Text

Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Correction to ITS 3.3.7, Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation
	ML15244A781
Person / Time
Site:	Sequoyah
Issue date:	08/31/2015
From:	James Shea; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CNL-15-188
	Download: ML15244A781 (69)
	v • d • e

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-15-188 August 31, 2015 10 CFR 50.90 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328

Subject:

Sequoyah Nuclear Plant, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Correction to ITS 3.3.7, Control Room Emergency Ventilation System (CREVS)

Actuation Instrumentation

References:

1. TVA Letter to NRC, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10),

dated November 22, 2013 (ADAMS Accession No. ML13329A881)

2. TVA Letter to NRC, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) -

Supplement 2, dated June 19, 2015 (ADAMS Accession No. ML15176A678)

3. TVA Letter to NRC, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) -

Supplement 3, dated July 24, 2015 (ADAMS Accession No. ML15176A404)

4. TVA Letter to NRC, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) -

Proposed License Conditions, dated August 5, 2015 (ADAMS Accession No. ML15218A185)

U.S. Nuclear Regulatory Commission CNL-15-188 Page 2 of 4 August 31, 2015 By letter dated November 22, 2013 (Reference 1), Tennessee Valley Authority (TVA) requested a license amendment to revise the current Technical Specifications for Sequoyah Nuclear Plant (SQN), Units 1 and 2, to the Improved Technical Specifications (ITS) consistent with the Improved Standard Technical Specifications described in NUREG-1431, Standard Technical Specifications - Westinghouse Plants, Revision 4.0. By letters dated June 19, 2015 (Reference 2), July 24, 2015 (Reference 3), and August 5, 2015 (Reference 4), TVA provided supplemental information to the ITS license amendment request (LAR).

The purpose of this letter is to provide a correction for a self-identified issue (SII) associated with ITS 3.3.7, Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation.

Current Technical Specification (CTS) 3.3.3.1 requires, in part, the Radiation Monitoring Instrumentation shown in Table 3.3-6 to be OPERABLE during Applicable Modes.

CTS Table 3.3-6, Instrument 2.c (Process Monitors, Control Room Isolation) is required OPERABLE during ALL MODES and during movement of irradiated fuel assemblies.

CTS Table 3.3-6 does not contain a requirement for the automatic actuation logic and actuation relays associated with control room isolation. Additionally, CTS Table 4.3-3, Radiation Monitoring Instrumentation Surveillance Requirements, does not provide Surveillance Requirements (SRs) for the automatic actuation logic and actuation relays associated with control room isolation.

ITS 3.3.7 requires, in part, that the CREVS actuation instrumentation for each Function in Table 3.3.7-1 be OPERABLE during Applicable Modes or Other Specified Conditions.

ITS Table 3.3.7-1 Function 2 provides requirements for two trains of Automatic Actuation Logic and Actuation Relays in MODES 1, 2, 3, 4, 5, 6 and during movement of irradiated fuel assemblies. Additionally, ITS Table 3.3.7-1 requires the following Surveillance Requirements for the Automatic Actuation Logic and Actuation Relays: an ACTUATION LOGIC TEST (SR 3.3.7.3); a MASTER RELAY TEST (SR 3.3.7.4); and a SLAVE RELAY TEST (SR 3.3.7.5).

This proposed change to the CTS to add requirements for the CREVS Automatic Actuation Logic and Actuation Relays Function was justified in Discussion of Change (DOC) M05.

The addition of the proposed Surveillance Requirements was intended to verify the OPERABILITY of the Automatic Actuation Logic and Actuation Relays. This change was designated as more restrictive because additional functions are required in ITS than were required in the CTS. However, the existing CTS function of detecting Control Room Radiation in the Control Room Air Intakes does not use any logic, or master or slave relays to perform the intended function. Additionally, during MODES 5 and 6, the Engineering Safety Features Cabinet supporting all logic functions is de-energized.

U.S. Nuclear Regulatory Commission CNL-15-188 Page 3of4 August 31, 2015 SQN proposes to restore the current licensing basis. This requires removal of the change annotated in DOC MOS and retention of the single function "Control Room Radiation, Control Room Air Intakes," as ITS Table 3.3.7-1 Function 2, which will be required OPERABLE in Modes 1, 2, 3, 4, 5, 6, and (a), where Footnote (a) states, "During movement of irradiated fuel assemblies, During CORE ALTERATIONS." Table 3.3.7-1, Function 2 will require the same tests, at the same frequency, as the CTS. This existing CTS function will ensure CREVS will actuate to terminate the supply of unfiltered outside air to the control room, initiate filtration, and pressurize the control room in the event of a design basis accident concurrent with a single failure. contains mark-ups associated with ITS 3.3.7, "Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation" to assist the NRC in their review of this self-identified issue. contains a table delineating the specific pages associated with the proposed Sii changes.

The information provided by this supplement to the original ITS LAR does not change the intent or the justification for the requested ITS license amendment. TVA has further determined that this supplement does not affect the basis for concluding that the proposed license amendment does not involve a Significant Hazards Consideration. As such, the 10 CFR 50.92 evaluation provided in the November 22, 2013, ITS LAR remains valid. In addition, the ITS LAR, including this supplement, continues to be exempt from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9).

There are no new regulatory commitments associated with this submittal. If there are any questions or if additional information is needed, please contact Mr. Tom Hess at 423-751-3487.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 31st day of August 2015.

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She a ce President, Nuclear Licensing Enclosure cc: See Page 4

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 Sequoyah Nuclear Plant, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Correction to ITS 3.3.7, Control Room Emergency Ventilation (CREVS) Actuation Instrumentation

ATTACHMENT 7 ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) ACTUATION INSTRUMENTATION, Volume 8, Rev. 0, Page 967 of 1148, Volume 8, Rev. 0, Page 967 of 1148

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs), Volume 8, Rev. 0, Page 968 of 1148, Volume 8, Rev. 0, Page 968 of 1148

A01 ITS ITS 3.3.7 3/4.3.3 MONITORING INSTRUMENTATION RADIATION MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.1 The radiation monitoring instrumentation channels shown in Table 3.3-6 shall be OPERABLE with their alarm/trip setpoints within the specified limits.

APPLICABILITY: As shown in Table 3.3-6.

ACTION:

a.

With a radiation monitoring channel alarm/trip setpoint exceeding the value shown in Table 3.3-6, adjust the setpoint to within the limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or declare the channel inoperable.

b.

With one or more radiation monitoring channels inoperable, take the ACTION shown in Table 3.3-6.

c.

The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.1 Each radiation monitoring instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-3.

April 11, 2005 SEQUOYAH - UNIT 1 3/4 3-39 Amendment No. 301 CONTROL ROOM EMERGENCY VENTILATION (CREVS) ACTUATION A02 CREVS actuation A02 M01 CREVS actuation instrumentation A02 M02 CREVS actuation A02 CHANNEL OPERATIONAL TEST (COT)

M03 LCO 3.3.7 Applicability SR Table Note ACTION A, ACTION B, ACTION C, ACTION D, ACTION E Add proposed ACTIONS Note A03 Page 1 of 8, Volume 8, Rev. 0, Page 969 of 1148, Volume 8, Rev. 0, Page 969 of 1148

A01 ITS ITS 3.3.7 TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION INSTRUMENT MINIMUM CHANNELS OPERABLE APPLICABLE MODES ALARM/TRIP SETPOINT MEASUREMENT RANGE ACTION 1.

AREA MONITOR a.

Fuel Storage Pool Area 1

151 mR/hr 10 104 mR/hr 26 2.

PROCESS MONITORS a.

Containment Purge Air 1

1, 2, 3, 4 & 6 8.5x 10-3 Ci/cc 10 - 107 cpm 28 b.

Containment i.

Deleted ii. Particulate Activity RCS Leakage Detection 1

1, 2, 3 & 4 N/A 10 - 107 cpm 27 c.

Control Room Isolation 2

ALL MODES and during movement of irradiated fuel assemblies 400 cpm**

10 - 107 cpm 29

With fuel in the storage pool or building

- Equivalent to 1.0 x 10-5 Ci/cc.

December 04, 2008 SEQUOYAH - UNIT 1 3/4 3-40 Amendment Nos. 12, 60, 112, 168, 256, 310, 322 See ITS 3.3.8 See ITS 3.3.6 See ITS 3.4.15 See ITS 3.3.8 CONTROL ROOM EMERGENCY VENTILATION (CREVS) ACTUATION A02 LA01 LA01 M04 Function 3 Footnote (b)

Page 2 of 8 Add proposed Table 3.3.7-1 Function 1 Table 3.3.7-1 M06 Add proposed Table 3.3.7-1 Function 4 M05 Add proposed Table 3.3.7-1 Function 2, Volume 8, Rev. , Page 970 of 1148, Volume 8, Rev. , Page 970 of 1148 and during CORE ALTERATIONS A04 MHC003 SII 3

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A01 ITS ITS 3.3.7 TABLE 3.3-6 (Continued)

ACTION STATEMENTS ACTION 26 -

With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, perform area surveys of the monitored area with portable monitoring instrumentation at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 27 -

With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.4.6.1.

ACTION 28 -

With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.9 (MODE 6) and 3.3.2.1 (MODES 1, 2, 3, and 4).

ACTION 29 -

a.

