 2 sets 1, 2, 3, 4 18

-.0 It

b.

Automatic Actuation Logic and Actuation Relays

c.

Reactor Building Pressure--High-3 (Phase 'A' isolation aligns spray system discharge valves and NaOH tank suction valves) 2 1

2 3

a, 2.,.3, 'I 1, 2, 3 4

2 Lt 16 D

er x

TABLE 4.3-2 I

.ENGINEERED SAFETY FEATURE ACTUATION M

-SURVEILLANCE REQUIF I

'4 F

CHANNEL FUNCTIONAL UNIT CHECK

1. SAFETY INJECTION, REACTOR TRIP FEEDWATER ISOLATION, CONTROL ROOM ISOLATION START DIESEL GENERATORS, CONTAINMENT COOLING FANS AND ESSENTIAL SERVICE WATER

a. Manual Initiation

.A.

w b. Automatic Actuation N.A.

Logb-enda A-ctuat1ion Relays

c.

Reactor Building S

Pressure-High-I

d. Pressurizer Pressure--Low S

e.

Differential Pressure S

Between Steam Lines--High

f. Steam Line Pressure Low S

2. REACTOR BUILDING SPRAY

a. Manual Initiation N.A.

b. Automatic Actuation N.A.

Logic and Actuation Relays

c. Reactor Building S

Pressure-High-3 TRIP ANALOG ACTUATING CHANNEL DEVICE OPERATIONAL OPERATIONAL TEST TEST

q.

A N.A.

R A -[N.A.

N.A.

ACTUATION LOGIC TEST MASTER RELAY TEST SLAVE RELAY TEST MODES FOR WHICH SURVEILLANCE IS REQUIRED I

iIi i

iII I

iI i.I i

i

. i i

I II I

I I

I IiI I

. I I

i

..i IIiI N.

A.

N.

A.

N..

ANA.

".n.

L, 2, 3, 4 M(1)

M(1)

Q 1, 2, 3, 4 N.A N.A.

N.A.

1, 2, 3 J N.

A.

N.A N. A.

N. A.

N.

A.

N. A.

N.A.

N. A.

1, 1,

2, 2,

3 3

R R

N. A.

N.A.

.1, 2, 3 3'

4 4

4 r

S.-

N.

A.

N.

A.

N.

A.

N.

A.

R N.

A.

N.A.

M(1)

N.A.

M(1)

N.A.

1, Q

1, 2,

2, 3,

3, R

IQ N.A.

N.

A.

N.A.

1, 2, 3 Ih1 A

TABLE 4.3-2 (Continued)

I 9

H'4

~-A w

w w

FUNCTIONAL UNIT

3.

CONTAINMENT ISOLATION

a. Phase "A" Isolation

1) Manual

2) Safety Injection

3) Automatic Actuatioi Logic and Actuation Relays

b. Phase '"B" Isolation

1) AutomaticActuatioi Logic and Actuation Relays

2) Reactor Building Pressure-High-3

c. Purge and Exhaust Isola

1) Automatic Actuatio Logic and Actuation Relays

2) Containment Radio.

activity-High

3) Safety injection ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SUVILLANCE REQUIRtEMENTS f olTcteVA ANALOG ACTUATING I

L HANNEL DEVICE MA CHANNEL N

PERATIONAL OPERATIONAL ACTUATION REL CHECK C

BA EST TEST LOGIC TEST TES-N.A.

N.A.

MA N.A.

R N.A.

N.

See 1 ab e fo all Safety Injection Surveillance Requirements.

i NA.

N.A.

it.R A.

NA.

M(1)

M n NA.

NA.

$.,A N.A.

N.A.

M(1)

M S

R NA.

N.A.

N ition n N.A.

N.A.

-V.A. A.

NA.

M(1)

M

> S R

J AM N.A.

N.A.

N STER AY T

SLAVE RELAY TEST A.

N.A.

1, 2,3,4 (1)

Q 1,2,3,4 (1)

Q 1,2,3,4

.A.

N.A.

1,2,3 1(1)

Q(2) 1,2,3,4 i.A.

N.A.

1,2,3,4 MODES FOR WHICH SURVEILLANCE IS REQUIRED d's t

05I rs z

See 1 above for all Safety Injection Surveillance Requirements.

TABLE 4.3-24Continued)

ENGINEERED SAFETY FEATURE ACTUYAflGN-jSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL CHECK FUNCTIONAL UNI

4. STEAM LINE ISOLATION

a. Manual

b. Automatic Actuation Logic and Actuation Relays

c. Reactor Building Pressure-High-2

d. Steam Flow in Two Steam Lines--High Coincident with Tavg_ Low-Low

e. Steam Line Pressure Low NA.

N.A.

S S

p-l-6 IALOG 6, i ANNEL PERA-CHA ONAL CALIBRATIG EST NA.

NJi.

N.A.

fi N.A.

RC3 Qc R LS)

IQ R C3)

,& Q WR a1Q N.A.

I A/

N.A.

lye A. N.A.

N.A.

MA.

NA.

Qa TRIP ACTUATING DEVICE OPERATIONAL TEST R

N.A.

ACTUATION LOGIC TEST

5. TURBINE TRIP AND FEEDWATER ISOLATION NA.

N.A.

NA.

N.A.

R N.A.

NA.

M(1)

N.A.

M A N.A.

N.A.

M(1)

N.A.

M(1)

N.A.

MASTER RELAY TEST N.A.

M(1)

N.A.

M(1)

N.A.

M(1)

N.

SLAVE RELAY TEST N.A.

0 N.A.

N.A.

Q N.A.

MODES FOR WHICH SURVEILLANCE IS REQUIRED 1,2,3 1,2,3 1,2,3 1, 2,3 1,2, 3 1,2,3 i

1,2 1,2 1,2,3 1,2, 3 1,2, 3

a. Steam Generator Water Level--High-High

b. Automatic Actuation Logic and Actuation Relay

6. EMERGENCY FEEDWATER S

N.A.

a. Manual

b. Automatic Actuation Logic and Actuation Relays

c. Steam Generator Water Level--Low-Low N.A.

N.A.

S

TABLE 4.3-2 (Cwntiued) en

-4

'-a ENGIIERED SAF FEATTY E ACTUATIOW SYSTM INSTRWMATION SURItIANCE R MiULREHENYS TRIP ACT'VATING VICE OPERATIOAL TEST ta JIa I.1 i..;

': *t

.I.,I-fUNCTIAL UNIT MRGCY FEEMI7ER (ContinM

)

d.

neroltage - Botli ESF Busses

e.

Safety Injection

f.

Uilervoltage - One

[SF Bus

g. Trip of Nain Feedwater Pumps

h. Suction transfer on low pressure

7.

LOSS OF PMlR

a. 7.2 kV EfrgencY Bus Undervoltage (Loss of Voltage)

b.

7.2 kV Emergency Bus Undervoltage (Degraded Voltage) t8.

AUTOVATIC SW}TMV(R TO COWTAIWMT SUUP

a.

Tv elvewIvoCv 2'

b. Automatfc Actuation logic and Actuation Relays N.A.

R N.A.

See I N.A.

N.A.

S N.A.

NA.

S N.A.

above for R

Injection Surveillance Requirewei I

R N.A.

1.

R N.A.

N.A.

MmN CH ACTUATION LOGIC TEST N.A.

R FODES FOR MSTER SLAVE WMCH MIAY RELAY SUREILLANCE TEST TEST IS REUIRED N.A.

N.A.

1, 2, 3 Its N.A N.A.

1. 2, 3 tiA. it.A.

1, z N.A.

N.A.

1, 2, 3 N.A.

NA.

1, 2, 3, 4 N.A.

N.A.

I, 2, 3, 4 R

R I

13 I

I I.A.

N.A.

tN.A.

R R

N.A..

N. A.

N.A.

N. A.

".(1

".A.

"M(1 R.A.

1, 2, 3 Q

1,2,3

! 1 iiII

e FUNCTIONAL UNIT

9.

ENGINEERED SAFETY FEATUI ACTUATION SYSTEM INTERLI

a. Pressurizer Pressur P-11

b.

Low, Low 71avg,-P-1

c. Reactor Trip, P-4 TABLE 4.3-2 (Continued)

ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS-

~

TRIP

~J AL(t13 LOG ACTUATING C ANNEL DEVICE CHANNEL C

EL 0 ERATIONAL OPERATIONAL ACTUI CHECK CALl ON T ST TEST LOGII RE DCKS e, N.A.

R. 3Q Q

N.

A.

I

--NWA.

~

R.

r.lQN.

A.

I N.A.

N.A. lJ,)NA.

RI

%TION

. TEST MASTER RELAY TEST SLAVE RELAY TEST MODES FOR WHICH SURVEILLANCE IS REQUIRED i

i I

ii I

Ii iI

i. i ii i

i Ii iiiI II p

I ii i

I I

j i

IiiI iI I

I N.

A.

N.A.

1, 2, 3 N. A.

N. A.

N.A.

N. A.

1, 2, 3 1, 2, 3 0M C+

INSTRUMENTATION

)

TABLE 4.3-2 (Continued)

TABLE NOTATION (1)

Each train shall be tested at least every 62 days on a STAGGERED TEST BASIS.

(2)

The 36 inch containment purge supply and exhaust isolation valves are I

sealed closed during Modes 1 through 4, as required by TS 3.6.1.7. With these valves sealed closed, their ability to open is defeated; therefore, they are excluded from the quarterly slave relay test.

