ML17254A729
ML17254A729 | |
Person / Time | |
---|---|
Site: | Ginna ![]() |
Issue date: | 01/21/1986 |
From: | ROCHESTER GAS & ELECTRIC CORP. |
To: | |
Shared Package | |
ML17254A730 | List: |
References | |
NUDOCS 8601270040 | |
Download: ML17254A729 (135) | |
Text
TABLE OF CONTENTS 1.0 DEFINITIONS l-l Parcae 2.0 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS 2 1 1
~
2.1 Safety Limit, Reactor Core 2.1-1 2.2 Safety Limit, Reactor Coolant System Pressure 2.2-1 2.3 Limiting Safety System Settings, Protective Instrumentation 2~3 1 )
3.0 LIMITING CONDITIONS FOR OPERATION 3.0 Applicability 3.0-1 3.1 Reactor Coolant System 3 1 1
~
3.1.1 Operational Components 3.1-1 3.1.2 Heatup and Cooldown 3.1-5 3.1.3 Minimum Conditions for Criticality 3.1-18 3.1.4 Maximum Coolant. Activity 3.1-21
- 3. 1. 5 Leakage 3.1-25 3.1.6 Maximum Reactor Coolant Oxygen, Fluoride, and Chloride Concentration 3 ~ 1 31 3.2 Chemical and Volume Control System 3 ~2 1 3.3 Emergency Core Cooling System, Auxiliary Cooling Systems, Air Recirculation Fan Coolers, Containment, Spray and Charcoal Filters 3~3 1 3.4 Turbine Cycle 3.4-1 3.5 Instrumentation System 3.5-1 3.6 Containment, System 3.6-1 3.7 Auxiliary Electrical Systems 3+7 1 3.8 Refueling 3. 8-1 3.9 Plant Effluents 3.9-1 3.10 Control Rod and Power Distribution Limits 3.10-1 3.11 Fuel Handling in the Auxiliary Building 3 11 1
~
3.12 Movable In-Core Instrumentation 3.12-1 3.13 Shock Suppressors (Snubbers) 3.13-1 3.14 Fire Suppression System 3.14-1 3.15 Overpressure Protection, System 3.15-1 3.16 Radiological Environmental Monitoring 3.16-1 4.0 SURVEILLANCE REQUIREMENTS 4.1 Operational Safety Review 4.1-1 4.2 Inservice Inspection 4.2-1 4.3 Reactor Coolant System 4.3-1 4.4 Containment Tests 4.4-1 4.5 Safety'njection, Containment Spray and 4.5-1 Iodine Removal Systems Tests 4.6 Emergency Power System Periodic, Tests 4.6-1 4.7 Main Steam Stop Valves 4.7-1 S
- 3. Proposed S601270040 860i2i 05000244 '-
PDR p
ADOCK
'DR- -i-
t
,I i)
'I II
')
1t 1,
TECHNICAL SPECIFICATIONS DEFINITIONS The following terms are defined for uniform interpretation of the specifications.
Thermal Power The rate that the thermal energy generated by the fuel is accumulated by the coolant as it passes through the reactor vessel.
Reactor 0 eratin Nodes Coolant Reactivity Temperature Node k ko oF Refueling T < 140 Cold Shutdown avg 200 Hot, Shutdown T > 540 Operating 20 T w 580
~1' avg Any operation within the containment involving movement of fuel and/or control rods when the vessel head is unbolted.
Proposed
0 erable-0 erabilit A system, subsystem, train, component or device shall be operable or have operability when it is capable of performing its specified function(s). Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal or emergency electrical power sources (subject to Section 3.0.2), cooling or seal water, lubrication or other auxiliary equipment that are required for the n
system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s).
Proposed
l I /
I I'
+I d
II ll LIMITING CONDITIONS FOR OPERATION
~1n, the event a Limiting Condition for Operation and/or associated action requirements cannot be satisfied because of circumstances in excess of those addressed in the specification, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in at least hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (i.e., a total of seven hours),
and in at least cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (i.e., a total of 37 hour4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />') unless corrective measures are completed that permit operation under the permissible action statements for the specified time interval as measured from initial discovery or until the reactor is placed in a mode in which the specifi-cation is not applicable. If the action statement, corresponding to the Limiting Condition for Operation that was exceeded contains time limits to hot and cold shutdown that are less than those specified above, these more limiting time limits shall be applied.
Exceptions to these requirements shall be stated in the individual specifications.
When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered operable for the purpose of satisfying the requirements of its applicable Limiting Condition for 3.0-1 Proposed
)
II f II 15 Q ~ ~
b b II h
I
gl 5
Operation, provided: (1) its corresponding normal or emergency power source is operable; and (2) all of its redundant system(s), subsystem(s), train(s), com-ponent(s) and device(s) are operable, or likewise satisfy the requirements of this specification.
Unless both conditions (1) and (2) are satisfied within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the unit shall be placed in at least hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at, least cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This specification is not. applicable in cold shutdown or refueling modes.
Basis Specification 3.0.1 delineates the ACTION to be taken for circum-a stances not directly provided for in the ACTION statements and whose occurrence would violate the intent of the specification.
For example, Specification 3.3,2 requires two Containment Spray Pumps to be'operable and provides. explicit acti'on requirements I
J i',
if one spray pump is inoperable. Under the terms of Specification 3.0.1, if both of the required Containment Spray Pumps are inoperable, the unit is required to be in at least hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in at least cold shutdown in the next 30 hours. These time limits apply because the time limits for one spray pump inoperable (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to hot shutdown, wait 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> then 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> to cold shutdown) are less limiting. As a further example, Specification 3.3.1 requires each Reactor Coolant System accumulator to be operable and provides explicit action requirements if one accumulator is inoperable. Under the terms of Specification 3.0.1, if more than one accumulator is 3.0-2 Proposed
PL t
t h
II )l I
inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the
~ ~ ~
unit in at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdown
~
within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The time limit of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to hot shutdown and 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> to cold shutdown do not apply because the time limits for 1 accumulator inoperable are more limiting. It is assumed that, the unit is brought to the required mode within the required times by promptly initiating and carrying out the appropriate action statement.