With one channel inoperable, place the associated control room emergency ventilation system (CREVS) train in recirculation mode of operation within 7 days or be 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With two channels inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of one CREVS train in the recirculation mode of operation and enter the required Actions for one CREVS train made inoperable by inoperable CREVS actuation instrumentation.

Or place both trains in the recirculation mode of operation within one hour.

If the completion time of Action 29b cannot be met in Modes 1, 2, 3, and 4, 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

If the completion time of Action 29b cannot be met during the movement of irradiated fuel assemblies, suspend core alterations and suspend movement of irradiated fuel assemblies.

If the completion time of Action 29b cannot be met in Modes 5 and 6, initiate action to restore one CREVS train.

May 31, 2000 SEQUOYAH - UNIT 1 3/4 3-41 Amendment No. 12, 112, 168, 256 See ITS 3.3.8 See ITS 3.3.6 See ITS 3.4.15 ACTION A ACTION C ACTION B ACTION C ACTION D ACTION E Add proposed ACTIONS D and E M07 L02 Add proposed Required Actions for Table 3.3.7-1 Function 1 M04 Page 9 of 22 Page 3 of 8 L01 Immediately L01 Immediately, Volume 8, Rev. , Page 971 of 1148, Volume 8, Rev. , Page 971 of 1148 Stet MHC003

A01 ITS ITS 3.3.7 TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS INSTRUMENT CHANNEL CHECK CHANNEL CALIBRATION CHANNEL FUNCTIONAL TEST MODES FOR WHICH SURVEILLANCE REQUIRED 1.

AREA MONITOR a.

Fuel Storage Pool Area S

R Q

2.

PROCESS MONITORS a.

Containment Purge Air Exhaust S

R Q

1, 2, 3, 4 & 6

b. Containment

i. Deleted ii. Particulate Activity RCS Leakage Detection S

R Q

1, 2, 3, & 4

c. Control Room Isolation S

R Q

ALL MODES

With fuel in the storage pool or building.

December 04, 2008 SEQUOYAH - UNIT 1 3/4 3-42 Amendment Nos. 12, 112,168, 220, 322 COT M03 LA02 See ITS 3.3.8 See ITS 3.3.6 See ITS 3.4.15 Add proposed SR 3.3.7.6 for Table 3.3.7-1 Function 1 at a Frequency of 18 months M04 See ITS 3.3.8 SR 3.3.7.1 SR 3.3.7.2 SR 3.3.7.7 Table 3.3.7-1 Function 3 CONTROL ROOM EMERGENCY VENTILATION (CREVS) ACTUATION A02 In accordance with the Surveillance Frequency Control Program Add proposed SR 3.3.7.3 for Table 3.3.7-1 Function 2 at a Frequency of 92 days on a STAGGERED TEST BASIS M05 Add proposed SR 3.3.7.4 for Table 3.3.7-1 Function 2 at a Frequency of 92 days on a STAGGERED TEST BASIS M05 LA02 Add proposed SR 3.3.7.5 for Table 3.3.7-1 Function 2 at a Frequency of 92 days M05 In accordance with the Surveillance Frequency Control Program LA02 In accordance with the Surveillance Frequency Control Program Page 4 of 8, Volume 8, Rev. , Page 972 of 1148, Volume 8, Rev. , Page 972 of 1148 3

4 SII SII 2

A01 ITS ITS 3.3.7 INSTRUMENTATION 3/4.3.3 MONITORING INSTRUMENTATION RADIATION MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.1 The radiation monitoring instrumentation channels shown in Table 3.3-6 shall be OPERABLE with their alarm/trip setpoints within the specified limits.

APPLICABILITY: As shown in Table 3.3-6.

ACTION:

a.

With a radiation monitoring channel alarm/trip setpoint exceeding the value shown in Table 3.3-6, adjust the setpoint to within the limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or declare the channel inoperable.

b.

With one or more radiation monitoring channels inoperable, take the ACTION shown in Table 3.3-6.

c.

The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.1 Each radiation monitoring instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-3.

April 11, 2005 SEQUOYAH - UNIT 2 3/4 3-40 Amendment No. 290 LCO 3.3.7 Applicability SR Table Note ACTION A, ACTION B, ACTION C, ACTION D, ACTION E CONTROL ROOM EMERGENCY VENTILATION (CREVS) ACTUATION A02 CREVS actuation A02 Add proposed ACTIONS Note A03 CREVS actuation instrumentation A02 M02 CREVS actuation A02 CHANNEL OPERATIONAL TEST (COT)

M03 Page 5 of 8 M01, Volume 8, Rev. 0, Page 973 of 1148, Volume 8, Rev. 0, Page 973 of 1148

A01 ITS ITS 3.3.7 TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION INSTRUMENT MINIMUM CHANNELS OPERABLE APPLICABLE MODES ALARM/TRIP SETPOINT MEASUREMENT RANGE ACTION

1. AREA MONITOR a.

Fuel Storage Pool 1

151 mR/hr 10 104 mR/hr 26 Area

2. PROCESS MONITORS a.

Containment Purge Air 1

1, 2, 3, 4 & 6 8.5 x 10-3 Ci/cc 10 - 107 cpm 28

b. Containment

i. Deleted ii. Particulate Activity RCS Leakage Detection 1

1, 2, 3 & 4 N/A 10 - 107 cpm 27 c.

Control Room Isolation 2

ALL MODES and during movement of irradiated fuel assemblies 400 cpm**

10 - 107 cpm 29 With fuel in the storage pool or building

- Equivalent to 1.0 x 10-5 Ci/cc.

December 04, 2008 SEQUOYAH - UNIT 2 3/4 3-41 Amendment Nos. 52, 102, 158, 247, 299, 314 Footnote (b)

See ITS 3.3.8 See ITS 3.3.6 See ITS 3.4.15 CONTROL ROOM EMERGENCY VENTILATION (CREVS) ACTUATION A02 LA01 See ITS 3.3.8 Add proposed Table 3.3.7-1 Function 1 M04 Page 6 of 8 LA01 Function 3 Table 3.3.7-1 M06 Add proposed Table 3.3.7-1 Function 4 M05 Add proposed Table 3.3.7-1 Function 2, Volume 8, Rev. , Page 974 of 1148, Volume 8, Rev. , Page 974 of 1148 and during CORE ALTERATIONS MHC003 A04 SII 2

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A01 ITS ITS 3.3.7 TABLE 3.3-6 (Continued)

ACTION STATEMENTS ACTION 26 -

With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, perform area surveys of the monitored area with portable monitoring instrumentation at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 27 -

With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.4.6.1.

ACTION 28 -

With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.9 (MODE 6) and 3.3.2 (MODES 1, 2, 3, and 4).

ACTION 29 -

a.

With one channel inoperable, place the associated control room emergency ventilation system (CREVS) train in recirculation mode of operation within 7 days or be 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With two channels inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of one CREVS train in the recirculation mode of operation and enter the required Actions for one CREVS train made inoperable by inoperable CREVS actuation instrumentation.

Or place both trains in the recirculation mode of operation within one hour.

If the completion time of Action 29b cannot be met in Modes 1, 2, 3, and 4, 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

If the completion time of Action 29b cannot be met during the movement of irradiated fuel assemblies, suspend core alterations and suspend movement of irradiated fuel assemblies.

If the completion time of Action 29b cannot be met in Modes 5 and 6, initiate action to restore one CREVS train.

May 31, 2000 SEQUOYAH - UNIT 2 3/4 3-42 Amendment Nos. 102, 158, 247 See ITS 3.3.8 See ITS 3.3.6 See ITS 3.4.15 ACTION A ACTION C ACTION B ACTION C ACTION D ACTION E M07 Add proposed ACTIONS D and E L02 Add proposed Required Actions for Table 3.3.7-1 Function 1 M04 Page 7 of 8 L01 Immediately L01 Immediately, Volume 8, Rev. , Page 975 of 1148, Volume 8, Rev. , Page 975 of 1148 Stet MHC003

A01 ITS ITS 3.3.7 TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS INSTRUMENT CHANNEL CHECK CHANNEL CALIBRATION CHANNEL FUNCTIONAL TEST MODES FOR WHICH SURVEILLANCE IS REQUIRED 1.

AREA MONITOR a.

Fuel Storage Pool Area S

R Q

2.

PROCESS MONITORS a.

Containment Purge Air Exhaust S

R Q

1, 2, 3, 4 & 6 b.

Containment

i. Deleted ii. Particulate Activity RCS Leakage Detection S

R Q

1, 2, 3 & 4 c.

Control Room Isolation S

R Q

ALL MODES With fuel in the storage pool or building.