CCs-lo c4hA"e#

elV4 lva+-

eJ Z'e 4e 2

o e

4

/

5~rts/4ce c~c 4q.?0 ge Sor~z

^

c&

7<Ly A

y le/

4sre

'A A6 <ie 1/ST cc

/o S 2 /

V el chE7"ls

~d-qfc 4 -Iees+ once t¢ee every 6 yeaq

, )

,/

SUMMER -UNIT I 3/4 3-40 A.mendment No. 128

W

INSTRUMENTATION METEOROLOGICAL INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.4 The meteorological monitoring instrumentation channels shown in Table 3.3-B shall be-OPERABLE.

APPLICABILITY:

At all times.

ACTION:

a. With one or more required Meteorological monitoring channels inoperable for more than 7 days, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next 10 days outlining the cause of the malfunction and the plans for restoring the channel(s) to OPERABLE status.

b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.4 Each of the above meteorological monitoring instrumentation channIls shall be demonstrated OPERABLE by the performance of the CHANNEL CKEC n

CHANNEL CALIBRATIOat the frequencies shown in Table 4.3-57-f f v',q oJTO~t,,v sVolid~ h\\

SUMMER - UNIT 1 3/4 3-50

(

):)

INSTRUMENTATION TABLE 4.3-5 METEOROLOGICAL MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Oti -Ln e INSTRUMENT CHANNEL CHECK CHANNEL CALIBRATIO

1.

Wind Speed

a.

Wind Speed Lower 10m D

A (i) 9

b.

Wind Speed Upper 61m D

A (')

l

2.

Wind Direction

a.

Wind Direction Lower 10m D

A (I)

Q

b.

Wind Direction Upper 61.

D A (I)

3.

Atmospheric Stability/

a.

Delta T 1 10-61m D

A(i/

b.

Delta T 2 10-40m D

A(,)

Elevations nominal above grade elevattion 0

-1

-ZI-7

{x (/)

1>t cit444t 1ol Qv(.4/je4 YC 6)v a ~/8 C 2

0i 4a

/owv rt/de

/tc-k

.544//

6z e.f o

ve wctg tAcf otva c4n els arce

4.stde vie,oresctrlAd -*cce1opA?,ce AI I^

-/s eA at s1 e

0%5 l

All -4ef,1/

Iolvn-o ez;4s i

6e Ca/rll two/la e&6Ty 36 SUMMER - UNIT 1 3/w4 3-52

INSTRUMENTATION REMOTE SHUTDOWN INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.5 The remote shutdown monitoring instrumentation channels shown in Table 3.3-9 shall be OPERABLE with readouts displayed external to the control room.

APPLICABILITY:

MODES 1, 2 and 3.

ACTION:

a.

With the number of OPERABLE remote shutdown monitoring channels less than required by Table 3.3-9, restore the inoperable channel to OPERABLE status within 7 days, or be in HOT SHUTDOWN within the next 1t hours.

b.

The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.5 Each remote shutdown monitoring instrumentation chaniel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK idjCANNEL CALIS A

TI nqMr.i-snr h!abl M~!

Gi 4-73tOJIO IS 6.i

^

3~e I

SUMMER - UNIT 1 3/4 3-53

i:

- MY (A

1'-4

-4 OA)

LA U'1 U'b REM(

INSTRUMENT

1. Reactor Trip Breaker Indication

2. Pressurizer Pressure

3. Pressurizer Level

4. Steam Generator Pressure

5. Steam Generator Level

6. Conudensate Storage Tank Level

7. Reactor Coolant System Hot Leg'

8. Reactor Coolant System Cold Leg

9. Reactor Coolant System Pressure

10.

Pressurizer Relief Tank Level

11.

Reactor Building Temperature

12.

Boric Acid Tank Level TABLE 4.3-6

)TE SHUTDOWN MONITORING INSTRUMENTATION-SURVEILLANCE REQUIREMENTS CHANNEL CHECK

`

M M

Temperature Temperature M

M M

H M

M H

H CHANNEL CALIBRATION N. A.

R()

R Q )

R (i)

R R

R R ( )

R R

R C;4 -Z.,4 e A/%nfo tonj Ar/. / Id to-f Al. A.

Al A.

7?dLE A~o7'T/o4A)

'c~c qo A

,ce g

P

~

4 e

/4 # /e-4,s# 04e, ree, k#'dq~

7e.0 os^ hte g~~

1 e C-4/,4e -q7'e a' tJ~

B~

7 sh 5 7 -4 IR.

)

7 s 3 S 5 ~ t, £ /~C 1 ~ '. Z ~

e~ s,*

~ c e 0?

Ye

INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.6 The accident monitoring Instrumentation channels shown in Table 3.3-10 shall be OPERABLE.

APPLICABILITY MODES 1, 2, and 3.

ACTION:

a.

With the number of OPERABLE accident monitoring channels less than the Required Number of Channels shown on Table 3.3-10, either restore the Inoperable channel(s) to OPERABLE status within 30 days or submit a Special Report within the following 14 days from the time the action is required. The report shall outline the preplanned alternate method of monitoring, the cause of the Inoperability, and the plans and schedule for restoring the Instrumentation I

channels tb batus.

b.1 With the nu F

B LE Reactor Building radiation monitoring channels less than the Minimum Channels Operable requirement of Table 3.3-10, either restore the Inoperable channel(s) to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or.

i)

Initiate the preplanned alternate method of monitoring the appropriate parameter(s), and ii)

Submit a Special Report to Ihe Commission pursuant to Specification 6.9.2 within 14 days following the event outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status.

b.2 Deleted b.3 With the number of OPERABLE accident monitoring channels less than the Minimum Channels Operable requirement of Table 3.3-10, either restore the Inoperable channels to OPERABLE status within 7 days or be In at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

c.

The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.6 Each accident monitoring Instrumentation channel shall be demonstrated OPERABLE by nerforming a monthly CHANNEL CHECK and a CHANNEL CALIBRATION ever rueling outage.1The Reactor Building Radiation Level Instrumentation CHANNEL l

CALIBRATION may consist of an electronic calibration of the channel, not including the detector, for the range decades above 1OR/hr and a single point calibration of the detector below 1 OR/hr with an installed or portable gamma source.

SUMMER - UNIT 1 3/4 3-56 Amendment No. 48-8 170

3/4.3 INSTRUMENTATION BASES 3/4.3.1 and 3/4.3.2 REACTOR 'IP AND ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION The OPERABILITY of the Reactor Protection System and Engineered Safety Feature Actuation System Instrumentation and interlocks ensure that 1) the associated action and/or reactor trip will be initiated when the parameter monitored by each channel or combination thereof reaches its setpoints, 2) the specified coincidence logic and sufficient redundancy is maintained to permit a channel to be out of service for testing or maintenance consistent with maintaining an appropriate level of reliability of the Reactor Protection and Engineered Safety Features instrumentation and, 3) sufficient system functions capability is available from diverse parameters.

The OPERABILITY of these systems is required to provide the overall reliability, redundancy, and diversity assumed available in the facility design for the protection and mitigation of accident and transient conditions.

The integrated operation of each of these systems is consistent with-the assumptions used in the accident analyses. The surveillance requirements specified for these systems ensure that the overall system functional capability is maintained comparable to the original design standards. The periodic surveillance tests performed at the minimum frequencies are sufficient to demonstrate this capability. Specified surveillance and surveillance and maintenance outage times have been determined in accordance with WCAP-10271, "Evaluation oaf urveillance Frequencies and Out of Service Times for Reactor Protection Instrumentation System," and supplements to that report. Surveillance intervals and outofservice times were determined based on maintaining an appropriate level of reliability of the Reactor Protection m and Engineered Safety Features instrumentation.

Engineered Safety Feature Actuation System Instrumentation Trip Setpoints specified in Table 3.3-4 are the nominal values at which the bistables are set for each functional unit. A setpoint is considered to be adjusted consistent with the nominal value when the "as measured" setpoint is within the band allowed for calibration accuracy.

To accommodate the instrument drift assumed to occur between operational tests and the accuracy to which setpoints can be measured and calibrated, Allowable Values for the setpoints have been specified in Table 3.3-4.

Operation with setpoints less conservative than the Trip Setpoint but within the Allowable Value is acceptable since an allowance has been made in the safety analysis to accommodate this error.

The methodology to derive the trip setpoints is based upon combining all of the uncertainties in the channels. Inherent to the determination of the trip setpoints are the magnitudes of these channel uncertainties. Sensor and rack instrumentation utilized in these channels are expected to be capable of operating within the allowances of these uncertainty magnitudes. Rack drift in excess of the Allowable Value exhibits the behavior that the rack has not met its allowance. Being that there is a small statistical chance that this SUMMER -UNIT I B 3/4 3-1 Amendment No. b, 120

INSTRUMENTATION BASES 3/4.3.3.3 SEISMIC INSTRUMENTATION Deleted.

3/4.3.3.4 METEOROLOGICAL INSTRW1ENTATION The OPERABILITY of the meteorological Instrumentation ensures that sufficient meteorological data 1s available for estimating potential radiation doses to the public as a result of routine or accidental release of radioactive materials to the atmosphere.

This capability is required to evaluate the need for initiating protective measures to protect the health and safety of the public and is consistent with the. recommendations of Regulatory Guide 1.23,

Onsite Meteorological Programs,' February 1972.

3/4.3.3.5 REMOTF SHUTDOWN INSTRUMENTATTON

.1--

The OPERABILITY of the remote shutdown instrumentation ensures that sufficient capability is available to permit shutdown and maintenance of HOT STANDBY of the facility from locations outside of the control room.

This capability is required in the event control room habitability is lost and is consistent with General Design Criteria 19 of 10 CFR 50.