Specification 3.0.2 delineates what additional conditions must be satisfied to permit operation to continue, consistent with the action statements for power sources, when a normal or emergency power source is not operable. It allows operation to be governed by the time limits of the action statement associated with the Limiting Condition for Operation for the normal or emergency
~ ~ ~ ~
power source, not the individual action statements for each
~ ~ ~ ~
system, subsystem, train, component or device that is determined to be inoperable solely becuase of the inoperability of its normal or emergency power source..
For example, Specification 3.7.1.d requires in part that. two emergency diesel generators be operable. The action statement provides for a maximum out-of-service time when one emergency diesel generator is not operable. If the definition of operable were applied without consideration of Specification 3.0.2, all systems, subsystems, trains, components and devices supplied by the inoperable emergency power source would also be inoperable.
This would dictate invoking the applicable action statements for each of the applicable Limiting Conditions for Operation. However,
- 3. 0-3 Proposed
U A E'
bk ~
the provisions of Specification 3.0.2 permit the time limits for continued operation to be consistent with the action statement for the inoperable emergency diesel generator instead, provided the other specified conditions are satisfied. In this case, this would mean that the corresponding normal power source must be operable, and all redundant systems, subsystems, trains, components, and devices must, be operable, or otherwise satisfy Specification 3.0.2 (i.e., be capable of performing their design function and have at least one normal or one emergency power source operable).
If they are not satisfied, shutdown is reguired.in accordance with this specification.
H
(
- 3. 0-4 Proposed
1 I
II t
0 P
I 1 N
I t
I '\
I
Reactor Coolant S stem A licabilit Applies to the operating status of the Reactor Coolant System when fuel is in the reactor.
To specify those conditions of the Reactor Coolant System which must be met. to assure safe reactor operation.
S ecification:
0 erational Com onents Reactor Coolant Loo s
- a. When the reactor power is above 130 MWT (8.5%),
both reactor coolant loops and their associated steam generators and reactor coolant pumps shall be in operation.
- b. If the conditions of 3.1.1.1.a are not met, then immediate power reduction shall be initiated under administrative control. If the shutdown margin meets the one loop requirements of Figure 3.10-2, then the power shall be reduced to less than 130 MWT. If the one loop shutdown margin of Figure 3.10-2 is not. met, the plant shall be taken to the hot shutdown condition and the one loop shutdown margin shall be met.
C. Except for special tests, when the RCS temperature is at or above 350'F with the, reactor power less than or equal to 130 MWT (8.5%), at least one reactor coolant loop and its associated steam generator and reactor coolant pump shall be in 3~1 1 Proposed
operation. The other loop and its associated steam generator must be operable so that heat could. be removed via natural circulation. However, both reactor coolant pumps may be de-energized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided (1) no operations are permitted that would cause dilution of the reactor coolant system boron concentration, and (2) core outlet II temperature is maintained 'at least 10'F below saturation temperature. 'll
- d. If the'onditions of 3.1~.1'.1".c are not met, then lp (i) if one loop is in operation, but the other loop is not operable, restore the inoperable loop to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or take the plant to the hot shutdown condition and reduce the RCS temperature to less than 350'F within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or if (ii) neither loop is in operation suspend all operations involving a reduction in boron concentration in the Reactor Coolant System and immediately initiate corrective action to return a coolant loop to operation.
- e. When the RCS temperature is less than 350'F, at least two of the following coolant loops shall be operable:
(i) reactor coolant loop A and its associated steam generator and reactor coolant pump.
(ii) reactor coolant loop B and its associated steam generator and reactor coolant pump.
3~1 2 Proposed
l 0
( iii) residual heat removal loop A. *
(iv) residual heat removal loop B.*
- f. Except during steam generator crevice cleaning operations, at least one of the coolant loops listed in paragraph 3.1.1.1.e shall be in operation while RCS temperature is less than 350'F. However, both reactor coolant pumps and residual heat removal pumps may be de-energized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided 1) no operations are permitted that would cause dilution of the reactor coolant system boron concentration, and 2) core outlet temperature is maintained at least 104F below saturation temperature.
- g. If the conditions of 3.1.1.1.e are not met, immediately initiate corrective action to return the required loops to operable status, and if not in cold shutdown already, be in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- h. If the conditions of 3.1.1.1.f are not met, then suspend all operations involving a reduction in boron concentration of the Reactor Coolant System and immediately initiate corrective action to return the required coolant loop to operation.
'4 I
lf
- The normal or emergency, power" source 'may be inoperable, while in cold shutdown.
3~1 3 Proposed
t t
h II
\
II $ ' pA' 1
I f W h
q II
% I 'I J rr H1 L
,II
)
ll II Jl
'I Ji' 0
- c. Whenever the reactor is at or above an RCS temperature of 350'F, both pressurizer code safety valves shall be operable with a lift setting of 2485 psig 21%.