December 04, 2008 SEQUOYAH - UNIT 2 3/4 3-43 Amendment Nos. 102, 158, 210, 314 See ITS 3.3.8 See ITS 3.3.6 See ITS 3.4.15 See ITS 3.3.8 CONTROL ROOM EMERGENCY VENTILATION (CREVS) ACTUATION A02 M03 COT LA02 SR 3.3.7.1 SR 3.3.7.2 SR 3.3.7.7 Page 8 of 8 Function 3 Table 3.3.7-1 Add proposed SR 3.3.7.6 for Table 3.3.7-1 Function 1 at a Frequency of 18 months M04 In accordance with the Surveillance Frequency Control Program Add proposed SR 3.3.7.3 for Table 3.3.7-1 Function 2 at a Frequency of 92 days on a STAGGERED TEST BASIS M05 Add proposed SR 3.3.7.4 for Table 3.3.7-1 Function 2 at a Frequency of 92 days on a STAGGERED TEST BASIS M05 LA02 In accordance with the Surveillance Frequency Control Program Add proposed SR 3.3.7.5 for Table 3.3.7-1 Function 2 at a Frequency of 92 days M05 In accordance with the Surveillance Frequency Control Program LA02, Volume 8, Rev. , Page 976 of 1148, Volume 8, Rev. , Page 976 of 1148 SII SII 3

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DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 7 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.3.3.1 requires, in part, the radiation monitoring instrumentation channels shown in Table 3.3-6 to be OPERABLE. CTS 3.3.3.1 ACTIONS a and b provide the Required Actions and associated Completion Time for when the radiation monitoring instrumentation is inoperable. CTS 4.3.3.1 requires, in part, that each radiation monitoring instrumentation channel be demonstrated OPERABLE. CTS Table 3.3-6 lists the instruments required to be OPERABLE, the Applicable MODES, and the appropriate ACTIONS to take for the Radiation Monitoring Instrumentation. ITS LCO 3.3.7 requires, in part, that the Control Room Emergency Ventilation System (CREVS) actuation instrumentation for each Function in Table 3.3.7-1 to be OPERABLE. ITS 3.3.7 ACTIONS A, B, C, D, and E provide the Required Actions and associated Completion Time for when the CREVS actuation instrumentation is inoperable. ITS SR 3.3.7.1, SR 3.3.7.2, SR 3.3.7.3, SR 3.3.7.4, SR 3.3.7.5, SR 3.3.7.6, and SR 3.3.7.7 provide the testing requirements for each CREVS actuation instrument in Table 3.3.7-1. This changes the CTS by having a separate Specification for the CREVS actuation instrumentation, in lieu of including them in the Radiation Monitoring Instrumentation Specification.

This change is acceptable because the technical requirements for the radiation monitoring instrumentation are maintained with the change in format. The CREVS Actuation Instrumentation continues to require the OPERABILITY of the radiation monitoring instrumentation. This change is designated as administrative because it does not result in a technical change to the CTS.

A03 The ACTIONS for CTS 3.3.3.1 do not contain a specific Note that allows separate Condition entry for each instrument. ITS 3.3.7 ACTIONS contains a Note which states that separate Condition entry is allowed for each Function.

This changes the CTS by specifically allowing separate Condition entry for each specified Function.

This change is acceptable because it clearly states the current requirement. The CTS considers each radiation monitoring instrument Function to be separate and independent. This change is designated as administrative because it does not result in a technical change to the CTS., Volume 8, Rev. , Page 977 of 1148, Volume 8, Rev. , Page 977 of 1148 MHC003 Insert 1 4

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INSERT 1 A04 CTS 3.3.3.1 requires, in part, the Radiation Monitoring Instrumentation shown in Table 3.3-6 to be OPERABLE during Applicable Modes. CTS Table 3.3-6, Instrument 2.c, Process Monitors, Control Room Isolation, is required OPERABLE during ALL MODES and during the movement of irradiated fuel assemblies. ITS LCO 3.3.7 requires, in part, that the Control Room Emergency Ventilation System actuation instrumentation for each Function in Table 3.3.7-1 be OPERABLE during Applicable Modes or Other Specified Conditions. ITS Table 3.3.7-1, Function 3.a, Control Room Radiation, Control Room Air Intakes, is required OPERABLE in Modes 1, 2, 3, 4, 5, 6, and (a), where Footnote (a) states, During movement of irradiated fuel assemblies, During CORE ALTERATIONS.

This changes the CTS by specifying the Process Monitors, Control Room Isolation

,QVWUXPHQWDWLRQ LV required OPERABLE during CORE ALTERATIONS.

This change is acceptable because CORE ALTERATIONS can only be performed in MODE 6. CTS 3.3.3.1 requires the Process Monitors, Control Room Isolation, to be OPERABLE in MODE 6. This change is designated as administrative because it does not result in a technical change to the CTS., Volume 8, Rev. , Page 977D of 1148, Volume 8, Rev. , Page 977D of 1148 MHC003 2

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DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 2 of 7 MORE RESTRICTIVE CHANGES M01 CTS 3.3.3.1 ACTION a requires that when a radiation monitor channel alarm/trip setpoint exceeds the value shown in Table 3.3-6, to adjust the setpoint within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or declare the channel inoperable. ITS 3.3.7 does not contain an ACTION for adjusting a setpoint that exceeds the required valued. Instead, ITS 3.3.7 ACTION A requires that when one required radiation monitoring channel is inoperable (i.e., setpoint not within tolerance) to enter the applicable Required Actions immediately. This changes the CTS by not allowing adjustment of the setpoint in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months before declaring the channel inoperable.

The purpose of CTS 3.3.3.1 ACTION a is to allow adjustment of the radiation monitor setpoint to within limits before declaring the channel inoperable.

Although ITS does not include this allowance, restoration such that the LCO is met, is always an option. This change is acceptable because the channel requirements in ITS 3.3.7 will ensure that the required radiation monitoring channel is OPERABLE. The proposed ITS ACTION for when one channel is inoperable will ensure that the Required Actions and Completion Times used establish remedial measures that when taken minimize risk associated with continued operation. This change is designated as more restrictive because more stringent Required Actions and Completion Times are being applied in the ITS than were applied in the CTS.

M02 CTS 3.3.3.1 ACTION c states that the provisions of Specification 3.0.3 are not applicable for the radiation monitoring instrumentation in CTS Table 3.3-6.

ITS 3.3.7 does not contain this exception. This changes the CTS by not allowing an exception to CTS Specification 3.0.3.

CTS 3.0.3 requires the unit to be shut down when the requirements of the LCO and the associated ACTIONS are not satisfied. This change is acceptable because ITS 3.3.7 does not provide an exception to LCO 3.0.3 for the radiation monitoring instrumentation used for control room isolation. Eliminating the CTS 3.0.3 exemption ensures that the operators are provided guidance regarding actions to take in the event the required radiation monitoring instrumentation is inoperable and the associated ACTIONS are not satisfied within the required time periods. This change is designated as more restrictive because an explicit exception provided in the CTS is eliminated.

M03 CTS 4.3.3.1 requires, in part, that the radiation monitoring instrumentation on Table 4.3-3 be demonstrated OPERABLE by performance of a CHANNEL FUNCTIONAL TEST. CTS Table 4.3-3 Instrument 2.c (Process Monitors -

Control Room Isolation) requires a CHANNEL FUNCTIONAL TEST.

ITS Table 3.3.7-1 Function 3 (Control Room Radiation - Control Room Air Intakes) requires the performance of ITS SR 3.3.7.2. ITS SR 3.3.7.2 requires the performance of a CHANNEL OPERATIONAL TEST (COT). This changes the CTS by requiring a COT instead of a CHANNEL FUNCTIONAL TEST.

This change is acceptable because the COT continues to perform tests similar to the current CHANNEL FUNCTIONAL TEST. The CTS defines a CHANNEL FUNCTIONAL TEST based on the type of channel. In CTS, a CHANNEL, Volume 8, Rev. , Page 978 of 1148, Volume 8, Rev. , Page 978 of 1148 2.a SII

DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 3 of 7 FUNCTIONAL TEST shall be: for Analog channels, the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions; for Bistable channels, the injection of a simulated signal into the sensor to verify OPERABILITY including alarm and/or trip functions; and for Digital channels, the injection of a simulated signal into the channel as close to the sensor input to the process racks as practicable to verify OPERABILITY including alarm and/or trip functions. This does not include the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors as does the CHANNEL CALIBRATION.

The COT provides similar tests with the addition that the COT includes adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the necessary range and accuracy. This change is designated as more restrictive because the ITS requires additional acceptance criteria that is not currently required in the CTS.

M04 CTS Table 3.3-6 and CTS Table 4.3-3 do not contain requirements for a manual initiation of the CREVS actuation instrumentation. ITS Table 3.3.7-1 Function 1 contains the applicable MODES, Required Channels, and Surveillance Requirements for the manual initiation of CREVS. ITS 3.3.7 ACTIONS provide the compensatory actions to take when ITS Table 3.3.7-1 Function 1 is not satisfied. Additionally, ITS SR 3.3.7.6 has been added to provide the testing requirements for manual initiation of the CREVS. This changes the CTS by adding requirements for the manual initiation function of the CREVS.

This change is acceptable because the manual initiation Function is necessary to ensure that the operator has manual initiation capability for CREVS at any time from the control room. Initiation of CREVS can be accomplished by manual initiation of Safety Injection. The safety injection function refers the operator to LCO 3.3.2 for all of the Safety Injection initiation functions and requirements.

This change is designated as more restrictive because additional functions are required in the ITS than were in the CTS.