3/4.3.3.6 ACCIDENT MONITORING INSTRUMENTATION The PAM Instrumentation LCO provides OPERABILITY requirements for Regulatory Guide 1.97 Type A monitors, which provide information required to perform certain manual actions specified in the Emergency Operating Procedures.

These manual actions ensure that.a system can accomplish its safety function and are credited in the safety analyses.

Additionally, this LCD addresses Regulatory Guide 1.97 instruments that have been designated Category I, non-Type A.

The OPERABILITY of the PAM instrumentation ensures there is sufficient information available on selected unit parameters to monitor and assess unit status following an accident.

LCO 3.3.3.6 requires two OPERABLE channels for most Functions.

Two OPERABLE channels ensure no single failure prevents operators from getting the information necessary for them to determine the safety status of the unit, and to bring the unit to and maintain it in a safe condition following an accident.

J Furthermore, OPERABILITY of two channels allows a CHANNEL CHECK during the post accident phase to confirm the validity of displayed information.

SUMMER - UNIT 1 B 3/4 3-3 Amendment No. fi, 11g, 122

Document Control Desk 1 LAR 05-0677 RC-06-0024 Page 1 of 23 ATTACHMENT 11 PROPOSED TECHNICAL SPECIFICATION CHANGES (RETYPED)

INDEX DEFINITIONS SECTION PAGE 1.0 DEFINITIONS 1.1 ACTION.........................................................

1-1 1.2 ACTUATION LOGIC TEST........................................................

1-1 1.3 ANALOG CHANNEL OPERATIONAL TEST.................................................

1-1 1.4 AXIAL FLUX DIFFERENCE.........................................................

1-1 1.5 CHANNEL CALIBRATION........................................................

1-1 1.6 CHANNELCHECK.........................................................

1-1 1.7 CONTAINMENT INTEGRITY.........................................................

1-2 1.8 CONTROLLED LEAKAGE........................................................

1-2 1.9 CORE ALTERATION........................................................

1-2 1.9a CORE OPERATING LIMITS REPORT.1-2 1.10 DOSE EQUIVALENT 1-131.........................................................

1-2 1.11 E-AVERAGE DISINTEGRATION ENERGY..................................................

1-3 1.12 ENGINEERED SAFETY FEATURES RESPONSE TIME.............

1-3 1.13 FREQUENCY NOTATION........................................................

1-3 1.14 GASEOUS RADWASTE TREATMENT SYSTEM.........................................

1-3 1.15 IDENTIFIED LEAKAGE........................................................

1-3 1.16 MASTER RELAY TEST.........................................................

1-3 1.17 OFFSITE DOSE CALCULATION MANUAL (ODCM)....................................

1-4 1.18 ON-LINE MONITORING.........................................................

1-4 1.19 OPERABLE - OPERABILITY........................................................

1-4 1.20 OPERATIONAL MODE - MODE........................................................

1-4 1.21 PHYSICS TESTS.........................................................................

1-4 1.22 PRESSURE BOUNDARY LEAKAGE........................................................

1-4 1.23 PROCESS CONTROL PROGRAM (PCP)....................................................

1-5 1.24 PURGE-PURGING.........................................................

1-5 1.25 QUADRANT POWER TILT RATIC)..............................................................

1-5 1.26 RATED THERMAL POWER........................................................

1-5 1.27 REACTOR TRIP SYSTEM RESPONSE TIME...........................

1-5 1.28 REPORTABLE EVENT........................................................

1-5 1.29 SHUTDOWN MARGIN.........................................................

1-5 1.30 SLAVE RELAY TEST........................................................

1-5 1.31 DELETE........................................................

1-5 1.32 SOURCE CHECK...................

1-6 1.33 STAGGERED TEST BASIS...................

1-6 1.34 THERMAL POWER........................................................

1-6 1.35 TRIP ACTUATING DEVICE OPERATIONAL TEST......................................

1-6 1.36 UNIDENTIFIED LEAKAGE.........................................................

1-6 1.37 VENTILATION EXHAUST TREATMENT SYSTEM....................

1-6 1.38 VENTING........................................................

1-6 TABLE 1.1 OPERATIONAL MODES.1-7 TABLE 1.2 FREQUENCY NOTATION.1-8 SUMMER - UNIT 1 1

Amendment No. 35, 88,104,

DEFINITIONS OFFSITE DOSE CALCULATION MANUAL (ODCM) 1.17 The OFFSITE DOSE CALCULATION MANUAL (ODCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm/Trip Setpoints, and in the conduct of the Environmental Radiological Monitoring Program. The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs required by Section 6.8.4 and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by Specifications 6.9.1.6 and 6.9.1.8.

ON-LINE MONITORING 1.18 ON-LINE MONITORING is the assessment of channel performance and calibration while the channel is operating. ON-LINE MONITORING differs from CHANNEL CALIBRATION in that the channel is not adjusted by the process of ON-LINE MONITORING.

Instead, ON-LINE MONITORING compares channel performance to established acceptance criteria to determine if a CHANNEL CALIBRATION is necessary.

OPERABLE - OPERABILITY 1.19 A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s), and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s).

OPERATIONAL MODE - MODE 1.20 An OPERATIONAL MODE (i.e., MODE) shall correspond to any one inclusive combination of core reactivity condition, power level and average reactor coolant temperature specified in Table 1.1.

PHYSICS TESTS 1.21 PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation and 1) described in Chapter 14.0 of the FSAR, 2) authorized under the provisions of 10 CFR 50.59, or 3) otherwise approved by the Commission.

PRESSURE BOUNDARY LEAKAGE 1.22 PRESSURE BOUNDARY LEAKAGE shall be leakage (except steam generator tube leakage) through a non-isolable fault in a Reactor Coolant System component body, pipe wall or vessel wall.

SUMMER - UNIT 1 1-4 Amendment No. 4104, 117,

DEFINITIONS PROCESS CONTROL PROGRAM (PCP) 1.23 The PROCESS CONTROL PROGRAM (PCP) shall contain the current formulas, sampling, analyses, tests, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10 CFR Parts 20, 61, and 71, State regulations, burial ground requirements, and other requirements governing the disposal of solid radioactive waste.

PURGE - PURGING 1.24 PURGE or PURGING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is required to purify the confinement.

QUADRANT POWER TILT RATIO 1.25 QUADRANT POWER TILT RATIO shall be the ratio of the maximum upper excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater. With one excore detector inoperable, the remaining three detectors shall be used for computing the average.

RATED THERMAL POWER 1.26 RATED THERMAL POWER shall be a total reactor core heat transfer rate to the reactor coolant of 2900 MWt.

REACTOR TRIP SYSTEM RESPONSE TIME 1.27 The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip selpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC.

REPORTABLE EVENT 1.28 A REPORTABLE EVENT shall be any of those conditions specified in Section 50.73 to 10 CFR Part 50.

SHUTDOWN MARGIN 1.29 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all full length rod cluster assemblies (shutdown and control) are fully inserted except for the single rod cluster assembly of highest reactivity worth which is assumed to be fully withdrawn.

SLAVE RELAY TEST 1.30 A SLAVE RELAY TEST shall be the energization of each slave relay and verification of OPERABILITY of each relay. The SLAVE RELAY TEST shall include a continuity check, as a minimum, of associated testable actuation devices.

1.31 Not Used SUMMER - UNIT 1 1-5 Amendment No. 35, 104, 117-,

433, 446,

I DEFINITIONS SOURCE CHECK 1.32 A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source.

STAGGERED TEST BASIS 1.33 A STAGGERED TEST BASIS shall consist of:

a.

A test schedule for n systems, subsystems, trains or other designated components obtained by dividing the specified test interval into n equal subintervals,

b.

The testing of one system, subsystem, train or other designated component at the beginning of each subinterval.

Furthermore, for systems, subsystems, channels, or other designated components that are evaluated by ON-LINE MONITORING, all n systems, subsystems, channels, or other designated components will be tested at a frequency not to exceed 6 years, regardless of the size of n.

THERMAL POWER 1.34 THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

TRIP ACTUATING DEVICE OPERATIONAL. TEST 1.35 A TRIP ACTUATING DEVICE OPERATIONAL TEST shall consist of operating the Trip Actuating Device and verifying OPERABILITY of alarm, interlock and/or trip functions. The TRIP ACTUATING DEVICE OPERATIONAL. TEST shall include adjustment, as necessary, of the Trip Actuating Device such that it actuates at the required setpoint within the required accuracy.

UNIDENTIFIED LEAKAGE 1.36 UNIDENTIFIED LEAKAGE shall be.il leakage which is not-IDENTIFIED LEAKAGE or CONTROLLED LEAKAGE.

VENTILATION EXHAUST TREATMENT SYSTEM 1.37 A VENTILATION EXHAUST TREATMENT SYSTEM is any system designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and/or HEPA filters for the purpose of removing iodines or particulales from the gaseous exhaust stream prior to the release to the environment (such a system is not considered to have any effect on noble gas effluents). Engineered Safety Feature (ESF ) atmospheric cleanup systems are not considered to be VENTILATION EXHAUST TREATMENT SYSTEM components.

VENTING 1.38 VENTING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTING. Vent, used in system names, does not imply a VENTING process.

SUMMER - UNIT 1 1--6 Amendment No.

TABLE 4.3-1 REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS FUNCTIONAL UNIT

1.

Manual Reactor Trip

2.

Power Range, Neutron Flux High Setpoint Low Setpoint CHANNEL CHECK N.A.

CHANNEL CALIBRATION N.A.

ON-LINE MONITORING EVALUATION N.A.

ANALOG CHANNEL OPERATIONAL TEST N.A.

TRIP ACTUATING DEVICE OPERATIONAL TEST R(11)

ACTUATION LOGIC TEST N.A.