- d. If one pressurizer code safety valve is not operable while the reactor is at or above an RCS temperature of 350'F, then either restore the inoperable valve to operable status within 15 minutes or be in at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and below an RCS temperature of 350'F within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Relief Valves
- a. Both pressurizer power operated relief valves (PORVs) and their associated block valves shall be operable whenever the reactor is at or above an RCS temperature of 350'F, or (i) with one or more PORV(s) inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the PORV(s) to operable status or close the associated block valve(s);
otherwise,'e in at least hot shutdown within the next. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and below an RCS temperature tl kI
",of 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or L
4 (ii) with one or more block valve(s) inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the block valve(s) to operable status or close the block valve(s) and remove power from the block valve(s);
3.1-5 Proposed
II t l4 h! IJ
}l
otherwise, be in at least hot shutdown within the next 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />s~Iand below an RCS temperature of 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Pressurizer
- a. Whenever t:he reactor is at. or above an RCS temperature of 350'F the pressurizer shall have at least 100 kw of heaters operable and a water level maint:ained between 12% and 87% of level span. If the pressurizer is inoperable due to heaters or water level, restore the pressurizer to operable status within 6 hrs. or have the reactor below an RCS temperature of 350'F and the RHR system in operation within an additional 6 hrs.
- b. This requirement shall not. apply during performance of RCS hydro test provided the test is completed and the pressurizer is operable per 3.1.1.5a within 16 hours.
Reactor Coolant S stem Vents
- a. When the reactor is at hot shutdown or critical, at least one reactor coolant system vent path consisting of two valves in series shall be operable and closed~
at each of the following locations:
- 1. Reactor Vessel head
- 2. Pressurizer steam space
- The PORV block valve is not required to be closed but must be operable if the PORV is capable of being opened.
Amendment No. g Proposed
- b. With one or more vents at the above reactor coolant system vent path locations inoperable, startup may commence and/or power operation may continue provided at least one vent path is, operable and the inoperable vent paths are maintained closed with motive power removed from the valve actuator of all the valves in the inoperable vent paths.
If the requirements of 3.1.1.6a are not met within 30 days, be in hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and below 350'F within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- c. With all of the above reactor coolant system vent paths inoperable; maintain the inoperable vent paths closed with power removed from the valve actuators o'f all the valves in the inoperable vent
-paths, and'restore .at least oneof the vent paths to operable status, wi'thin "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and below 350'F within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Bases The plant is designed to operate with all reactor coolant loops in operation and maintain the DNBR above the limit value during all normal 3.1-6a Amendment, No. P Proposed
IP
) r ~ ~,( J P
N t
'J y 1 1 Lf g ~,
3.1.5.1 Detection S stems 3.1.5.1.1 With an RCS temperature greater than 350'F, two of the following leak detection systems, including one system sensitive to radioactivity, shall be in operation.
- a. The containment air particulate monitor
- b. The containment radiogas monitor
- c. The containment atmosphere humidity detector
- d. The containment water inventory monitoring system 3.1.5.1.2 When a system sensitive to radioactivity is not operable, operation may continue for up to 30 days provided grab samples of the containment atmosphere are obtained and analyzed at least once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the RCS temperature less than 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
3.1.5.2 RCS Leaka e Limits a V 3.1.5.2.1 With the RCS temperature at 'or'above 350'F," RCS leakage shall be limited to:
- a. No leakage, if known to be'through an RCS pressure boundary such as a pipe, vessel or valve body,
- b. 10 gpm from a known leakage source other than the above,
- c. 1 gpm from an unidentified leakage source,
- d. .1 gpm tube leakage in one steam generator when averaged over 24 hours.
3.1-25 Proposed
a 1
1 'I I, 1J
3.1.5.2.2
~ ~ ~ If the limits specified
~
above are exceeded the following action- is required.
~ ~
- a. With any RCS pressure boundary leakage, as defined in 3.1.5.2.1.a, be at hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350'F in the following 6 hours.
- b. With leakage in excess of 3.1.5.2.1 b or c, reduce leakage rate to within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350'F within the following 6 hours.
- c. With steam generator tube leakage in excess of 3.1.5.2.ld, be at hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. If more than six months have elapsed since the last steam generator inspection, perform an inspection in accordance with the requirements of Technical Specification 4.2.
Basis Water inventory balances, monitoring equipment, boric acid crystalline deposits, and physical inspections can disclose reactor coolant leaks. Any leak of radioactive fluid, whether or not it is from the reactor coolant system, pressure boundary, c'a n,-be a serious problem with r'espect to in-plant radi'oactivity'contamination or it, could develop into a still more serious problem if the leakage rate is of sufficient magnitude to effect cooling of the reactor core; and, therefore, first indications of such leakage should be investigated as soon as practicable.
3.1-26 Proposed
I'<
1 J
If leakage is to the containment, its presence may be indicated by one or more of the following methods:
- a. The containment air particulate monitor is sensitive to low leak rates. The rate of leakage to which the instrument is sensitive is 0.013 gpm within twenty minutes, assuming the presence of corrosion product activity.
- b. The containment radiogas monitor is less sensitive but can be used as a backup to the air particulate monitor. The sensitivity range of the instrument is approximately 2 gpm to greater than 10 gpm.
- c. The humidity detector provides a backup to a. and b.
The sensitivity range of this instrument is from approximately 2.gpm to l1 10 gpm;, ~"
- d. A leakage detection system which determines leakage from water and ste'am'systems within the containment collects and measures moisture condensed from the containment atmosphere by cooling coils of the main recirculation units. This system provides a dependable and accurate means of determining total leakage, including leaks from the cooling coils.
This system can detect leakage from approximately 1/2 gpm to 10 gpm.
3~1 27 Proposed
11 Indication of leakage from the above sources should be cause for an investigation and could require a containment entry and limited inspection at power of the reactor coolant system. Visual inspection
(,'
procedures, i.e., looking'or steam," floor wetness or boric acid crystalline formations, would be used.
It should be noted that detection 'systems sensitive to r'adioactivity will have an indication that is sensitive to the coolant activity and the location of the leak as well as the leak rate. Also since leakage directly into the containment could be from a variety of sources, such as the component cooling system, the service water system, the secondary system, the reactor make-up water system, the chemical and volume control system, the seal injection system, the sampling system, as well as the primary coolant system, an increase in containment air moisture or sump actuation does not necessarily mean a primary system leak. Water inventory balances, liquid waste activities and tritium content can all be used in determining the nature of a leak inside the containment.