M05 CTS Table 3.3-6 Instrument 2.c does not contain a requirement for the Automatic Actuation Logic and Actuation Relays associated with the Control Room Isolation. CTS Table 4.3-3 Instrument 2.c does not provide Surveillance Requirements for Actuation Logic testing and Master and Slave relay testing of the Automatic Actuation Logic and Actuation Relays associated with the Control Room Isolation. ITS Table 3.3.7-1 Function 2 provides the requirements for the 2 trains of Automatic Actuation Logic and Actuation Relays in MODES 1, 2, 3, 4, 5, 6 and during movement of irradiated fuel assemblies. If one train of the Automatic Actuation Logic and Actuation Relays Function is inoperable, ACTION A specifies that one train of CREVS be placed in the recirculation mode in 7 days. If two trains of the Automatic Actuation Logic and Actuation Relays Function are inoperable, ACTION B specifies that one train of CREVS be placed in the recirculation mode immediately and the applicable Conditions are Required Actions for one CREVS train made inoperable by inoperable CREVS actuation instrumentation be entered immediately. Otherwise, both trains of CREVS are required to be placed in the recirculation mode immediately. If the Required, Volume 8, Rev. , Page 979 of 1148, Volume 8, Rev. , Page 979 of 1148 SII Not Used 3

SII

DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 4 of 7 Actions and Completion Times of Condition A or B are not met in MODES 1, 2, 3, or 4, ACTION C specifies that the unit be placed in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . If the Required Actions and Completion Times of Condition A or B are not met during the movement of irradiated fuel assemblies, ACTION D specifies to immediately suspend the movement of fuel assemblies. If the Required Actions and Completion Times of Condition A or B are not met in MODES 5 or 6, ACTION E specifies to immediately initiate action to restore one CREVS train to OPERABLE status. Additionally, ITS Table 3.3.7-1 requires the following Surveillance Requirements for the Automatic Actuation Logic and Actuation Relays: an ACTUATION LOGIC TEST (SR 3.3.7.3) every 92 days on a STAGGERED TEST BASIS; a MASTER RELAY TEST (SR 3.3.7.4) every 92 days on a STAGGERED TEST BASIS; and a SLAVE RELAY TEST (SR 3.3.7.5) every 92 days. This changes the CTS by adding requirements for the CREVS Automatic Actuation Logic and Actuation Relays Function.

The Automatic Actuation Logic and Actuation Relays are required to support the OPERABILITY of the CREVS actuation instrumentation. Requiring two trains of Automatic Actuation Logic and Actuation Relays will ensure CREVS will actuate to terminate the supply of unfiltered outside air to the control room, initiate filtration, and pressurize the control room in the event of a design basis accident concurrent with a single failure. The specified Actions will ensure that the CREVS actuation instrumentation Function is accomplished or the unit is placed in a condition where the LCO requirements are not applicable. The addition of the proposed Surveillance Requirements will verify the OPERABILITY of the Automatic Actuation Logic and Actuation Relays. This change is designated as more restrictive because additional functions are required in the ITS than were in the CTS.

M06 CTS 3.3.3.1 states, "The radiation monitoring instrumentation channels shown in Table 3.3-6 shall be OPERABLE." Table 3.3-6 lists the radiation monitors required for the Control Room Isolation. ITS LCO 3.3.7 states, "The Control Room Emergency Ventilation System (CREVS) actuation instrumentation for each Function in Table 3.3.7-1 shall be OPERABLE." ITS Table 3.3.7-1 lists all required CREVS instrument functions which includes the Safety Injection signal.

The ITS Table 3.3.7-1 specification of the Safety Injection signal includes a reference to the requirements for the Safety Injection signal being specified in ITS 3.3.2, Engineered Safety Feature Actuation (EFAS) instrumentation. This changes the CTS by specifying an additional instrumentation actuation function for the CREVS.

ITS 3.3.7 is a system related instrumentation specification that includes all the required instrumentation for the CREVS. The Safety Injection signal, although specified in ITS 3.3.2, EFAS instrumentation, provides an actuation of CREVS that is credited in the LOCA safety analysis. The proposed change provides a more complete listing of the required CREVS actuations in a single specification.

If the Safety Injection Function is inoperable, such that only the CREVS function is affected, the less restrictive Actions of ITS 3.3.7 would be applicable. The other credited CREVS actuation instrumentation provides a complete list of required CREVS instrumentation with a common set of Actions to assure the plant is placed in a safe condition when the required instrumentation is, Volume 8, Rev. , Page 980 of 1148, Volume 8, Rev. , Page 980 of 1148 SII

DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 5 of 7 inoperable. Thus, the proposed change ensures the control room doses after a design basis event are maintained within the required limits. This change is designated as more restrictive because additional functions are required in the ITS than were in the CTS.

M07 CTS Table 3.3-6 ACTION 29a requires when one channel of the control room isolation instrumentation is inoperable and a CREVS train is not placed in the recirculation mode of operation within 7 days, to be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months in all MODES and during movement of irradiated fuel assemblies. ITS ACTION D requires when one channel of the control room isolation is inoperable (during movement of irradiated fuel assemblies) and a CREVS train is not placed in the recirculation mode of operation within 7 days, to immediately suspend movement of irradiated fuel assemblies. ITS ACTION E requires that when one channel of the control room isolation is inoperable and a CREVS train is not placed in the recirculation mode of operation within 7 days (in MODE 5 or 6) to initiate action to immediately restore one CREVS train to OPERABLE status. This changes the CTS by adding Required Actions if one channel of control room isolation is inoperable and a CREVS train is not placed in the recirculation mode of operation within 7 days when in MODE 5 or 6 and during movement of irradiated fuel assemblies.

The purpose of CTS Table 3.3-6 ACTION 29a is to provide the compensatory actions to take when one or more instrumentation channels of CREVS are inoperable. ITS 3.3.7 ACTIONS D and E provide new compensatory actions to take during the movement of irradiated fuel assemblies and in MODE 5 or 6.

This change is acceptable because these compensatory actions are commensurate with the Applicable MODES of operation or other specified conditions. During the movement of irradiated fuel assemblies, suspending the movement of irradiated fuel assemblies alone will reduce the risk of an accident that would require CREVS actuation. Furthermore, because the requirements for MODES 5 and 6 are to ensure adequate isolation capabilities in the event of a fuel handling accident, ITS 3.3.7 ACTION E, to initiate action to restore one CREVS train to OPERABLE status, is the correct action to take. This change is considered more restrictive because additional Required Actions are being applied in ITS that were not applied in CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-6 for Radiation Monitoring Instrumentation has five columns stating various requirements for the radiation monitoring instruments. These columns are labeled "MINIMUM CHANNELS OPERABLE,"

"APPLICABLE MODES," "ALARM/TRIP SETPOINT," "MEASUREMENT, Volume 8, Rev. , Page 981 of 1148, Volume 8, Rev. , Page 981 of 1148 CORE ALTERATIONS and suspend CORE ALTERATIONS and during CORE ALTERATIONS and suspending MHC003 MHC003 1

1

DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 6 of 7 RANGE," AND "ACTION." ITS Table 3.3.7-1 does not contain the column titled "MEASUREMENT RANGE." This changes the CTS by moving this information to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required channels, the Applicable MODES, the alarm/trip setpoint, and the appropriate Condition to enter if a required channel becomes inoperable.

Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS Table 4.3-3 Instrument 2.c requires a CHANNEL CHECK every shift (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ), a CHANNEL FUNCTIONAL TEST every quarter (92 days), and a CHANNEL CALIBRATION every refueling cycle (18 months). ITS SR 3.3.7.1, SR 3.3.7.2, SR 3.3.7.3, SR 3.3.7.6, and SR 3.3.7.7 require similar Surveillances and specify the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for this SR and associated Bases to the Surveillance Frequency Control Program. (See DOC M03 for discussion on changing the CHANNEL FUNCTIONAL TEST to a COT. See DOC M05 for the addition of ITS SR 3.3.7.3, SR 3.3.7.4, and SR 3.3.7.5. See DOC M04 for the addition of ITS SR 3.3.7.6.)

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications., Volume 8, Rev. , Page 982 of 1148, Volume 8, Rev. , Page 982 of 1148 4

3 SII

DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 7 of 7 LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS Table 3.3-6 ACTION 29b requires that when two channels of the Control Room Isolation instrumentation are inoperable, to initiate and maintain operation of one CREVS train in the recirculation mode of operation and enter the required Actions for one CREVS train made inoperable by inoperable CREVS actuation instrumentation within one hour or to place both trains in the recirculation mode of operation within one hour. ITS 3.3.7 ACTION B requires the same actions, but specifies the Completion Time as "Immediately." This changes the CTS by allowing additional time to complete ITS 3.3.7 ACTION B.

The purpose of CTS Table 3.3-6 ACTION 29b is to ensure that the CREVS will be able to perform its required safety function. This change is acceptable because the Required Actions have not changed, just the Completion Time.

When the Completion Time of "Immediately" is used in the ITS, it requires that the Required Action should be pursued without delay and in a controlled manner.

Depending on plant conditions, the Required Action could be completed within one hour or may take longer than one hour. The ITS 3.3.7 ACTION B Completion Time is acceptable because it will be completed without delay. This change is designated as less restrictive because less stringent Required Actions are being applied in ITS than were applied in CTS.

L02 (Category 4 - Relaxation of Required Action) CTS Table 3.3-6 ACTION 29b provides compensatory actions to take when the completion time of the specified actions cannot be met during the movement of irradiated fuel assemblies. One of the compensatory actions is to suspend core alterations. ITS 3.3.7 ACTION D does not require suspension of core alterations, but instead only requires the suspension of the movement of irradiated fuel assemblies. This changes the CTS by deleting the requirement to suspend core alterations.