MODES FOR WHICH SURVEILLANCE IS REQUIRED 1,2,3*,4*, 5*

S S

D(2, 4),

M(3, 4),

Q(4, 6),

R(4, 5)

R(4)

N.A.

Q S/U(1)

N.A.

1, 2 1 "", 2 2

CD 0.

CDzp

3.

Power Range, Neutron Flux High Positive Rate

4.

Deleted

5.

Intermediate Range, Neutron Flux

6.

Source Range, Neutron Flux

7.

Overtemperature AT B.

Overpower AT

9.

Pressurizer Pressure--Low

10.

Pressurizer Pressure--High

11. Pressurizer Water Level--

High

12.

Loss of Flow N.A.

S R(4)

S S

R R

R(15)

R(1 5)

R(4)

N.A.

Q Q

Q S/U(1)

S/U(1), Q(9)

Q Q

N.A.

1, 2 1###, 2 2##, 3, 4, 5 1, 2 1, 2 1, 2 1

1

TABLE 4.3-1 (Continued)

REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS FUNCTIONAL UNIT

13.

Steam Generator Water Level--Low-Low

14.

Steam Generator Water Level - Low Coincident with Steam/Feedwater Flow Mismatch

15. Undervoltage - Reactor Coolant Pumps

16. Underfrequency - Reactor Cooiani Pumrips

17.

Turbine Trip A. Low Fluid Oil Pressure B. Turbine Stop Valve Closure

18.

Safety Injection Input from ESF CHANNEL CHECK S

CHANNEL CALIBRATION R(15)

ON-LINE MONITORING EVALUATION Q

ANALOG CHANNEL OPERATIONAL TEST Q

TRIP ACTUATING DEVICE OPERATIONAL TEST N.A.

ACTUATION LOGIC TEST N.A.

MODES FOR WHICH SURVEILLANCE IS REQUIRED 1,2 S

N.A.

R(1 5)

Q N.A.

N.A.

Q Q

N.A.

1, 2 I

I R

R N.A.

N.A N.A N.A.

R R

N.A.

S/U (1, 10)

R N.A.

N.A.

I 1

1, 2 N.A.

N.A.

19. Reactor Trip System Interlocks A. Intermediate Range Neutron Flux, P-6 N.A.

3 CD 0.

CD z0 B. Low Power Reactor Trips N.A.

Block, P-7 R(4)

R(4)

N.A.

R R

R N.A.

N.A.

1 1

C. Power Range Neutron Flux, P-8 N.A.

TABLE 4.3-1 (Continued)

(n m

z

--I REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL CHANNEL CHECK CALIBRATION ON-LINE MONITORING EVALUATION ANALOG CHANNEL OPERATIONAL TEST TRIP ACTUATING DEVICE OPERATIONAL TEST ACTUATION LOGIC TEST MODES FOR WHICH SURVEILLANCE IS REQUIRED FUNCTIONAL UNIT D. Low Setpoint Power Range Neutron Flux, P-10 E. Turbine Impulse Chamber Pressure, P-13 F. Low Power Range Neutron Flux, P-9

20.

Reactor Trip Breaker

21. Automatic Trip Logic N.A.

N.A.

R(4)

R(15)

N.A.

Q R

R N.A.

N.A.

1, 2 1

C;)

WA CA)

N.A.

R(4)

NA.

N.A.

R N.A.

N.A.

M(7, 12)

N.A.

M(7)

I

1. 2. 3*; 4*; 5*

1, 2, 3*, 4*, 5*

22.

Reactor Trip Bypass Breaker N.A.

N.A.

M(13), R(14)

N.A.

1, 2, 3*, 4*, 5*

3 CD 03 CL 3

CD z0

.A)

TABLE 4.3-1 (Continued)

TABLE NOTATION With the reactor trip system breakers closed and the control rod drive system capable of rod withdrawal.

Below P-6 (Intermediate Range Neutron Flux Interlock) setpoint.

f-Below P-10 (Low Setpoint Power Range Neutron Flux Interlock) setpoint.

(1)

If not performed in previous 31 days.

(2)

Comparison of calorimetric to excore power indication above 15% of RATED THERMAL POWER. Adjust excore channel gains consistent with calorimetric power if absolute difference is greater than :2 percent. The provisions of Specification 4.0.4 are not applicable for entry into MODE 2 or 1.

(3)

Single point comparison of incore to excore AXIAL FLUX DIFFERENCE above 15% of RATED THERMAL POWER. Recalibrate if the absolute difference is greater than or equal to 3 percent. The provisions of Specification 4.0.4 are not applicable for entry into MODE 2 or 1.

(4)

Neutron detectors may be excluded from CHANNEL CALIBRATION.

(5)

Detector plateau curves shall be obtained evaluated and compared to manufacturer's data. For the Power Range Neutron Flux Channels the provisions of Specification 4.0.4 are not applicable for entry into MODE 2 or 1.

(6)

Incore - Excore Calibration, above 75% of RATED THERMAL POWER. The provisions of Specification 4.0.4 are not applicable for entry into MODE 2 or 1.

(7)

Each train shall be tested at least every 62 days on a STAGGERED TEST BASIS.

(8)

DELETED (9)

Quarterly Surveillance in MODES 3*, 4* and 5* shall also include verification that permissives P-6 and P-10 are in their required state for existing plant conditions by observation of the permissive annunciator window.

(10) -

Setpoint verification is not required.

(1 1) -

The TRIP ACTUATING DEVICE OPERATIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip circuits for the Manual Reactor Trip Function. The test shall also verify the OPERABILITY of the Bypass Breaker trip circuit(s).

(12) -

The TRIP ACTUATING DEVICE OPERATIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip attachments of the Reactor Trip Breakers.

(13) -

Local manual shunt trip prior to placing breaker in service.

(14) -

Automatic undervoltage trip.

(15) -

For Channels evaluated by ON-LINE MONITORING, a formal surveillance evaluation shall be performed to verify that no channels are outside the prescribed acceptance limits on a quarterly basis. At least one redundant transmitter will be calibrated every 18 months on a STAGGERED TEST BASIS, with each channel calibrated at least once per every 6 years.

SUMMER - UNIT 1 3/4 3-14 Amendment No. 73, 7-8, 10Q1,

CD I;

CK l

LC z

IrI1_

TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION

- m TOTAL NO.

OF CHANNELS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE FUNCTIONAL UNIT APPLICABLE MODES 1, 2, 3##

ACTION 24*

f. Steam Line Pressure-Low 1 pressure/

loop 1 pressure any 2 loops 1 pressure any 2 loops I

2. REACTOR BUILDING SPRAY

a. Manual

-I

b. Automatic Actuation Logic and Actuation Relays

c. Reactor Building Pressure -

High-3 (Phase 'A' isolation aligns spray system discharge valves and NaOH tank suction valves) 2 sets - 2 switf hMO/0tf 2

4 1 set 2 sets 1, 2, 3, 4 1

2 3

1, 2, 3, 4 1, 2, 3 18 14 16 2

3 CD 0.

3 CD z0

0)C m

z TABLE 4.3-2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS CA)

CD 03 CD Z

pI CHAI FUNCTIONAL UNIT CHEI I. SAFETY INJECTION, REACTOR TRIP, FEEDWATER ISOLATION, CONTROL ROOM ISOLATION START DIESEL GENERATORS, CONTAINMENT COOLING FANS AND ESSENTIAL SERVICE WATER

a. Manual Initiation N.A.

b. Automatic Actuation Logic N.A.

and Actuation Relays

c. Reactor Building S

Pressure-High-1

d. Pressurizer Pressure-Low S

e. Differential Pressure S

Between Steam Lines-High

f. Steam Line Pressure Low S

2. REACTOR BUILDING SPRAY

a. Manual Initiation N.A.

b. Automatic Actuation Logic N.A.

and Actuation Relays

c. Reactor Building S

Pressure-High-3 N.A..

N.A.

R(3)

R R

N.A.

R(3)

N.A.

Q Q

N.A.

Q ON-LINE iNNEL CHANNEL MONITORING rCK CALIBRATION EVALUATION ANALOG CHANNEL OPERA-TIONAL TEST N.A.

N.A.

Q Q

N.A N.A Q

R N.A.

N.A.

R N.A.

N.A.

M(1)

N.A.

M(1)

N.A.

M(1)

N.A N.A.

N.A.

N.A N.A.

M(1)

N.A.

TRIP ACTUATING DEVICE MODES FOR OPERA-ACTUATION MASTER SLAVE WHICH TIONAL LOGIC RELAY RELAY SURVEILLANCE TEST TEST TEST TEST IS REQUIRED N.A.

1,2,3,4 Q

1,2,3,4 N.A.

1,2,3 N.A 1,2,3 N.A 1,2,3 N.A 1,2,3 N.A.

1,2,3,4 Q

1,2,3,4 N.A.

1,2,3

(I)

C m

Cz TABLE 4.3-2 Continued ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS ON-LINE CHANNEL CHANNEL MONITORING CHECK CALIBRATION EVALUATION ANALOG CHANNEL OPERA-TIONAL TEST TRIP ACTUATING DEVICE OPERA-TIONAL TEST ACTUATION LOGIC TEST MASTER RELAY TEST SLAVE RELAY TEST MODES FOR WHICH SURVEILLANCE IS REQUIRED 0)

FUNCTIONAL UNIT

3. CONTAINMENT ISOLATION

a. Phase 'A' Isolation

1) Manual

2) Safety Injection

3) Automatic Actuation Logic and Actuation Relays

b. Phase "B" Isolation

1) Automatic Actuation Logic and ?ctuation Relays

2) Reactor Building Pressure-High-3

c. Purge and Exhaust Isolation

1) Automatic Actuation Logic and Actuation Relays

2) Containment Radioactivity-High

3) Safety Injection N.A.