If leakage is to another system, it will be detected by the plant radiation monitors and/or water inventory control.
When the source of leakage has been investigated, the situation can be evaluated to determine if operation can be continued safely. This evaluation will be within the criteria of this specification.
- 3. 1-28 Proposed
P
- a. A leak of any magnitude in a pipe, vessel, or valve body in the coolant system pressure boundary compromises the integrity of that system and significantly r,'A alters'he probability,, of a loss-of-coolant "accident occurr'ing. Therefore, prompt shutdown of the reactor or isolation of the leaking component, is required to
- l. ~
reduce the consequences I
of this event or prevent its occurrence.
- b. The identified leakage rate is restricted to less than 25% of the coolant make-up capability with the minimum charging capacity powered by emergency power. This does allow for further degradation of the system during the evaluation and shutdown process with assurance that adequate cooling make-up capability exists. Xf the maximum allowable coolant activity existed, the 10 gpm leak rate would not, result in doses in excess of the annual average allowed by. 10 CFR Part 20.
Should a postulated transient or accident occur (such as a rod ejection or steam line break accident), then, if the primary to secondary leak rate is limited to 0.1 gpm per steam generator, the site boundary dose would be maintained well within the guide-,
lines and all steam generator tubes would maintain their integrity.
Continuous operability of two systems of diverse principles is desired to assure some surveillance of coolant leakage. However, 3.1-29 Proposed
I' JIJ
due to the redundancy of systems designed to monitor degradation of the reactor coolant pressure boundary, provisions for short term degradation of one system or long term substitution of a system do not materially alter the degree of safety.
Reference:
(1) FSAR Section 11.2.3, 14.2.4 El H
3.1-30 Proposed
E
'I I
A I' I 4
ill t
I- 'I
l t
3.1.6
~ . ', Maximum Reactor Coolant
~
Ox en, Fluoride, and Chloride Concentration 3.1.6.1 With an RCS temperature above 200'F, the RCS chemistry shall be maintained within the following limits.
Steady-State Transient Contaminant Limit m Limit m
- Oxygen 0.10 1.00 Chloride 0.15 1.50 Fluoride 0.15 1.50 3.1.6.2 With any one or more of the chemistry parameters in excess of its Steady State Limit, but within its Transient Limit, restore the parameter to within its Steady State Limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and below an RCS tempera-ture of 200'F within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
3.1.6.3 With any one or more of the chemistry parameters in
.excess of its Transient Limit, be in at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and below an RCS temperature of 200'F within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> and perform an engineeiing evaluation in accordance with 3.1.6.5.
3.1.6.4 With the RCS temperature at or below 200'F, the RCS chemistry shall be maintained within the following limits.
Normal Limit Transient. Limit Contaminant m m Oxygen Saturated Saturated
- Limits for Oxygen not applicable below 250'F.
3 ~ 1 31 Proposed
ql E lt I I*
V ii Chloride 0.15 1.50 Fluoride 0.15 1.50 3.1.6.5 If the concentration of chloride or fluoride exceeds the Steady State Iimit for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or exceeds the Transient limit, maintain the RCS pressure less than 500 psig and perform an engineering evaluation of the effects of the out of limit conditions on the structural integrity of the RCS. This evaluation shall'etermine that the RCS remains acceptable for continued operation prior to increasing RCS temperature and pressure above 200'F and 500 psig respectively.
Basis:
By maintaining the oxygen, chloride and fluoride concentrations in the reactor coolant below the normal limits as specified, the integrity of the Reactor Coolant System is assured under all operating conditions (1). If normal limits are exceeded, measures can be taken to correct the condition, e.g., replacement, of ion exchange resin, the addition of hydrazine during subcritical operation, or adjustment of the hydrogen concentration in the volume control tank (2) during power operation. Because of'he time dependent, nature of any adverse effects arising from oxygen, chloride, and fluoride concentration in excess of the limits, it is unnecessary to shut, down immediately since the condition can be corrected. Thus, the period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for corrective action to restore concentrations within the limits has been established.
If the corrective action has not been effective at the end of the F 1 32 Proposed
'lt
'I J
I
24 hour period, then the RCS will be brought below 200'F and the corrective action will continue. The effects of contaminants in the reactor coolant are temperature dependent. It is consistent/
therefore, to permit a steady state concentration in excess of limit to exist for a longer period of time at the colder RCS temperatures and still provide the assurance that the integrity of the primary coolant system will be maintained. In order to restore the contaminant concentrations to within specification limits in the event such limits were exceeded, mixing of the primary coolant with the reactor coolant pumps may be required. This will result in a small heatup of short duration and will not. increase the average coolant temperature above 250'F.
Reference:
(1) FSAR, Section 4.2 '.
(2) FSAR, Section 9.2 N
3~1 33 Proposed
7 C
1i e
t 4'
ll
3.2 Chemical and Volume Control S stem Applies to the operational status of the chemical and volume control system.
~b'o define those conditions of the chemical and volume control syst: em necessary to assure safe reactor operation.
fuel is, in. the reactor there shall be at least
'f'.2.1 When one flow path to the core for boric acid injection.
.The, minimum capability for boiic acid injection shall 4
f I be 'equivalent to that s'upplied from the refueling water storage tank.
3.2.2
~ ~ The reactor shall not be taken above cold shutdown unless the following Chemical and Volume Control System conditions are met.
- a. At. least two charging pumps shall be operable.
- b. Both boric acid transfer pumps shall be operable.
- c. The boric acid tanks together shall contain a, minimum of 2,000 gallons of a 12% to 13% by weight boric acid solution at a temperature of at least 145'F.