The purpose of CTS Table 3.3-6 ACTION 29 is to reduce the risk of an accident that would require the CREVS to operate. CORE ALTERATIONS is defined in CTS 1.1, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity within the reactor vessel with the vessel head removed and fuel in the vessel." The accidents postulated to happen during core alterations, are fuel handling accidents, inadvertent criticality (due to control rod removal error or continuous control rod withdrawal error during refueling or boron dilution), and the inadvertent loading of, and subsequent operation with, a fuel assembly in an improper location. This change is acceptable because the only accident that can occur during CORE ALTERATIONS that results in a significant radioactive release is the fuel handling accident. ITS 3.3.7 Required Action D.1 requires the immediate suspension of movement of irradiated fuel assemblies, thereby reducing the risk of an accident that would require the actuation of CREVS. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS., Volume 8, Rev. , Page 983 of 1148, Volume 8, Rev. , Page 983 of 1148 Not Used MHC003

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs), Volume 8, Rev. 0, Page 984 of 1148, Volume 8, Rev. 0, Page 984 of 1148

CREFS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7A Westinghouse STS 3.3.7A-1 Rev. 4.0 CTS 1

V SEQUOYAH UNIT 1 Amendment XXX 3

3.3 INSTRUMENTATION 3.3.7A Control Room Emergency Filtration System (CREFS) Actuation Instrumentation (Without Setpoint Control Program)

LCO 3.3.7 The CREFS actuation instrumentation for each Function in Table 3.3.7-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.7-1.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one channel or train inoperable.

A.1

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

[ Place in toxic gas protection mode if automatic transfer to toxic gas protection mode is inoperable. ]

Place one CREFS train in emergency [radiation protection] mode.

7 days B. One or more Functions with two channels or two trains inoperable.

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

[ Place in the toxic gas protection mode if automatic transfer to toxic gas protection mode is inoperable. ]

B.1.1 Place one CREFS train in emergency [radiation protection] mode.

AND Immediately 1

Ventilation V

V recirculation recirculation V

V 3.3.3.1 3.3.3.1 Applicability DOC A03 Table 3.3-6 ACTION 29a Table 3.3-6 ACTION 29b 1

2 1

2 2

1 2

3 3, Volume 8, Rev. 0, Page 985 of 1148, Volume 8, Rev. 0, Page 985 of 1148

CREFS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7A Westinghouse STS 3.3.7A-2 Rev. 4.0 CTS 1

V SEQUOYAH UNIT 1 Amendment XXX 3

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.1.2 Enter applicable Conditions and Required Actions for one CREFS train made inoperable by inoperable CREFS actuation instrumentation.

OR B.2 Place both trains in emergency [radiation protection] mode.

Immediately Immediately C. Required Action and associated Completion Time for Condition A or B not met in MODE 1, 2, 3, or 4.

C.1 Be in MODE 3.

AND C.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours D. Required Action and associated Completion Time for Condition A or B not met during movement of [recently]

irradiated fuel assemblies.

D.1 Suspend movement of

[recently] irradiated fuel assemblies.

Immediately E. [ Required Action and associated Completion Time for Condition A or B not met in MODE 5 or 6.

E.1 Initiate action to restore one CREFS train to OPERABLE status.

Immediately ]

recirculation V

V V

Table 3.3-6 ACTIONS 29a and 29b DOC M07, Table 3.3-6 ACTION 29b DOC M07, Table 3.3-6 ACTION 29b Table 3.3-6 ACTION 29.b 1

1 2

2 2

2 1

3, Volume 8, Rev. , Page 986 of 1148, Volume 8, Rev. , Page 986 of 1148 AND D.2 Suspend CORE ALTERATIONS Immediately

, or during CORE ALTERATIONS.

MHC003 7

7

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V SEQUOYAH UNIT 1 Amendment XXX 3

SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.7-1 to determine which SRs apply for each CREFS Actuation Function.

SURVEILLANCE FREQUENCY SR 3.3.7.1 Perform CHANNEL CHECK.

[ 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR In accordance with the Surveillance Frequency Control Program ]

SR 3.3.7.2 Perform COT.

[ 92 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.3.7.3 Perform ACTUATION LOGIC TEST.

[ 31 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Program ]

V 4.3.3.1 Table 4.3-3 Instrument 2.c Table 4.3-3 Instrument 2.c 1

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CREFS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7A Westinghouse STS 3.3.7A-4 Rev. 4.0 CTS 1

V SEQUOYAH UNIT 1 Amendment XXX 3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.7.4 Perform MASTER RELAY TEST.

[ 31 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Program ]

REVIEWERS NOTE----------------------------------

The Frequency of 92 days on a STAGGERED TEST BASIS is applicable to the actuation logic processed through the Relay or Solid State Protection System.

SR 3.3.7.5

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

This Surveillance is only applicable to the actuation logic of the ESFAS Instrumentation.

Perform ACTUATION LOGIC TEST.

[ 92 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Program ]

5 4

3 DOC M05 4

6 5, Volume 8, Rev. 0, Page 988 of 1148, Volume 8, Rev. 0, Page 988 of 1148 SII 1

1

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V SEQUOYAH UNIT 1 Amendment XXX 3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

REVIEWERS NOTE----------------------------------

The Frequency of 92 days on a STAGGERED TEST BASIS is applicable to the master relays processed through the Solid State Protection System.

SR 3.3.7.6

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

This Surveillance is only applicable to the master relays of the ESFAS Instrumentation.

Perform MASTER RELAY TEST.

[ 92 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Program ]

SR 3.3.7.7 Perform SLAVE RELAY TEST.

[ [92] days OR In accordance with the Surveillance Frequency Control Program ]

4 5

DOC M05 DOC M05 4

4 6

5 4

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V SEQUOYAH UNIT 1 Amendment XXX 3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.7.8

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

Verification of setpoint is not required.

Perform TADOT.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ]

SR 3.3.7.9 Perform CHANNEL CALIBRATION.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ]

6 7

Table 4.3-3 Instrument 2.c DOC M04 5

4 4

5 4

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4 SII SII

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V SEQUOYAH UNIT 1 Amendment XXX 3

Table 3.3.7-1 (page 1 of 1)

CREFS Actuation Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS TRIP SETPOINT

1. Manual Initiation 1, 2, 3, 4, [5, 6], (a) 2 trains SR 3.3.7.8 NA

2. Automatic Actuation Logic and Actuation Relays 1, 2, 3, 4, [5, 6], (a) 2 trains SR 3.3.7.3 SR 3.3.7.4 SR 3.3.7.5 SR 3.3.7.6 SR 3.3.7.7 NA

3. Control Room Radiation

a. Control Room Atmosphere 1, 2, 3, 4 [5, 6], (a)

[2]

SR 3.3.7.1 SR 3.3.7.2 SR 3.3.7.9

[2] mR/hr

b. Control Room Air Intakes 1, 2, 3, 4, [5, 6], (a)

[2]

SR 3.3.7.1 SR 3.3.7.2 SR 3.3.7.9

[2] mR/hr

4. Safety Injection Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 1, for all initiation functions and requirements.

(a)

During movement of [recently] irradiated fuel assemblies.

V 6

7 400 cpm (b)

(b)

Equivalent to 1.0 x 10-5 Ci/cc.

Table 4.3-3 Instrument 2.c DOC M06 DOC M04 Table 4.3-3 Instrument 2.c Table 3.3-6 Footnote **

1 2

5 5

5 2

3 5

3 4

5 DOC M05 2

3 3, Volume 8, Rev. , Page 991 of 1148, Volume 8, Rev. , Page 991 of 1148 During CORE ALTERATIONS.

MHC003 DOC A04 7

3 4

SII SII 2

3 5

5

CREFS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7A Westinghouse STS 3.3.7A-1 Rev. 4.0 CTS 1

V SEQUOYAH UNIT 2 Amendment XXX 3

3.3 INSTRUMENTATION 3.3.7A Control Room Emergency Filtration System (CREFS) Actuation Instrumentation (Without Setpoint Control Program)

LCO 3.3.7 The CREFS actuation instrumentation for each Function in Table 3.3.7-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.7-1.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one channel or train inoperable.

A.1

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

[ Place in toxic gas protection mode if automatic transfer to toxic gas protection mode is inoperable. ]

Place one CREFS train in emergency [radiation protection] mode.

7 days B. One or more Functions with two channels or two trains inoperable.

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

[ Place in the toxic gas protection mode if automatic transfer to toxic gas protection mode is inoperable. ]

B.1.1 Place one CREFS train in emergency [radiation protection] mode.

AND Immediately 1

Ventilation V

V recirculation recirculation V

V 3.3.3.1 3.3.3.1 Applicability DOC A03 Table 3.3-6 ACTION 29a Table 3.3-6 ACTION 29b 1

2 1

2 2

1 2

3 3, Volume 8, Rev. 0, Page 992 of 1148, Volume 8, Rev. 0, Page 992 of 1148

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V SEQUOYAH UNIT 2 Amendment XXX 3

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.1.2 Enter applicable Conditions and Required Actions for one CREFS train made inoperable by inoperable CREFS actuation instrumentation.

OR B.2 Place both trains in emergency [radiation protection] mode.

Immediately Immediately C. Required Action and associated Completion Time for Condition A or B not met in MODE 1, 2, 3, or 4.