N.A.

R N.A.

N.A.

See 1 above for all Safety Injection Surveillance Requirements.

N.A.

S N.A.

N.A.

R(3)

N.A.

Q N.A.

N.A.

Q N.A.

M N.A.

N.A.

M(1)

N.A.

M(1)

N.A.

M(1)

N.A.

M(1)

N.A.

Q 1,2,3,4 Q

1,2,3,4 N.A.

1,2,3 Q(2) 1,2,3,4 N.A.

1,2,3,4 N.A.

1,2,3,4 CD 3CD z

0

( Yn I.

-4 S

R See I above for all Safety Injection Surveillance Requirements.

CO, C

m Cz TABLE 4.3-2 (Continued)

ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS FUNCTIONAL UNIT

4. STEAM LINE ISOLATION

a. Manual

b. Automatic Actuation Logic and Actuation Relays

c. Reactor Building Pressure-High-2

d. Steam Flow in Two Steam Lines-High Coincident with Tav--Low-Low

e. Steam Line Pressure Low

5. TURBINE TRIP AND FEEDWATER ISOLATION

a. Steam Generator Water Level-High-High

b. Automatic Actuation Logic and Actuation Relay

6. EMERGENCY FEEDWATER

a. Manual

b. Automatic Actuation Logic and Actuation Relays

c. Steam Generator Water Level--Low-Low CHANNEL CHANNEL CHECK CALIBRATION ON-LINE MONITORING EVALUATION ANALOG CHANNEL OPERA-TIONAL TEST TRIP ACTUATING DEVICE OPERA-TIONAL TEST ACTUATION LOGIC TEST N.A.

N.A.

S R(3)

S S

S R(3)

-(3 R(3)

N.A.

Q a

Q Q

Q N.A.

N.A.

Q N.A.

N.A.

0 Q

Q Q

Q N.A N.A.

N.A.

Q R

N.A.

R N.A.

N.A.

M(1)

N.A.

M(1)

N.A.

M(1)

N.A.

MASTER RELAY TEST N.A.

M(1)

N.A.

M(1)

N.A.

M(1)

N.A.

SLAVE RELAY TEST N.A.

1,2,3 Q

1,2,3 N.A.

1,2 Q

1,2 N.A.

1,2,3 Q

1,2,3 N.A.

1,2,3 MODES FOR WHICH SURVEILLANCE IS REQUIRED S

R(3) 2 CD CD I-#.

z0 N.A.

N.A.

S N.A.

N.A.

R(3)

C,,

C m

3, TABLE 4.3-2 (Continued)

ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS Cz

--I ON-LINE CHANNEL CHANNEL MONITORING CHECK CALIBRATION EVALUATION ANALOG CHANNEL OPERA-TIONAL TEST TRIP ACTUATING DEVICE OPERA-TIONAL TEST ACTUATION LOGIC TEST MASTER RELAY TEST SLAVE RELAY TEST MODES FOR WHICH SURVEILLANCE IS REQUIRED FUNCTIONAL UNIT EMERGENCY FEEDWATER (Continued)

d. Undervoltage - Both ESF Busses

e. Safety Injection

f.

Undervoltage - One ESF Bus Trinp nf Maimn Feeed.a'.er Pumps

h. Suction Transfer on Low Pressure N.A.

R N.A.

N.A.

R N.A.

N.A.

1,2,3 See I above for all Safety Injection Surveillance Requirements to N.A.

NI A S

R N.A.

hi A 1I'.M.

L.I1.

N.A.

Q R

R N.A.

N.A.

1,2,3 N.A.

1,2 N.A.

1,2,3 R

N.A.

7. LOSS OF POWER 3

CD a-CD

3 z

0

a. 7.2 kV Emergency Bus Undervoltage (Loss of Voltage)

b. 7.2 kV Emergency Bus Undervoltage (Degraded Voltage)

8. AUTOMATIC SWITCHOVER TO CONTAINMENT SUMP

a. RWST level low-low

b. Automatic Actuation Logic and Actuation Relays N.A.

N.A.

R N.A.

N.A.

R N.A.

N.A.

R N.A.

N.A.

1,2,3,4 N.A.

1,2,3,4 S

R(3)

N.A.

Q N.A.

N.A.

M(1)

N.A M(1)

N.A.

1,2,3 Q

1,2,3 N.A.

=1)

TABLE 4.3-2 (Continued)

ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHAI FUNCTIONAL UNIT CHEI

9. ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INTERLOCKS

a. Pressurizer Pressure, P-1l N.A.

b. Low, LowTavg, P-12 N.A.

c. Reactor Trip, Pa N.A.

ON-LINE 4JNEL CHANNEL MONITORING iK CALIBRATION EVALUATION ANALOG CHANNEL OPERA-TIONAL TEST Q

Q N.A.

TRIP ACTUATING DEVICE MODES FOR OPERA-ACTUATION MASTER SLAVE WHICH TIONAL LOGIC RELAY RELAY SURVEILLANCE TEST TEST TEST TEST IS REQUIRED R(3)

R N.A.

Q N.A.

N.A.

R N.A.

N.A.

1,2,3 N.A.

1,2,3 co CD CD z

-P

INSTRUMENTATION TABLE 4.3-2 (Continued)

TABLE NOTATION (1)

Each train shall be tested at least every 62 days on a STAGGERED TEST BASIS.

(2)

The 36 inch containment purge supply and exhaust isolation valves are sealed closed during Modes 1 through 4, as required by TS 3.6.1.7. With these valves sealed closed, their ability to open is defeated; therefore, they are excluded from the quarterly slave relay test.

(3)

For channels evaluated by ON-LINE MONITORING, a formal surveillance check shall be performed to verify that no channels are outside the prescribed acceptance limits on a quarterly basis.

At least one redundant transmitter will be calibrated every 18 months on a STAGGERED TEST BASIS, with all channels calibrated at least once per every 6 years.

SUMMER - UNIT 1

3/4 3-40 Amendment No. 42&,

INSTRUMENTATION METEOROLOGICAL INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.4 The meteorological monitoring instrumentation channels shown in Table 3.3-8 shall be OPERABLE.

APPLICABILITY:

At all times.

ACTION:

a.

With one or more required meteorological monitoring channels inoperable for more than 7 days, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next 10 days outlining the cause of the malfunction and the plans for restoring the channel(s) to OPERABLE status.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.4 Each of the above meteorological monitoring instrumentation channels shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION, and ON-LINE MONITORING evaluation operations at the frequencies shown in Table 4.3-5.

SUMMER - UNIT 1

3/4 3-50 Amendment No.

INSTRUMENTATION TABLE 4.3-5 METEOROLOGICAL MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL INSTRUMENT CHECK CHANNEL CALIBRATION ON-LINE MONITORING EVALUATION

1.

Wind Speed a.

b.

Wind Speed Lower 1 Om Wind Speed Upper 61 m D

D SA(1)

SA(1)

Q Q

2.

Wind Direction a.

b.

Wind Direction Lower 1 Om Wind Direction Upper 61m D

D SA(1)

SA (1)

Q Q

3.

Atmospheric Stability a.

b.

Delta T 1 10-61m Delta T 2 10-40m D

D SA(1)

SA(1)

Q Q

Elevations nominal above grade elevation TABLE NOTATION (1) For channels evaluated by ON-LINE MONITORING, a formal surveillance check shall be performed to verify that no channels are outside the prescribed acceptance limits on a quarterly basis.

All field mounted sensors will be calibrated every 36 months.

SUMMER - UNIT 1 3/4 3-52 Amendment No.

INSTRUMENTATION REMOTE SHUTDOWN INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.5 The remote shutdown monitoring instrumentation channels shown in Table 3.3-9 shall be OPERABLE with readouts displayed external to the control room.

APPLICABILITY:

MODES 1, 2 and 3.

ACTION:

a.

With the number of OPERABLE: remote shutdown monitoring channels less than required by Table 3.3-9, restore the inoperable channel to OPERABLE status within 7 days, or be in HOT SHIJTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b.

The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.5 Each remote shutdown monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, CHANNEL CALIBRATION, or ON-LINE MONITORING evaluation operations at the frequencies shown in Table 4.3-6.

SUMMER - UNIT 1

314 3-53 Amendment No.

Cn TABLE 4.3-6 m

REMOTE SHUTDOWN MONITORING INSTRUMENTATION C

SURVEILLANCE REQUIREMENTS z

-I ON-LINE CHANNEL CHANNEL MONITORING INSTRUMENT CHECK CALIBRATION EVALUATION

1.

Reactor Trip Breaker Indication M

N.A N.A

2.

Pressurizer Pressure M

R(1)

Q

3.

Pressurizer Level M

R(1)

Q

4.

Steam Generator Pressure M

R(1)

Q X

5.

Steam Generator Level M

R(1)

Q en

6.

Condensate Storage Tank Level M

R N.A

7.

Reactor Coolant System Hot Leg Temperature M

R N.A

8.

Reactor Coolant System Cold Leg Temperature M

R N.A

9.

Reactor Coolant System Pressure M

R(1)

Q

10.

Pressurizer Relief Tank Level M

R N.A

11.

Reactor Building Temperature M

R N.A 2

CD

12.

Boric Acid Tank Level M

R N.A 0.

cL 3

TABLE NOTATION CD (1) For channels evaluated by ON-LINE MONITORING, a formal surveillance check shall be performed to verify that no channels o

are outside the prescribed acceptance limits on a quarterly basis.