3~2 1 Proposed
- d. System piping and valves shall be operable to the extent of establishing two flow paths from the boric acid tanks to the Reactor Coolant System and a flow path from the refueling water storage tank to the Reactor Coolant System.
- e. Both channels of heat tracing shall be operable for the above flow paths.
The requirements of 3.2.2 may be modified to allow one of the following components to be inoperable at any one time. If the system is not restored to meet the requirements of 3.2.2 within the time period specified below, the reactor shall be placed in the hot shutdown condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. If the requirements of 3.2.2 are not satisfied within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> the reactor shall be in cold shutdown within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- a. If only one charging pump is operable, then have two pumps operable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- b. One boric acid pump may be out of service provided the pump is restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- c. One boric acid tank may be out of service provided a minimum of 2,000 gallons of a 12% to 13% by weight boric acid solution at a temperature of at least 145'F is contained in the operable tank and provided that the tank is restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
3 2 2
~ Proposed
I II l I l
- d. If only one flow path from the boric acid tanks is operable, then restore a total of two paths to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- e. One, channel of heat. tracing may be out of service provided it is restored to operable status within h 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />., t 3."2,4 "
Whenever"the RCS temperature is greater than 200'F and is being cooled by the RHR system and the overpressure protection system is not operable, at, least one charging pump shall be demonstrated inoperable at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control switch is in the pull-stop position.
Basis The chemical and volume control system provides control of the reactor coolant system boron inventory. This is normally accomplished by using either one of the three charging pumps in series with one of the two boric acid pumps. An alternate method of boration will be to use the charging pumps directly from the refueling water storage tank. A third method will be to depressurize and use the safety injection pumps. There are two sources of borated water available for injection through three different paths.
(1) The boric acid transfer pumps can deliver the boric acid tank contents (12% concentration of boric acid) to the charging pumps.
3 2 3
~ Proposed
Emer enc Core Coolin S stem, Auxiliar Coolin S stems, Azr Reczrculatzon Fan Coolers, Containment S ra , and Charcoal HEPA Fa.lters
~b'o define those conditions for operation that are necessary:
(1) to remove decay heat from the core in emergency or normal shutdown situations, (2) to remove heat from containment in normal operating and emergency situations, (3) to remove airborne iodine from the containment atmosphere following a postulated Design Basis Accident, and (4) to minimize containment leakage to the environ-ment subsequent to F
a Design Basis Accident.
lF F
'F'i i.
In 'ection and Residual Heat Removal S stems IF Safet The reactor shall not be taken above the mode indicated unless the following conditions are met:
- a. Above cold shutdown, the refueling water storage tank contains not less than 300,000 gallons of water, with a boron concentration of at least 2000 ppm.
b." Above a reactor coolant system pressure of 1600 psig, each accumulator is pressurized to at least 700 psig with an indicator level of at least 50% and a maximum of 82% with a boron concentration of at, least 1800 ppm.
- c. At or above a reactor coolant system pressure and temperature of 1600 psig and 350'F, except during performance of RCS hydro test, three safety injection pumps are operable.
- 3. 3-1 Proposed
l 4
- d. At or above an RCS temperature of 350'F, two residual heat removal pumps are operable.
- e. At or above an RCS temperature of 350'F, two residual heat removal heat exchangers are operable.
- f. At the conditions required in a through e above, all valves, interlocks and piping associated with the above components which are reguired to function during accident conditions are operable.
- g. At or above an RCS temperature of 350'F, A.C.
power shall be removed from the following valves with the valves in the open position: safety injection cold leg injection valves 878B and D, and refueling water storage tank delivery valve 856. A.C. power shall be removed from safety injection hot leg injection valves 878A and C with the valves closed. D.C. control power shall be
, removed from refueling water storage tank delivery valves 896A and B with the,'valves open.
- h. At or above an RCS temperature of 350'F, check valves 853A, 853B, 867A, 867B, 878G, and 878J shall be operable with less than 5.0 gpm leakage each. The leakage reguirements of Technical Specification 3.1.5.2.1 are still applicable.
Above a reactor coolant. system pressure of 1600 psig, A.C. power shall be removed from accumulator isolation valves 841 and 865 with the valves open.
NRC Order dated April 20, 1981 3 ' 2 Amendment No.
Proposed
~
r k
4 I E i'V l .r P k
l h
3.3.1.2
~ ~ ~ If the conditions of 3.3.1.1a are not met, then be at hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at cold shutdown within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
3.3.1.3 The requirements of 3.3.1.1b and 3.3.1.1i may be modified to allow one accumulator to be inoperable or isolated for up to one hour. If the accumulator is not operable or is still isolated after one hour, the reactor shall be placed in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and below a RCS pressure of 1600 psig within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
3.3.1. 4 The requirements of 3.3.1.1.c may be modified to allow one safety injection pump to be, inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If the pump is not operable after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the reactor shall be placed in hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS pressure and temperature less than i
psig and 35'O'F. within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
I'600 3.3.1.5 The requirements of 3.3.1.1d through h may be modified to allow components to be inoperable at any. one time.
V 1t More than one component may be'noperable at any one time provided that one train of the ECCS is operable.
If the requirements of 3.3.1.1d through h are not satisfied within the time period specified below, the reactor shall be placed in hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350'F in an ad-ditional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
- a. One residual heat removal pump may be out of service provided the pump is restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
3~3 3 Proposed
f>
I N
- b. One residual heat removal heat exchanger may be out, of service for a period of no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
- c. Any valve, interlock, or piping required for the functioning of one safety injection train and/or one low head safety injection train (RHR) may be inoperable provided repairs are completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (except as specified in e. below).