C.1 Be in MODE 3.

AND C.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours D. Required Action and associated Completion Time for Condition A or B not met during movement of [recently]

irradiated fuel assemblies.

D.1 Suspend movement of

[recently] irradiated fuel assemblies.

Immediately E. [ Required Action and associated Completion Time for Condition A or B not met in MODE 5 or 6.

E.1 Initiate action to restore one CREFS train to OPERABLE status.

Immediately ]

recirculation V

V V

Table 3.3-6 ACTIONS 29a and 29b DOC M07, Table 3.3-6 ACTION 29b DOC M07, Table 3.3-6 ACTION 29b Table 3.3-6 ACTION 29.b 1

1 2

2 2

2 1

3, Volume 8, Rev. , Page 993 of 1148, Volume 8, Rev. , Page 993 of 1148

, or during CORE ALTERATIONS.

AND D.2 Suspend CORE ALTERATIONS Immediately MHC003 7

7

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V SEQUOYAH UNIT 2 Amendment XXX 3

SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.7-1 to determine which SRs apply for each CREFS Actuation Function.

SURVEILLANCE FREQUENCY SR 3.3.7.1 Perform CHANNEL CHECK.

[ 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

OR In accordance with the Surveillance Frequency Control Program ]

SR 3.3.7.2 Perform COT.

[ 92 days

OR In accordance with the Surveillance Frequency Control Program ]

SR 3.3.7.3 Perform ACTUATION LOGIC TEST.

[ 31 days on a STAGGERED TEST BASIS

OR In accordance with the Surveillance Frequency Control Program ]

V 4.3.3.1 Table 4.3-3 Instrument 2.c Table 4.3-3 Instrument 2.c 1

4 4

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CREFS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7A Westinghouse STS 3.3.7A-4 Rev. 4.0 CTS 1

V SEQUOYAH UNIT 2 Amendment XXX 3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.7.4 Perform MASTER RELAY TEST.

[ 31 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Program ]

REVIEWERS NOTE----------------------------------

The Frequency of 92 days on a STAGGERED TEST BASIS is applicable to the actuation logic processed through the Relay or Solid State Protection System.

SR 3.3.7.5

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

This Surveillance is only applicable to the actuation logic of the ESFAS Instrumentation.

Perform ACTUATION LOGIC TEST.

[ 92 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Program ]

5 4

3 DOC M05 4

6 5, Volume 8, Rev. , Page 995 of 1148, Volume 8, Rev. , Page 995 of 1148 SII

CREFS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7A Westinghouse STS 3.3.7A-5 Rev. 4.0 CTS 1

V SEQUOYAH UNIT 2 Amendment XXX 3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

REVIEWERS NOTE----------------------------------

The Frequency of 92 days on a STAGGERED TEST BASIS is applicable to the master relays processed through the Solid State Protection System.

SR 3.3.7.6

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

This Surveillance is only applicable to the master relays of the ESFAS Instrumentation.

Perform MASTER RELAY TEST.

[ 92 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Program ]

SR 3.3.7.7 Perform SLAVE RELAY TEST.

[ [92] days OR In accordance with the Surveillance Frequency Control Program ]

4 5

DOC M05 DOC M05 4

4 6

5 4

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CREFS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7A Westinghouse STS 3.3.7A-6 Rev. 4.0 CTS 1

V SEQUOYAH UNIT 2 Amendment XXX 3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.7.8

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

Verification of setpoint is not required.

Perform TADOT.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ]

SR 3.3.7.9 Perform CHANNEL CALIBRATION.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ]

6 7

Table 4.3-3 Instrument 2.c DOC M04 5

4 4

5 4

4, Volume 8, Rev. , Page 997 of 1148, Volume 8, Rev. , Page 997 of 1148 SII SII 3

4

CREFS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7A Westinghouse STS 3.3.7A-7 Rev. 4.0 CTS 1

V SEQUOYAH UNIT 2 Amendment XXX 3

Table 3.3.7-1 (page 1 of 1)

CREFS Actuation Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS TRIP SETPOINT

1. Manual Initiation 1, 2, 3, 4, [5, 6], (a) 2 trains SR 3.3.7.8 NA

2. Automatic Actuation Logic and Actuation Relays 1, 2, 3, 4, [5, 6], (a) 2 trains SR 3.3.7.3 SR 3.3.7.4 SR 3.3.7.5 SR 3.3.7.6 SR 3.3.7.7 NA

3. Control Room Radiation

a. Control Room Atmosphere 1, 2, 3, 4 [5, 6], (a)

[2]

SR 3.3.7.1 SR 3.3.7.2 SR 3.3.7.9

[2] mR/hr

b. Control Room Air Intakes 1, 2, 3, 4, [5, 6], (a)

[2]

SR 3.3.7.1 SR 3.3.7.2 SR 3.3.7.9

[2] mR/hr

4. Safety Injection Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 1, for all initiation functions and requirements.

(a)

During movement of [recently] irradiated fuel assemblies.

V 6

7 400 cpm (b)

(b)

Equivalent to 1.0 x 10-5 Ci/cc.

Table 4.3-3 Instrument 2.c DOC M06 DOC M04 Table 4.3-3 Instrument 2.c Table 3.3-6 Footnote **

1 2

5 5

5 2

3 5

3 4

5 DOC M05 2

3 3, Volume 8, Rev. , Page 998 of 1148, Volume 8, Rev. , Page 998 of 1148 During CORE ALTERATIONS.

MHC003 DOC A04 7

3 4

SII SII 2

3 5

5

JUSTIFICATION FOR DEVIATIONS ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 1 1.

The type of Setpoint Control Program (Without Setpoint Control Program) and the Specification designator "A" are deleted since they are unnecessary. This information is provided in NUREG 1431, Rev. 4.0 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in the plant specific implementation. In addition, ISTS 3.3.7B (with Setpoint Control Program Specification) is not used and is not shown.

Furthermore, the title of the Specification has been changed from "Control Room Emergency Filtration System (CREFS) Actuation Instrumentation" to " Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation" since Sequoyah Nuclear Plant (SQN) does not have a CREFS.

2.

The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

3.

Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

4.

ISTS SR 3.3.7.1, SR 3.3.7.2, SR 3.3.7.5, SR 3.3.7.6, SR 3.3.7.7, SR 3.3.7.8, and SR 3.3.7.9 (ITS SR 3.3.7.1, SR 3.3.7.2, SR 3.3.7.3, SR 3.3.7.4, SR 3.3.7.5, SR 3.3.7.6, and SR 3.3.7.7) provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Additionally, the Frequency description which is being removed will be included in the Surveillance Frequency Control Program.

5.

The ACTUATION LOGIC TEST and MASTER RELAY TEST for SQN are processed through the Solid State Protection System. Since ISTS SR 3.3.7.5 and ISTS SR 3.3.7.6 are the appropriate Surveillance for the ACTUATION LOGIC TEST and MASTER RELAY TEST when they are processed through the Solid State Protection System, ISTS SR 3.3.7.3 and SR 3.3.7.4 have been deleted and the subsequent Surveillance Requirements have been renumbered.

6.

The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal., Volume 8, Rev. , Page 999 of 1148, Volume 8, Rev. , Page 999 of 1148

7.

ISTS Table 3.3.7-1, Footnote (a) has been revised to state, During movement of irradiated fuel assemblies, During CORE ALTERATIONS. ISTS 3.3.7A Condition D has been revised to state, Required Action and associated Completion Time for Condition A or B not met during movement of irradiated fuel assemblies, or during CORE ALTERATIONS. ISTS 3.3.7A has been revised to add Required Action D.2 that states, Suspend CORE ALTERATIONS, with an immediate Completion Time. CTS 3.3.3.1, Table 3.3-6, ACTION 29 requires, in part, the suspension of CORE ALTERATIONS if two channels of Process Monitors, Control Room Isolation Instrumentation are inoperable and one train of CREVS is not maintained in the recirculation mode of operation and the required Actions for one train of CREVS made inoperable by inoperable CREVS actuation instrumentation is not completed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months during the movement of irradiated fuel. ITS 3.3.7 has been revised to retain the CTS requirement to suspend CORE ALTERATIONS and specify the condition when the ACTION is applicable.

MHC003 4

SII Insert 1

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6XEVHTXHQW6XUYHLOODQFH5HTXLUHPHQWVDQGIXQFWLRQVRQ7DEOHKDYHEHHQ UHQXPEHUHG, Volume 8, Rev. , Page 999D of 1148, Volume 8, Rev. , Page 999D of 1148 SII

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs), Volume 8, Rev. 0, Page 1000 of 1148, Volume 8, Rev. 0, Page 1000 of 1148

CREFS Actuation Instrumentation (Without Setpoint Control Program)

B 3.3.7A Westinghouse STS B 3.3.7A-1 Rev. 4.0 1

SEQUOYAH UNIT 1 Revision XXX V

2 B 3.3 INSTRUMENTATION B 3.3.7A Control Room Emergency Filtration System (CREFS) Actuation Instrumentation (Without Setpoint Control Program)

BASES BACKGROUND The CREFS provides an enclosed control room environment from which the unit can be operated following an uncontrolled release of radioactivity.

During normal operation, the Auxiliary Building Ventilation System provides control room ventilation. Upon receipt of an actuation signal, the CREFS initiates filtered ventilation and pressurization of the control room.