At least one redundant transmitter will be calibrated every 18 months on a STAGGERED TEST BASIS, with all channels calibrated at least once per every 6 years.

INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.6 The accident monitoring instrumentation channels shown in Table 3.3-10 shall be OPERABLE.

APPLICABILITY MODES 1, 2, and 3.

ACTION:

a.

With the number of OPERABLE accident monitoring channels less than the Required Number of Channels shown on Table 3.3-10, either restore the inoperable channel(s) to OPERABLE status within 30 days or submit a Special Report within the following 14 days from the time the action is required. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels to OPERABLE status.

b.1 With the number of OPERABLE Reactor Building radiation monitoring channels less than the Minimum Channels Operable requirement of Table 3.3-10, either restore the inoperable channel(s) to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or:

i)

Initiate the preplanned alternate method of monitoring the appropriate parameter(s), and ii)

Submit a Special Report to the Commission pursuant to Specification 6.9.2 within 14 days following the event outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status.

b.2 Dejeted b.3 With the number of OPERABLE accident monitoring channels less than the Minimum Channels Operable requirement of Table 3.3-10, either restore the inoperable channels to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

c.

The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.6 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performing a monthly CHANINEL CHECK and a CHANNEL CALIBRATION every refueling outage. For channels evaluated by ON-LINE MONITORING, a formal surveillance evaluation shall be performed to verify that no channels are outside the prescribed acceptance limits on a quarterly basis. At least one redundant transmitter will be calibrated every 18 months on a STAGGERED TEST BASIS, with each channel calibrated at least once per every 6 years. The Reactor Building Radiation Level Instrumentation CHANNEL CALIBRATION may consist of an electronic calibration of the channel, not including the detector, for the range decades above I OR/hr and a single point calibration of the detector below 1 OR/hr with an installed or portable gamma source.

SUMMER - UNIT 1 3/4 3-56 Amendment No. 18-, 1 70,

3/4.3 INSTRUMENTATION BASES 3/4.3.1 and 3/4.3.2 REACTOR TRIP AND ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION The OPERABILITY of the Reactor Protection System and Engineered Safety Feature Actuation System Instrumentation and interlocks ensure that 1) the associated action and/or reactor trip will be initiated when the parameter monitored by each channel or combination thereof reaches its setpoints, 2) the specified coincidence logic and sufficient redundancy is maintained to permit a channel to be out of service for testing or maintenance-consistent with maintaining an appropriate level of reliability of the Reactor Protection and Engineered Safety Features instrumentation and, 3) sufficient system functions capability is available from diverse parameters.

The OPERABILITY of these systems is required to provide the overall reliability, redundancy, and diversity assumed available in the facility design for the protection and mitigation of accident and transient conditions. The integrated operation of each of these systems is consistent with the assumptions used in the accident analyses. The surveillance requirements specified for these systems ensure that the overall system functional capability is maintained comparable to the original design standards. The periodic surveillance tests performed at the minimum frequencies are sufficient to demonstrate this capability. Specified surveillance and surveillance and maintenance outage times have been determined in accordance with WCAP-10271, "Evaluation of Surveillance Frequencies and Out of Service Times for Reactor Protection Instrumentation System," and supplements to that report.

Surveillance intervals and out of service times were determined based on maintaining an appropriate level of reliability of the Reactor Protection System and Engineered Safety Features instrumentation.

EPRI Technical Report, TR-1 04965, IRev 1, provides an alternative methodology fcr extending the calibration interval for safety-related instrumentation. The maximum an instrument calibration can be extended is to 16 years with at least one of the redundant instruments calibrated every 18 months. This methodology is based on the ON-LINE MONITORING system, which performs quarterly assessments of channel performance and can detect very small changes in instrument performance or drift.

The Engineered Safety Feature Actuation System Instrumentation Trip Setpoints specified in Table 3.3-4 are the nominal values at which the bistables are set for each functional unit. A setpoint is considered to be adjusted consistent with the nominal value when the "as measured" setpoint is within the band allowed for calibration accuracy.

To accommodate the instrument drift assumed to occur between operational tests and the accuracy to which setpoints can be measured and calibrated, Allowable Values for the setpoints have been specified in Table 3.3-4. Operation with setpoints less conservative than the Trip Setpoint but within the Allowable Value is acceptable since an allowance has been made in the safety analysis to accommodate this error.

The methodology to derive the trip setpoints is based upon combining all of the uncertainties in the channels. Inherent to the determination of the trip setpoints are the magnitudes of these channel uncertainties. Sensor and rack instrumentation utilized in these channels are expected to be capable of operating within the allowances of these uncertainty magnitudes. Rack drift in excess of the Allowable Value exhibits the behavior that the rack has not met its allowance. Being that there is a small statistical chance that this SUMMER - UNIT 1 B 3/4 3-1 Amendment No. 101, 120,

INSTRUMENTATION BASES 3/4.3.3.3 SEISMIC INSTRUMENTATION Deleted.

3/4.3.3.4 METEOROLOGICAL INSTRUMENTATION The OPERABILITY of the meteorological instrumentation ensures that sufficient meteorological data is available for estimating potential radiation doses to the public as a result of routine or accidental release of radioactive materials to the atmosphere. This capability is required to evaluate the need for initiating protective measures to protect the health and safety of the public and is consistent with the recommendations of Regulatory Guide 1.23, "Onsite Meteorological Programs," February 1972.

The application of EPRI TR-1 04965 to the meteorological instrumentation is consistent with the intent of the EPRI report, although it is outside the scope of the published report. The extension of calibration frequencies for these instruments will be controlled by the same requirements as the safety-related instruments in 3.3.1 and 3.3.2.

3/4.3.3.5 REMOTE SHUTDOWN INSTRUMENTATION The OPERABILITY of the remote shutdown instrumentation ensures that sufficient capability is available to permit shutdown and maintenance of HOT STANDBY of the facility from locations outside of the control room. This capability is required in the event control room habitability is lost and is consistent with General Design Criteria 19 of 10 CFR 50.

3/4.3.3.6 ACCIDENT MONITORING INSTRUMENTATION The PAM Instrumentation LCO provides OPERABILITY requirements for Regulatory Guide 1.97 Type A monitors, which provide information required to perform certain manual actions specified in the Emergency Operating Procedures. These manual actions ensure that a system can accomplish its safety function and are credited in the safety analyses.

Additionally, this LCO addresses Regulatory Guide 1.97 instruments that have been designated Category I, non-Type A.

The OPERABILITY of the PAM instrumentation ensures there is sufficient information available on selected unit parameters to monitor and assess unit status following an accident.

LCO 3.3.3.6 requires two OPERABLE channels for most Functions. Two OPERABLE channels ensure no single failure prevents operators from getting the information necessary for them to determine the safety status of the unit, and to bring the unit to and maintain it in a safe condition following an accident.

Furthermore, OPERABILITY of two channels allows a CHANNEL CHECK during the post accident phase to confirm the validity of displayed information.

SUMMER - UNIT 1 B 3/4 3-3 Amendment No. 79, 118,

412,

Document Control Desk Attachment IlIl LAR 05-0677 RC-06-0024 Page 1 of 9 ATTACHMENT III LIST OF REGULATORY COMMITMENTS As part of its acceptance of on-line monitoring, the NRC Safety Evaluation (SE) for EPRI Topical Report TR-104965, Revision 1, provides 14 requirements that must be addressed in the implementation process. The NRC SE provides additional clarification for each requirement that should also be reviewed to ensure a complete understanding of the requirement.

Each SE requirement is provided in its entirety, followed by a discussion of how this submittal addresses the requirement.

Amplifying information to support the discussion is located in the EPRI Implementation Guidelines, Attachments IV & V to this LAR.

Requirement I The submittal for implementation of the on-line monitoring technique shall confirm that the impact on plant safety of the deficiencies inherent in the on-line monitoring technique (inaccuracy in process parameter estimate, single-point monitoring, and untraceability of accuracy to standards), on plant safety will be insignificant, and that all uncertainties associated with the process parameter estimate have been quantitatively bounded and accounted for either in the on-line monitoring acceptance criteria or in the applicable setpoint and uncertainty calculations.

Discussion for Requirement 1:

The methodology provided in Section 6 of reference 7.3 (Applications to Nuclear Power Plant Technical Specification Instrumentation) is intended specifically to comply with Requirement 1. The uncertainties associated with the process parameter estimate and the single-point monitoring issue, have been quantified to a high degree of confidence.

Argonne National Laboratory (ANL), Expert Microsystems, the University of Tennessee, and others have developed uncertainty analysis tools to quantify the uncertainty of the process parameter estimate. These tools and techniques are applicable broadly to parameter estimation models developed for on-line monitoring (OLM) applications. The initial uncertainty analysis technique development was funded as part of the Department of Energy's Nuclear Energy Plant Optimization (NEPO) program. Further development of the uncertainty analysis tool has been funded by the Department of Energy's Office of Nuclear Science. These tools have been embedded in the OLM System software used at VCSNS. The numerical analysis methodology for the uncertainty tool is derived in part from the original Plant Specific Uncertainty Analysis conducted by ANL specifically for VCSNS. A description and discussion of the ANL methodology can be found in Appendix E of reference 7.3.

Document Control Desk Attachment IlIl LAR 05-0677 RC-06-0024 Page 2 of 9 The "untraceability of accuracy to standards" referenced in Requirement 1 is believed to refer to the inability to trace the software parameter estimate directly to an accepted standard. However, the software parameter estimate is indirectly traceable to known standards and as such does not give rise to a negative impact on plant safety. The traditional determination and verification of measurement accuracy through a series of qualified traceable comparisons to national standards does not apply directly to this methodology. An integrated approach is used to connect accuracy, traceability, and standards at several levels of the monitoring process.