- d. Power may be restored to'ny valve referenced in 3.3.1.1 g for the purposes of valve testing provided no more than one such valve has power restored and a
provided testing is completed and power removed 7 within 12, hours. II
> w
- e. Tho'se check valves specified in 3.3.1.1 h may be inoperable (greater than 5.0 gpm leakage) provided the inline MOVs are de-energized closed and repairs are completed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
3.3.1.6 Except during diesel generator load and safeguard sequence testing or when the vessel head is removed, or the steam generator primary system manway is open, no more than one safety injection pump shall be operable whenever the overpressure portection system is required to be operable.
3.3.1.6.1 Whenever only one safety injection pump may be operable by 3.3.1.6, at least two of the three safety injection pumps shall be demonstrated inoperable a minimum of once per twelve hours by verifying that the control switches are in the pull-stop position.
Amendment No.
3.3-4 Proposed
~ W Vv li
3.3.2 Containment Coolin and Iodine Removal 3.3.2.1 The reactor shall not be taken above cold shutdown unless the following conditions are met:
- a. The spray additive tank contains not less than 4500 gallons of solution with a sodium hydroxide t kl It concentration 'of not less"than 30%.by weight.
I
- b. Both containment spray pumps are operable.
- c. Four recirculation fan cool'er units including the associated HEPA filter units with demisters are operable.
- d. Both post accident charcoal filter units are operable.
- e. All valves and piping associated with the above components which are required to function during accident conditions are operable.
3.3.2.2
~ ~ ~ The requirements of 3.3.2.1 may be modified to allow components to be inoperable at any one time provided that 1) the time limits and other requirements specified in a through f below are satisfied, and 2) at least 1 containment spray pump, 3 fan cooler units, 3 HEPA filter units with demisters, and 1 charcoal filter unit and all required valves and piping associated with these components are operable. If these require-ments are not satisfied, the reactor shall be in hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. If the requirements are not satisfied within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, be in cold shutdown within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- a. One HEPA filter unit or demister and/or associated 0 recirculation fan cooler may be inoperable for a period of no more than 7 days.
3.3-5 Proposed
k I
c$ ,
,( I I
'II II l
1l f
'I
- b. One containment spray pump may be inoperable provided the pump is restored to operable status within 3 days.
- c. Any valve or piping in a system, required to function during accident conditions, may be inoperable provided it is restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
- d. One post accident charcoal filter unit and/or its II associated .fan cooler may be inoperable p'rovided I4 the unit is restored to operable status within 7 days ~
- e. The spray additive system may be inoperable for a period of no more than 3 days provided that. both charcoal filter units are operable.
3.3.3 Com onent Coolin S stem 3.3.3.1 The reactor shall not be taken above cold shutdown unless the following conditions are met:
- a. Both component cooling pumps are operable.
- b. Both component cooling heat exchangers are operable.
- c. All valves, interlocks and piping associated with the above components which are required to function during accident conditions are operable.
3.3.3.2 The requirements of 3.3.3.1 may be modified to allow one of the following components to be inoperable at any one time. If the system is not restored to meet the conditions of 3.3.3.1 within the time period 3.3-6 Proposed
I K
I I
specified, the reactor shall be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. If the requirements of 3.3.3.1 are not. satisfied within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be in the cold shutdown condition within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. If neither component cooling water loop is operable, the reactor shall be maintained below a reactor coolant system temperature of 350'F instead of at cold shutdown and corrective action shall be initiated to restore a component cooling water loop to operable status as soon as possible.
- a. One component cooling pump may be out of service provided the pump is restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- b. One heat. exchanger or other passive component, may be out of service provided the system may still operate at 100% capacity and repairs are completed within 24 hours.
3.3.4 Service Water S stem 3.3.4.1 The reactor shall not be taken above cold shutdown unless the following conditions are met:
- a. At least two service water pumps, one on bus 17 and one on bus 18, and one loop header are operable.
- b. All valves, interlocks, and piping associated with the operation of two pumps are operable.
3.3.4.2 Any time that the conditions of 3.3.4.1 above cannot be met, the reactor shall be placed in hot. shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Amendment; No.
Pl 3 ~3 7 Proposed
l 3.3.5 Control Room Emer enc Air Treatment S stem 3.3.5.1 The RCS temperature shall not be at or above 350'F unless the control room emergency air treatment system is operable.
3.3.5.2 The requirements of 3.3.5.1 may be modified to allow the control"room'mergency air,"treatment system to be,.
inoperable for a period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. If the system is not made operable within those 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor 1
t shall be placed in hot, shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and the RCS temperature less than 350 F in an additional 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Basis The normal procedure for starting the reactor is, first to heat the
- 3. 3-8 Proposed
0 i
'h
'1 P
h
't , t 1
h
The facility has four service water pumps. Only one is needed during the injection phase, and two are required during the recirculation phase of a postulated loss-of-coolant accident. (8) The control room emergency air treatment system is designed to filter the control room atmosphere during periods when the control room is isolated and to maintain radiation levels in the control room at acceptable levels following the Design I
Basis Accident;.' gb Reactor operation may continue for
- I a limited time while repairs are being made to the air treatment system since it is unlikely that the system would be needed. Technical Specification 3.3.5 applies only to the equipment necessary to filter the control room atmosphere. Equipment necessary to initiate isolation of the control room is covered by another specification.
The limits for the accumulator pressure and volume assure the required amount of water injection during an accident, and are based on values used for the accident analyses. The indicated level of 50% corresponds to 1108 cubic feet of water in the accumulator and the indicated level of 82% corresponds to 1134 cubic feet.
The limitation of no more than one safety injection pump to be operable and the surveillance requirement to verify that two safety injection pumps are inoperable below 330'F provides assurance that a mass addition pressure transient can be relieved by the operation of 3 ~ 3 13 Proposed
I if K
'k C
a single PORV.