This system is described in the Bases for LCO 3.7.10, "Control Room Emergency Filtration System."

The actuation instrumentation consists of redundant radiation monitors in the air intakes and control room area. A high radiation signal from any of these detectors will initiate both trains of the CREFS. The control room operator can also initiate CREFS trains by manual switches in the control room. The CREFS is also actuated by a safety injection (SI) signal. The SI Function is discussed in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation."

APPLICABLE The control room must be kept habitable for the operators stationed there SAFETY during accident recovery and post accident operations.

ANALYSES The CREFS acts to terminate the supply of unfiltered outside air to the control room, initiate filtration, and pressurize the control room. These actions are necessary to ensure the control room is kept habitable for the operators stationed there during accident recovery and post accident operations by minimizing the radiation exposure of control room personnel.

In MODES 1, 2, 3, and 4, the radiation monitor actuation of the CREFS is a backup for the SI signal actuation. This ensures initiation of the CREFS during a loss of coolant accident or steam generator tube rupture.

The radiation monitor actuation of the CREFS in MODES 5 and 6, and during movement of [recently] irradiated fuel assemblies are the primary means to ensure control room habitability in the event of a fuel handling or waste gas decay tank rupture accident.

The CREFS actuation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

1 V

Ventilation Control V

V its associated V

V V

V 1

2 1

1 1

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1 Ventilation (CREVS) 3 2

main steam line break 1, Volume 8, Rev. , Page 1001 of 1148, Volume 8, Rev. , Page 1001 of 1148

, and during CORE ALTERATIONS 5

MHC003

CREFS Actuation Instrumentation (Without Setpoint Control Program)

B 3.3.7A Westinghouse STS B 3.3.7A-2 Rev. 4.0 1

SEQUOYAH UNIT 1 Revision XXX V

2 BASES LCO The LCO requirements ensure that instrumentation necessary to initiate the CREFS is OPERABLE.

1.

Manual Initiation The LCO requires two channels OPERABLE. The operator can initiate the CREFS at any time by using either of two switches in the control room. This action will cause actuation of all components in the same manner as any of the automatic actuation signals.

The LCO for Manual Initiation ensures the proper amount of redundancy is maintained in the manual actuation circuitry to ensure the operator has manual initiation capability.

Each channel consists of one push button and the interconnecting wiring to the actuation logic cabinet.

2.

Automatic Actuation Logic and Actuation Relays The LCO requires two trains of Actuation Logic and Relays OPERABLE to ensure that no single random failure can prevent automatic actuation.

Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b., SI, in LCO 3.3.2. The applicable MODES and specified conditions for the CREFS portion of these functions are different and less restrictive than those specified for their SI roles. If one or more of the SI functions becomes inoperable in such a manner that only the CREFS function is affected, the Conditions applicable to their SI function need not be entered. The less restrictive Actions specified for inoperability of the CREFS Functions specify sufficient compensatory measures for this case.

3.

Control Room Radiation The LCO specifies two required Control Room Atmosphere Radiation Monitors and two required Control Room Air Intake Radiation Monitors to ensure that the radiation monitoring instrumentation necessary to initiate the CREFS remains OPERABLE.

For sampling systems, channel OPERABILITY involves more than OPERABILITY of channel electronics. OPERABILITY may also require correct valve lineups, sample pump operation, and filter motor operation, as well as detector OPERABILITY, if these supporting features are necessary for trip to occur under the conditions assumed by the safety analyses.

hand switch V

V 1

1 2

5 1

V V

1 1

1 and s, Volume 8, Rev. , Page 1002 of 1148, Volume 8, Rev. , Page 1002 of 1148 5

2 5

SII

CREFS Actuation Instrumentation (Without Setpoint Control Program)

B 3.3.7A Westinghouse STS B 3.3.7A-3 Rev. 4.0 1

SEQUOYAH UNIT 1 Revision XXX V

2 BASES LCO (continued)

4.

Safety Injection Refer to LCO 3.3.2, Function 1, for all initiating Functions and requirements.

APPLICABILITY The CREFS Functions must be OPERABLE in MODES 1, 2, 3, 4, and during movement of [recently] irradiated fuel assemblies. The Functions must also be OPERABLE in MODES [5 and 6] when required for a waste gas decay tank rupture accident, to ensure a habitable environment for the control room operators.

The Applicability for the CREFS actuation on the ESFAS Safety Injection Functions are specified in LCO 3.3.2. Refer to the Bases for LCO 3.3.2 for discussion of the Safety Injection Function Applicability.

ACTIONS The most common cause of channel inoperability is outright failure or drift of the bistable or process module sufficient to exceed the tolerance allowed by the unit specific calibration procedures. Typically, the drift is found to be small and results in a delay of actuation rather than a total loss of function. This determination is generally made during the performance of a COT, when the process instrumentation is set up for adjustment to bring it within specification. If the Trip Setpoint is less conservative than the tolerance specified by the calibration procedure, the channel must be declared inoperable immediately and the appropriate Condition entered.

A Note has been added to the ACTIONS indicating that separate Condition entry is allowed for each Function. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.7-1 in the accompanying LCO. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

A.1 Condition A applies to the actuation logic train Function of the CREFS, the radiation monitor channel Functions, and the manual channel Functions.

V V

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, and during CORE ALTERATIONS 5

MHC003 3

5 SII

CREFS Actuation Instrumentation (Without Setpoint Control Program)

B 3.3.7A Westinghouse STS B 3.3.7A-4 Rev. 4.0 1

SEQUOYAH UNIT 1 Revision XXX V

2 BASES ACTIONS (continued)

If one train is inoperable, or one radiation monitor channel is inoperable in one or more Functions, 7 days are permitted to restore it to OPERABLE status. The 7 day Completion Time is the same as is allowed if one train of the mechanical portion of the system is inoperable. The basis for this Completion Time is the same as provided in LCO 3.7.10. If the channel/train cannot be restored to OPERABLE status, one CREFS train must be placed in the emergency radiation protection mode of operation.

This accomplishes the actuation instrumentation Function and places the unit in a conservative mode of operation.

The Required Action for Condition A is modified by a Note that requires placing one CREFS train in the toxic gas protection mode instead of the

[radiation protection] mode of operation if the automatic transfer to toxic gas protection mode is inoperable. This ensures the CREFS train is placed in the most conservative mode of operation relative to the OPERABILITY of the associated actuation instrumentation.

B.1.1, B.1.2, and B.2 Condition B applies to the failure of two CREFS actuation trains, two radiation monitor channels, or two manual channels. The first Required Action is to place one CREFS train in the emergency [radiation protection]

mode of operation immediately. This accomplishes the actuation instrumentation Function that may have been lost and places the unit in a conservative mode of operation. The applicable Conditions and Required Actions of LCO 3.7.10 must also be entered for the CREFS train made inoperable by the inoperable actuation instrumentation. This ensures appropriate limits are placed upon train inoperability as discussed in the Bases for LCO 3.7.10.

Alternatively, both trains may be placed in the emergency [radiation protection] mode. This ensures the CREFS function is performed even in the presence of a single failure.

The Required Action for Condition B is modified by a Note that requires placing one CREFS train in the toxic gas protection mode instead of the

[radiation protection] mode of operation if the automatic transfer to toxic gas protection mode is inoperable. This ensures the CREFS train is placed in the most conservative mode of operation relative to the OPERABILITY of the associated actuation instrumentation.

1 5

recirculation V

5 1

1 5

V recirculation 1

V 1

V V

5 5

recirculation, Volume 8, Rev. 0, Page 1004 of 1148, Volume 8, Rev. 0, Page 1004 of 1148

CREFS Actuation Instrumentation (Without Setpoint Control Program)

B 3.3.7A Westinghouse STS B 3.3.7A-5 Rev. 4.0 1

SEQUOYAH UNIT 1 Revision XXX V

2 BASES ACTIONS (continued)

C.1 and C.2 Condition C applies when the Required Action and associated Completion Time for Condition A or B have not been met and the unit is in MODE 1, 2, 3, or 4. The unit must be brought to a MODE in which the LCO requirements are not applicable. To achieve this status, the unit must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

D.1 Condition D applies when the Required Action and associated Completion Time for Condition A or B have not been met when [recently]

irradiated fuel assemblies are being moved. Movement of [recently]

irradiated fuel assemblies must be suspended immediately to reduce the risk of accidents that would require CREFS actuation.

E.1 Condition E applies when the Required Action and associated Completion Time for Condition A or B have not been met in MODE 5 or 6. Actions must be initiated to restore the inoperable train(s) to OPERABLE status immediately to ensure adequate isolation capability in the event of a waste gas decay tank rupture.

SURVEILLANCE A Note has been added to the SR Table to clarify that Table 3.3.7-1 REQUIREMENTS determines which SRs apply to which CREFS Actuation Functions.