Traceability of accuracy to reference standards has been maintained by the very nature of the on-line monitoring implementation approach. The calibration frequency has been extended, not eliminated. The determination of accuracy for the on-line monitoring process is therefore derived by an integration of known inputs with traceable accuracy and the application of advanced numerical methods to quantify the uncertainty of the processing of those traceable inputs. The numerical analysis methods that have been developed to quantify the accuracy or uncertainties associated with the on-line monitoring method are traceable to standards indirectly through the process of scientific research, development, application, and review by independent industry experts. This process is conducted at all levels within applicable industry standards.

Section 5 of reference 7.3 addresses single-point monitoring in detail and the results are incorporated into Section 6 as part of the on-line monitoring drift allowance calculation.

The intent is to maintain traceability to the allowances provided in the associated setpoint calculation. All uncertainties are quantified and bounded by the OLM acceptance criteria that are derived from the setpoint calculations. The approach taken will have no impact on either the trip setpoint or the allowable value in the Technical Specifications.

Requirement 2 Unless the licensee can demonstrate otherwise, instrument channels monitoring processes that are always at the low or high end of an instrument's calibrated span during normal plant operation shall be excluded from the on-line monitoring program.

Discussion for Requirement 2:

VCSNS will not be including any instrument channels that normally indicate at either extreme of span into the on-line monitoring population.

Section 5 of reference 7.3 provides detailed information that confirms the basis for Requirement 2.

Section 3.1 of reference 7.3 summarizes the applications that are considered suitable candidates for on-line monitoring.

Section 3.2 summarizes the types of applications that are not typically considered suitable for on-line monitoring.

The basis for this determination is provided in Section 5.

In the EPRI TR, the Reactor Building Pressure indication is not typically considered suitable for on-line monitoring.

However, VCSNS utilizes narrow range pressure transmitters for the Reactor Building pressure protection channels. These narrow range

Document Control Desk Attachment IlIl LAR 05-0677 RC-06-0024 Page 3 of 9 instruments are set such that at normal operating conditions, the indication is approximately 25 percent of span. This value is sufficiently far enough from the extreme low or high end of the instruments calibrated span that it is suitable for on-line monitoring. In addition, the operating or monitored point is approximately 15% of span from the initial setpoint for Reactor Building pressure.

Requirement 3 The algorithm used for on-line monitoring shall be able to distinguish between the process variable drift (actual process going up or down) and the instrument drift and shall be able to compensate for uncertainties introduced by unstable process, sensor locations, non-simultaneous measurements, and noisy signals. If the implemented algorithm and its associated software cannot meet these requirements, administrative controls, including the guidelines in Section 3 of the technical report for avoiding a penalty for non-simultaneous measurement, could be implemented as an acceptable means to ensure that these requirements are met satisfactorily.

Discussion for Requirement 3:

VCS has selected ExpertMicro Systems "SureSense Diagnostic Monitoring Studio" software as its preferred on-line monitoring method. SureSense is capable of utilizing several types of algorithms that are menu selectable in order to optimize individual model performance.

For example, redundant sensor averaging methods and multivariable kernel regression methods are provided. The EPRI TR specifically addressed parameter estimation algorithms of these two types. SureSense also implements other parameter estimation methods, such as first principle models; however, redundant sensor averaging methods and multivariable kernel regression methods are the primary techniques that will be used by VCSNS.

Each parameter estimation model is specifically trained to recognize normal behavior as well as specific operating states regardless of the algorithm selected. The program distinguishes readily between a process change and an instrument drift. Noisy signals and measurement lead/lag relationships are accommodated by the model training procedures provided within SureSense. Detailed EPRI Technical Report 1003661 (Reference 7.5), Plant System Modeling Guidelines to Implement On-Line Monitoring, provides specific guidance for a SureSense type application. VCSNS will be using the guidance provided in EPRI Technical Report 1003661 and updated user manuals provided by the software vendor.

Requirement 4 For instruments that were not included in the EPRI drift study, the value of the allowance or penalty to compensate for single-point monitoring must be determined by using the instrument's historical calibration data and by analyzing the instrument performance over its range for all modes of operation, including startup, shutdown, and plant trips. If the required data for such a determination is not available, an evaluation demonstrating that the instrument's relevant performance specifications are as good as or better than those of a similar instrument included in the EPRI drift study, will permit a licensee to

Document Control Desk Attachment Ill LAR 05-0677 RC-06-0024 Page 4 of 9 use the generic penalties for single-point monitoring given in EPRI Technical Report 104965.

Discussion for Requirement 4:

Section 5 of reference 7.3 provides detailed information regarding single-point monitoring. VCSNS, in order to satisfy the criteria stated in NRC Requirement 4, will use the generic penalties provided in Section 5. Section 5 discusses the EPRI drift study to explain why the results are likely to be more conservative than necessary for most applications.

Section 5 also provides detailed information explaining how to perform a plant-specific analysis for a single-point monitoring allowance. All applicable safety-related VCSNS instrumentation is enveloped by this technical report. All VCSNS safety-related instrumentation is fully represented by instrument manufacturer, model number, configuration, and ranges as those utilized in the EPRI drift study. In the event that VCSNS would choose in the future to utilize plant-specific values for the single-point monitoring allowance a formal design basis engineering calculation would be performed utilizing the EPRI guidance.

Requirement 5 Calculations for the acceptance criteria defining the proposed three zones of deviation

("acceptable," Oneeds calibration, "and "inoperable) should be done in a manner consistent with the plant-specific safety-related instrumentation setpoint methodology so that using on-line monitoring technique to monitor instrument performance and extend its calibration interval will not invalidate the setpoint calculation assumptions and the safety analysis assumptions. If new or different uncertainties require the recalculation of instrument trip setpoints, it should be demonstrated that relevant safety analyses are unaffected. The licensee should have a documented methodology for calculating acceptance criteria that are compatible with the practice described in Regulatory Guide 1.105 and the methodology described in acceptable industry standards for TSP and uncertainty calculations.

Discussion for Requirement 5:

VCSNS will establish the acceptance criteria for each instrument through the application of formal design calculations. Each calculation will be based on the methodology established in Section 6 of reference 7.3 and will incorporate the applicable values for uncertainties and utilize the licensed setpoint methodology currently in use. The methodology provided in Section 6 ensures that setpoint calculation and safety analysis assumptions are unchanged. A clear basis for the on-line monitoring drift allowance has been established so that setpoint calculations at VCSNS will not require revision. The Technical Specification trip setpoint and allowable value requirements are also unaffected because the methodology deliberately ensures compliance with the setpoint calculations.

Unique uncertainties attributed to on-line monitoring or single-point monitoring are used to reduce the on-line monitoring drift allowance to ensure that the setpoint calculations do not require revision.

Requirement 6

Document Control Desk Attachment III LAR 05-0677 RC-06-0024 Page 5 of 9 For any algorithm used, the maximum acceptable value of deviation (MA VD) shall be such that accepting the deviation in the monitored value anywhere in the zone between PE and MA VD will provide high confidence (level of 95%/O/95%o) that drift in the sensor-transmitter or any part of an instrument channel that is common to the instrument channel and the on-line monitoring loop is less than or equal to the value used in the setpoint calculations for that instrument channel.

Discussion for Requirement 6:

The calculation method described in Section 6 of reference 7.3 ensures the MAVD provides a high confidence level that is entirely consistent with the setpoint calculations.

The allowance for drift has been conservatively determined without taking credit for non-sensor related uncertainty terms. The on-line monitoring allowance for drift is further reduced to account for unique uncertainty elements introduced by the use of on-line monitoring. In the approach taken each of these elements are both independent from each other and from the specific parameter estimation algorithm used. The single-point monitoring values have been established in Section 5. The uncertainty values for the parameter estimate are established by a numerical analysis program specifically designed to analyze each parameter estimation model. The numerical analysis methodology for the uncertainty tool is derived from the original Plant Specific Uncertainty Analysis conducted by ANL specifically for VCSNS. A description and discussion of the ANL methodology can be found in Appendix E of reference 7.3.

Requirement 7 The instrument shall meet all requirements of the above requirement 6 for the acceptable band or acceptable region.

Discussion for Requirement 7:

The same basis for Requirement 6 applies to this region.

Requirement 8 For any algorithm used, the maximum value of the channel deviation beyond which the instrument is declared "inoperable shall be listed in the technical specifications with a note indicating that this value is to be used for determining the channel operability only when the channel's performance is being monitored using an on-line monitoring technique. It could be called "allowable deviation value for on-line monitoring" (ADVOL M) or whatever name the licensee chooses. The ADVOLM shall be established by the instrument uncertainty analysis. The value of the ADVOLM shall be such to ensure:

(a) that when the deviation between the monitored value and its PE is less than or equal to the ADVOLM limit, the channel will meet the requirements of the current technical specifications, and the assumptions of the setpoint calculations and safety analyses are satisfied; and' (b) that until the instrument channel is recalibrated (at most until the next refueling outage), actual drift in the sensor-transmitter or any part of an instrument channel that is common to the instrument channel and the on-line monitoring

Document Control Desk Attachment IlIl LAR 05-0677 RC-06-0024 Page 6 of 9 loop will be less than or equal to the value used in the setpoint calculations and other limits defined in 10 CFR 50.36 as applicable to the plant specific design for the monitored process variable are satisfied.