References (1) FSAR Section 9.3 (2) FSAR Section 6.2 (3) FSAR Section 6.3 (4) FSAR Section 14.3.5 (5) FSAR Section 1.2 (6) FSAR Section 9.3 (7) FSAR Section 14.3 (8) FSAR Section 9.4 (9) FSAR Section 14.3.5 3.3-14 Proposed
cAr t l jk
'I
Turbine C cle A licabilit Applies to the operating status of turbine cycle.
~b'o define conditions of the turbine cycle steam-relieving capacity. Auxiliary Feedwater System and Service Water System operation is necessary to ensure the capability to remove decay heat from the core. The Standby Auxiliary Feedwater System provides additional assurance of capability to remove decay heat from the core should the Auxiliary Feedwater System be unavailable.
When the RCS temperature is at or above 350'F, the following conditi'ons shall be met:
- a. A 'minimum turbine cycle code approved steam-relieving capability of eight (8) main steam valves available (except for testing of the main steam safety valves).
- b. Two motor driven auxiliary feedwater pumps and their associated flow paths (including backup supply from the Service Water System) must be operable.
- c. The steam turbine driven auxiliary feedwater pump must be capable of being powered from an operable steam supply system, and the pump's associated flow path (including backup supply from the Service Water System) must be operable. The steam turbine driven auxiliary feedwater pump must be shown to be operable prior to exceeding 5% power.
- d. A minimum of 22,500 gallons of water shall be available in the condensate storage tanks for the Auxiliary Feedwater System.
- e. Two Standby Auxiliary Feedwater pumps and associated flow paths (including flow path from the Service Water System) must be operable.
Actions To Be Taken If Conditions of 3.4.1 Are Not Met
- a. With one or more main steam code safety valves inoperable, restore the inoperable valve(s) to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in at least 3.4-1 Amendment No.
Proposed
+
I E
yr l N W
1(
tf ll '4l P
,II
'I
hot",shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at "an RCS temperature below 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
- b. With one auxiliary feedwater pump or its flow path inoperable, restore the pump or flow path to operable status within 7 days. If the pump or flow path is not, restored to operable status within 7 days submit a Special Report within an additional 30 days in accordance with Specification 6.9.2 outlining the cause of the inoperability and plans for restoring the pump or flow path to operable status.
- c. With two auxiliary feedwater pumps or their flow paths inoperable, restore the inoperable pumps or flow paths to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature below 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
- d. With one standby auxiliary feed pump or flow path inoperable, restore the inoperable pumps or flow paths to operable status within 7 days or be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature below 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
O e. With the required 22,500 gallons of water unavailable in the condensate storage tanks, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, either:
- 1. Restore the required amount of water, or
- 2. Demonstrate the operability of the Service Water System as a backup supply to the auxiliary feed system and restore the required amount of water in the condensate storage tanks within 7 days, or
- 3. Be in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature of less than 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Basis
~'
reactor shutdown from power requires removal of core decay heat. Immediate decay heat. removal requirements are normally satisfied by the steam bypass to the condenser. Therefore, core decay heat can be continuously dissipated via the steam bypass to the condenser as feedwater in the steam generator is converted to steam by heat absorption. Normally, the capability to return
. feedwater flow to the steam generators is provided by operation of the turbine cycle feedwater system.
3.4-2 Proposed
j, l" tl i l 0
1 8
The eight main steam safety valves have a total combined rated capability of 6,580,000 lbs/hr. This capability exceeds the total full power steam flow of 6,577,279 lbs/hr. In the event of complete loss of off-site electrical power to the station, decay heat removal is assured by either the steam-driven auxiliary feedwater pump or one of the two motor-driven auxiliary feedwater pumps, and steam discharge to the atmospherygjy)the main steam safety valves or atmospheric relief valves. The turbine driven pump can supply 200% of the required feedwater and one motor-driven auxiliary feedwater pump can supply 100% of the required feedwater for, removal of decay heat from the plant, so any combination of two pumps can remove decay heat with a postu-lated single failure of one pump. The minimum amount of water in the
'" heat",condensate storage tanks is the amount needed to qpove decay for 2"hours after reactor scram from, full power. An unlimited supply is, available from,,the 'lake via either leg of the pl'ant service water system for'n indefinite time period.
The Standby Auxiliary Feedwater System is provided to give additional assurance of the capability to remove decay heat from the reactor.
The system would be used only if none of the auxiliary feedwater pumps were available to perform their intended function. Since operability requirements are established for the auxiliary unlikely event, should disable all auxiliary feedwater pumps. The specified time to restore the Standby System to full capability is longer than for other components since the probabiHty of being regnired to use the Standby System is extremely low.
References:
(1) FSAR Section 10.4 (2) FSAR Section 14.1.9 (3) "Effects of High Energy Pipe Breaks Outside the Containment, Building" submitted by letter dated November 1, 1973 from J. W. Amish, Rochester Gas and Electric Corporation to A. Giambusso, Deputy Director for Reactor Projects.
U.S. Atomic Energy Commission (4) L. D. White, Jr. letter to Mr. D. L. Ziemann, USNRC dated March 28, 1980 3.4-3 Proposed
l.
H
/
Instrumentation S stems Ob'ective To delineate the conditions of the plant instrumentation and safety circuits. !
S ecification 3.5.1 Protection System Instrumentation 3.5.1.1 The Protection System Instrumentation shown on Table 3.5-1 shall be operable whenever the conditions specified in Column 6 are exceeded.
3.5.1.2 In the event the number of channels of a particular sub-system falls below the limits given in the columns 1 or 3 of Table 3.5-1, action shall be taken according to the requirements shown in column 5 of Table 3.5-1.