SR 3.3.7.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

1 4

V 1

V fuel handling accident 2, Volume 8, Rev. , Page 1005 of 1148, Volume 8, Rev. , Page 1005 of 1148 or when CORE ALTERATIONS are being performed and CORE ALTERATIONS 5

MHC003 and D.2

CREFS Actuation Instrumentation (Without Setpoint Control Program)

B 3.3.7A Westinghouse STS B 3.3.7A-6 Rev. 4.0 1

SEQUOYAH UNIT 1 Revision XXX V

2 BASES SURVEILLANCE REQUIREMENTS (continued)

Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

[ The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.3.7.2 A COT is performed on each required channel to ensure the entire channel will perform the intended function. This test verifies the capability of the instrumentation to provide the CREFS actuation. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with those established by the setpoint methodology. [ The Frequency of 92 days is based on the known reliability of the monitoring equipment and has been shown to be acceptable through operating experience.

OR 1

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6 6, Volume 8, Rev. 0, Page 1006 of 1148, Volume 8, Rev. 0, Page 1006 of 1148

CREFS Actuation Instrumentation (Without Setpoint Control Program)

B 3.3.7A Westinghouse STS B 3.3.7A-7 Rev. 4.0 1

SEQUOYAH UNIT 1 Revision XXX V

2 BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.3.7.3 SR 3.3.7.3 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is pulse tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils. [ This test is performed every 31 days on a STAGGERED TEST BASIS. The Frequency is acceptable based on instrument reliability and industry operating experience.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

5 7, Volume 8, Rev. 0, Page 1007 of 1148, Volume 8, Rev. 0, Page 1007 of 1148

CREFS Actuation Instrumentation (Without Setpoint Control Program)

B 3.3.7A Westinghouse STS B 3.3.7A-8 Rev. 4.0 1

SEQUOYAH UNIT 1 Revision XXX V

2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.7.4 SR 3.3.7.4 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but large enough to demonstrate signal path continuity. [ This test is performed every 31 days on a STAGGERED TEST BASIS. The Frequency is acceptable based on instrument reliability and industry operating experience.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

[ SR 3.3.7.5 SR 3.3.7.5 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the bypass condition, thus preventing inadequate actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is pulse tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils. [ This test is performed ever 92 days on a STAGGERED TEST BASIS. The Surveillance interval is justified in Reference 1.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

2 5

3 3

5 6, Volume 8, Rev. , Page 1008 of 1148, Volume 8, Rev. , Page 1008 of 1148 SII (Ref. 1)

KAB061

CREFS Actuation Instrumentation (Without Setpoint Control Program)

B 3.3.7A Westinghouse STS B 3.3.7A-9 Rev. 4.0 1

SEQUOYAH UNIT 1 Revision XXX V

2 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

The SR is modified by a Note stating that the Surveillance is only applicable to the actuation logic of the ESFAS Instrumentation. ]

[ SR 3.3.7.6 SR 3.3.7.6 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but large enough to demonstrate signal path continuity. [ This test is performed every 92 days on a STAGGERED TEST BASIS. The Surveillance interval is justified in Reference 1.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

The SR is modified by a Note stating that the Surveillance is only applicable to the master relays of the ESFAS Instrumentation. ]

7 7

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KAB061

CREFS Actuation Instrumentation (Without Setpoint Control Program)

B 3.3.7A Westinghouse STS B 3.3.7A-10 Rev. 4.0 1

SEQUOYAH UNIT 1 Revision XXX V

2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.7.7 SR 3.3.7.7 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified in one of two ways. Actuation equipment that may be operated in the design mitigation MODE is either allowed to function or is placed in a condition where the relay contact operation can be verified without operation of the equipment. Actuation equipment that may not be operated in the design mitigation MODE is prevented from operation by the SLAVE RELAY TEST circuit. For this latter case, contact operation is verified by a continuity check of the circuit containing the slave relay.

[ This test is performed every [92] days. The Frequency is acceptable based on instrument reliability and industry operating experience.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.3.7.8 SR 3.3.7.8 is the performance of a TADOT. This test is a check of the Manual Actuation Functions. Each Manual Actuation Function is tested up to, and including, the master relay coils. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.).

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CREFS Actuation Instrumentation (Without Setpoint Control Program)

B 3.3.7A Westinghouse STS B 3.3.7A-11 Rev. 4.0 1

SEQUOYAH UNIT 1 Revision XXX V

2 BASES SURVEILLANCE REQUIREMENTS (continued)

The test also includes trip devices that provide actuation signals directly to the Solid State Protection System, bypassing the analog process control equipment. [ The Frequency of 18 months is based on the known reliability of the Function and the redundancy available, and has been shown to be acceptable through operating experience.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Functions tested have no setpoints associated with them.

SR 3.3.7.9 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with those established by the setpoint methodology.

[ The Frequency of 18 months is based on operating experience and is consistent with the typical industry refueling cycle.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

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V Revision XXX SEQUOYAH UNIT 1 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

REFERENCES 1.

WCAP-15376, Rev. 0, October 2000.

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SEQUOYAH UNIT 2 Revision XXX V

2 B 3.3 INSTRUMENTATION B 3.3.7A Control Room Emergency Filtration System (CREFS) Actuation Instrumentation (Without Setpoint Control Program)

BASES BACKGROUND The CREFS provides an enclosed control room environment from which the unit can be operated following an uncontrolled release of radioactivity.

During normal operation, the Auxiliary Building Ventilation System provides control room ventilation. Upon receipt of an actuation signal, the CREFS initiates filtered ventilation and pressurization of the control room.

This system is described in the Bases for LCO 3.7.10, "Control Room Emergency Filtration System."

The actuation instrumentation consists of redundant radiation monitors in the air intakes and control room area. A high radiation signal from any of these detectors will initiate both trains of the CREFS. The control room operator can also initiate CREFS trains by manual switches in the control room. The CREFS is also actuated by a safety injection (SI) signal. The SI Function is discussed in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation."

APPLICABLE The control room must be kept habitable for the operators stationed there SAFETY during accident recovery and post accident operations.

ANALYSES The CREFS acts to terminate the supply of unfiltered outside air to the control room, initiate filtration, and pressurize the control room. These actions are necessary to ensure the control room is kept habitable for the operators stationed there during accident recovery and post accident operations by minimizing the radiation exposure of control room personnel.

In MODES 1, 2, 3, and 4, the radiation monitor actuation of the CREFS is a backup for the SI signal actuation. This ensures initiation of the CREFS during a loss of coolant accident or steam generator tube rupture.

The radiation monitor actuation of the CREFS in MODES 5 and 6, and during movement of [recently] irradiated fuel assemblies are the primary means to ensure control room habitability in the event of a fuel handling or waste gas decay tank rupture accident.

The CREFS actuation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

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2 BASES LCO The LCO requirements ensure that instrumentation necessary to initiate the CREFS is OPERABLE.

1.

Manual Initiation The LCO requires two channels OPERABLE. The operator can initiate the CREFS at any time by using either of two switches in the control room. This action will cause actuation of all components in the same manner as any of the automatic actuation signals.

The LCO for Manual Initiation ensures the proper amount of redundancy is maintained in the manual actuation circuitry to ensure the operator has manual initiation capability.

Each channel consists of one push button and the interconnecting wiring to the actuation logic cabinet.

2.

Automatic Actuation Logic and Actuation Relays The LCO requires two trains of Actuation Logic and Relays OPERABLE to ensure that no single random failure can prevent automatic actuation.

Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b., SI, in LCO 3.3.2. The applicable MODES and specified conditions for the CREFS portion of these functions are different and less restrictive than those specified for their SI roles. If one or more of the SI functions becomes inoperable in such a manner that only the CREFS function is affected, the Conditions applicable to their SI function need not be entered. The less restrictive Actions specified for inoperability of the CREFS Functions specify sufficient compensatory measures for this case.

3.

Control Room Radiation The LCO specifies two required Control Room Atmosphere Radiation Monitors and two required Control Room Air Intake Radiation Monitors to ensure that the radiation monitoring instrumentation necessary to initiate the CREFS remains OPERABLE.

For sampling systems, channel OPERABILITY involves more than OPERABILITY of channel electronics. OPERABILITY may also require correct valve lineups, sample pump operation, and filter motor operation, as well as detector OPERABILITY, if these supporting features are necessary for trip to occur under the conditions assumed by the safety analyses.

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2 BASES LCO (continued)

4.

Safety Injection Refer to LCO 3.3.2, Function 1, for all initiating Functions and requirements.

APPLICABILITY The CREFS Functions must be OPERABLE in MODES 1, 2, 3, 4, and during movement of [recently] irradiated fuel assemblies. The Functions must also be OPERABLE in MODES [5 and 6] when required for a waste gas decay tank rupture accident, to ensure a habitable environment for the control room operators.

The Applicability for the CREFS actuation on the ESFAS Safety Injection Functions are specified in LCO 3.3.2. Refer to the Bases for LCO 3.3.2 for discussion of the Safety Injection Function Applicability.

ACTIONS The most common cause of channel inoperability is outright failure or drift of the bistable or process module sufficient to exceed the tolerance allowed by the unit specific calibration procedures. Typically, the drift is found to be small and results in a delay of actuation rather than a total loss of function. This determination is generally made during the performance of a COT, when the process instrumentation is set up for adjustment to bring it within specification. If the Trip Setpoint is less conservative than the tolerance specified by the calibration procedure, the channel must be declared inoperable immediately and the appropriate Condition entered.

A Note has been added to the ACTIONS indicating that separate Condition entry is allowed for each Function. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.7-1 in the accompanying LCO. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

A.1 Condition A applies to the actuation logic train Function of the CREFS, the radiation monitor channel Functions, and the manual channel Functions.

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