Discussion for Requirement 8:

Section 6 of reference 7.3 establishes the methodology for calculating the on-line monitoring drift allowance limits. The methodology has been defined in a manner that ensures the associated setpoint calculation allowances remain unchanged. This is an important part of the OLM System implementation process because the intent is to ensure negligible risk and to minimize the changes necessary to the Technical Specifications.

Accordingly, the on-line monitoring drift allowance ensures that the Technical Specification trip setpoint and allowable value for each parameter remain unchanged.

The on-line monitoring quarterly surveillance ensures that 1) the OLM System performance is acceptable and :2) each monitored parameter is operating within the acceptable limits of the current setpoint values. The on-line monitoring acceptance criteria, including the MAVD and the ADVOLM, will be provided in a quarterly surveillance procedure and formally documented in design basis engineering calculations.

Including this information in the body of the Technical Specifications should not be necessary; this information is more appropriately assigned to the surveillance procedures and design basis documents. This is no different in concept than providing acceptable as-found settings and as-left settings for instrument calibrations in the associated calibration documents.

Requirement 9 Calculations defining alarm setpoint (if any), acceptable band, the band identifying the monitored instrument as needing to be calibrated earlier than its next scheduled calibration, the maximum value of deviation beyond which the instrument is declared "inoperable, "and the criteria for determining the monitored channel to be an Moutlier, "

shall be performed to ensure that all safety analysis assumptions and assumptions of the associated setpoint calculation are satisfied and the calculated limits for the monitored process variables specified by, 10 CFR 50.36 are not violated.

Discussion for Requirement 9:

Section 6 of reference 7.3 establishes the methodology for calculating the on-line monitoring drift allowance criteria for each instrument. Formal design calculations will determine the values for the "maximum acceptable value of deviation" (MAVD) and the "allowable deviation for on-line-monitoring" (ADVOLM) for each instrument. The methodology has been defined in a manner that ensures the associated setpoint calculation allowances remain unchanged and that all assumptions of the associated setpoint calculation are satisfied and the calculated limits for the monitored process variables specified by 10 CFR 50.36 are not violated. The methodology ensures compliance with the above requirement.

Document Control Desk Attachment IlIl LAR 05-0677 RC-06-0024 Page 7 of 9 Requirement 10 The plant specific submittal shall confirm that the proposed on-line monitoring system will be consistent with the plant's licensing basis, and that there continues to be a coordinated defense in-depth against instrument failure.

Discussion for Requirement 10:

The VCSNS OLM System is in full compliance with this requirement. The application of on-line monitoring for Technical Specification parameters has been specifically designed to ensure consistency with VCSNS licensing basis. The on-line monitoring acceptance criteria have been developed in a manner that assures consistency with the setpoint calculation allowances for drift, while also ensuring no change to existing Technical Specification trip setpoints or allowable values. An improved, coordinated defense-in-depth against instrument failure has been established by the application of on-line monitoring. First, the OLM System has been shown not to have a contributing failure mechanism applicable to plant instrumentation.

Second, because instrument performance and all the associated failure mechanisms are evaluated more frequently than by traditional methods, additional layers of defense against instrument failures have been introduced through the application of on-line-monitoring.

Requirement 11 Adequate isolation and independence, aS) required by Regulatory Guide 1. 75, GDC 21, GDC 22, IEEE Std. 279 or IEEE Std. 603, and IEEE Std. 384, shall be maintained between the on-line monitoring devices and Class 1E instruments being monitored.

Discussion for Requirement 11:

The VCSNS on-line monitoring program is in full compliance with this requirement. The VCSNS OLM System does not connect to the safety-related portion of any instrument circuit. The data acquired for the OLM System is obtained from the plant computer historical data files. The plant computer acquires the instrument values from the downstream side of signal isolators for each instrument loop, thereby ensuring compliance with VCSNS licensing basis for isolation and independence.

The analytical software utilized by the OLM System does not connect to a physical instrument loop. The existing instrument circuits are entirely unchanged by the use of on-line monitoring at VCSNS. Signals are normally sent to the plant computer and are then stored in a conventional computer data archive.

The VCSNS OLM System acquires its inputs from the plant computer via the computer data archive.

Requirement 12 (a) QA requirements as delineated in 10 CFR Part 50, Appendix B, shall be applicable to all engineering and design activities related to on-line monitoring, including design and implementation of the on line system, calculations for determining process parameter estimates, all three zones of acceptance criteria (including the value of the ADVOLM),

evaluation and trending of on-line monitoring results, activities (including drift assessments) for relaxing the current TS-required instrument calibration frequency from "once per refueling cycle" to "once per a maximum period of 8 years," and drift

Document Control Desk Attachment IlIl LAR 05-0677 RC-06-0024 Page 8 of 9 assessments for calculating the allowance or penalty required to compensate for single-point monitoring.

(b) The plant-specific QA requirements shall be applicable to the selected on-line monitoring methodology, its algorithm, and the associated software. In addition, software shall be verified and validated and meet all quality requirements in accordance with NRC guidance and acceptable industry standards.

Discussion for Requirement 12:

a) The plant-specific engineering analyses performed in support of on-line monitoring implementation shall be performed in accordance with the applicable VCSNS engineering requirements which are in accordance with 10 CFR 50, Appendix B quality assurance requirements. The calculations of on-line monitoring acceptance criteria involve the review and interpretation of setpoint calculations and related documents.

Accordingly, quality assurance controls over these activities will be performed as stated in the NRC requirement.

b) Appendix C of reference 7.3 provides the verification and validation (V&V) documentation produced in support of the EPRI project; this documentation specifically describes an Argonne National Laboratory Multivariate State Estimation Technique (MSET) implementation for parameter estimation because this was the initial basis technique used in the EPRI On-Line Monitoring Implementation Project.

The documentation developed in support of this project included quality documents and V&V-related documents produced by the software supplier (Expert Microsystems, Inc.), Argonne National Laboratory, and EPRI. The software and its associated algorithms utilized by the VCSNS on-line monitoring program have qualified V&V documentation provided by Expert Microsystems, Inc. that meet or exceed industry standards. This documentation is integrated into the VCSNS plant-specific QA requirements for V&V.

VCSNS is in compliance with the above requirements. The plant-specific V&V programs are established to meet the QA requirements under 10 CFR 50, Appendix B and are consistent with accepted industry standards.

Requirement 13 Al equipment (except software) used for collection, electronic transmission, and analysis of plant data for on-line monitorng purposes shall meet the requirements of 10 CFR Part 50, Appendix B, Criterion XII, "Control of Measuring and Test Equipment. "

Administrative procedures shall be in place to maintain configuration control of the on-line monitoring software and algorithm.

Discussion for Requirement 13:

The OLM System at VCSNS is in full compliance with this requirement. The signal data evaluated by the OLM System is obtained from instrument circuits that are maintained in accordance with VCSNS-specific procedures. All equipment used in the collection, storage, transmission, analysis, and associated activities for the OLM System are controlled under formal plant processes and procedures that establish quality controls to

Document Control Desk Attachment IlIl LAR 05-0677 RC-06-0024 Page 9 of 9 maintain the system accuracy within the stated design requirements. No unique equipment is required or installed into these instrument loops; the data is acquired from the plant computer without any interaction with installed plant instrumentation.

Administrative controls are considered necessary to maintain configuration control of the monitoring software and its associated algorithms, which are an integral part of the software. Section 7 of the EPRI Implementation Guidelines (reference 7.3) describes plant procedures and surveillance requirements associated with on-line monitoring, which addresses these administrative controls.

Configuration control procedures are routinely implemented for software (computerware) employed at VCSNS.

Requirement 14 Before declaring the on-line monitoring system operable for the first time, and just before each performance of the scheduled surveillance using an on-line monitoring technique, a full-features functional test, using simulated input signals of known and traceable accuracy, should be conducted to verify that the algorithm and its software perform all required functions within acceptable limits of accuracy. Al applicable features shall be tested.

Discussion for Requirement 14:

The V&V documents produced in support of the SureSense software include a procedure with expected results for an acceptance test and periodic testing. The basis or example for this test is provided in reference 7.3 - the EPRI Technical Report 1007930, On-Line Monitoring of Instrument Channel Performance, Volume 3, Appendix C. The EPRI V&V report was produced specifically for a SureSense Diagnostic Monitoring Studio implementation which can be used as a guide for other software/algorithm applications. In support of the VCSNS V&V program and QA requirements the test files referenced in this procedure have been provided to VCSNS. As part of the plant-specific software acceptance, these test procedures and test files form the recommended basis for acceptance testing as well as for periodic testing in support of the quarterly on-line monitoring surveillance test.

Section 7 of the EPRI Technical Report 1007930, On-Line Monitoring of Instrument Channel Performance, Volume 3 provides the recommended input for the quarterly on-line monitoring surveillance test.

VCSNS will comply with the above requirements and the plant-specific programs that are established to meet QA requirements for computer software and testing. These programs are consistent with accepted industry standards as are routinely implemented for software (computerware) employed at VCSNS.

Document Control Desk Attachment IV LAR 05-0677 RC-06-0024 Page I of 1 ATTACHMENT IV EPRI Technical Report 1003361, On-Line Monitoring of Instrument Channel Performance, Volume 1: Guidelines for Model Development and Implementation Non-Proprietary Version

Document Control Desk Attachment V LAR 05-0677 RC-06-0024 Page I of I ATFACHMENT V EPRI Technical Report 1007930, On-Line Monitoring of Instrument Channel Performance, Volume 3: Applications to Nuclear Power Plant Technical Specification Instrumentation Non-Proprietary Version

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ML060400220

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Dear Sir / Madam:

Subject:

Enclosures:

Subject:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 ASSESSMENT

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6.0 ENVIRONMENTAL CONSIDERATION

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