3.5.2 Engineered Safety Feature Actuation Instrumentation 3.5.2.1 The Engineered Safety Feature Actuation System (ESFAS) instrumentation channels shown in Table 3.5-2 shall be operable with their trip setpoints set consistent with the values shown in the Trip Setpoint column of Table 3.5-4, whenever the conditions specified in column 6 of Table 3.5-2 are exceeded.
3.5.2.2 In the event the number of channels of a particular subsystem falls below the limits given in columns 1 or 3 of Table 3.5-2, action shall be taken according to the requirements of column 5 of Table 3.5-2.
3.5.2.3 With an instrumentation channel trip setpoint, less conservative than the value shown in the Allowable Values column of Table 3.5-4, declare the channel inoperable and take action according to the require-ments of column 5 of Table 3.5-2 until the channel is restored to operable status with the trip setpoint adjusted consistent with the Trip Setpoint value.
3.5.3 Accident Monitoring Instrumentation 3.5.3.1 The accident monitoring instrumentation channels shown in Table 3.5-3 shall be operable whenever the reactor is at or above hot shutdown.
Amendment No.
- 3. 5-1 Proposed
4 1
3.5.3.2
~ ~ When required by 3.5.3.1, with the number of operable 0 accident monitoring instrumentation channels less than the Total Number of Channels shown in Table 3.5-3, either restore the inoperable channel(s) to operable status within 7 days, or be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
3.5.3.3 When required by 3.5.3.1, with the number of operable accident monitoring instrumentation channels less than the Minimum Channels Operable requirements of Table 3.5-3 either restore the inoperable channel(s) to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
3.5.4 The radiation accident. monitoring instrumentation channels shown in Table 3.5-7 shall be operable, whenever the reactor is at or above hot shutdown.
With one or more radiation -monitoring channels inoperable, take the action shown in Table3.5-7,. Startup may commence or conti'nue consistent with the action statement.
E. I /
3.5.5 Radioactive Effluent Monitoring Instrumentation 3.5.5.1 The radioactive effluent monitoring instrumentation shown in Table 3.5-5,shall be operable at all time~
with alarm and/or trip setpoints set to insure that the limits of Specifications 3.9.1.1 and 3.9.2.1 are not exceeded. Alarm and/or trip setpoints .shall be established in accordance with calculational methods set forth in the Offsite Dose Calculation Manual.
3.5.5.2 If the setpoint for a radioactive effluent monitor alarm and/or trip is found to be higher than required, one of the following three measures shall be taken immediately:
(i) the setpoint shall be immediately corrected without declaring the channel inoperable; or immediately suspend the release of effluents monitored by the effected channel; or (iii) declare the channel inoperable.
3.5.5.3 If the number of channels which are operable is to be less than required, take the action shown found in Table 3.5-5.
3.5.6 Control Room HVAC Detection Systems 3.5.6.1
~ ~ ~ During all modes of plant operation, detection systems for chlorine gas, ammonia gas and radioactivity in the control room HVAC intake shall be operable with setpoints to isolate air intake adjusted as follows:
3.5-2 Amendment. No. p Proposed
'J
'C h
W C p /
4
chlorine, < 5 ppm ammonia, < 35 mg/m 3 radioactivity, particulate < 1 x 10 iodine < 9 x 10 noble gas < 1 x 10 3.5.6.2 With one of the detection systems inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> isolate the control room HVAC air intake. Maintain the air intake isolated except for short periods, not to exceed 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> a day, when fresh'ir makeup is allowed to improve the working environment in the control room.
Basis During plant operations, the complete instrumentation system will normally, be operable. Reactor safety is provided by the Reactor Protection System, which automatically initiates appropriate action to prevent exceeding established limits,. Safety is not compromised, however, by continuing operation'ith certain instrumentation channels i.noperable since provisions were made for this in the plant, design. This specification outlines limiting conditions for operation necessary to- preserve the effectiveness of the reactor contxol and protection system'when 'any one or more of the channels is inoperable.
Almost all reactor protection channels are supplied with sufficient redundancy to provide the capability for channel calibration and test at power. Exceptions are backup channels such as reactor coolant pump breakers. The removal of one trip channel is accom-plished by placing that channel bistable in a tripped mode; e.g.,
a two-out-of-three circuit becomes a one-out-of-two circuit.
Testing does not trip the system unless a trip condition exists in a concurrent channel.
The operability of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess these variables during and following an accident. This capability is consistent with the recommendations of NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations".
The radioactive liquid effluent instrumentation is provided to monitor and/or control, as applicable, the releases of radioactive materials in liquid effluents. The alarm and/or trip setpoints for these instruments are calculated in accordance with the ODCM to ensure that alarm and/or trip will occur prior to exceeding the limits of 10 CFR Part 20. The operability and use of this instrumentation is consistent with the r'equirements of General Design Criteria 60, 63 and 64 of Appendix A to 10 CFR Part 50.
3.5-3 Proposed
C>
~
> e ff )[
The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents. The alarm and/or trip setpoints for these instruments are calculated in accordance with the ODCN to ensure that alarm and/or trip will occur prior to-exceeding the limits of 10 CFR Part 20. This instrumentation also includes provisions for monitoring the concentrations of potentially explosive gas mixtures in the waste gas holdup system. The operability and use of this instrumentation is consistent with the requirements of General Design Criterion 64 of Appendix A to 10 CFR Part 50.
Il '1 Control room HVAC detection. systems are designed to prevent the intake of chlorine, ammonia and radiation at concentrations which may prevent plant operators from performing their required functions.
Concentrations which initiate isolation of the control room HVAC system have been established using the guidance of several established references (2-4).
The chlorine isolation setpoint is 1/3 of the toxicity limit of reference 2 but slightly greater than the short term exposure limit of reference 4. The ammonia setpoint is established at approximately 1/3 of the toxicity limit for anhydrous ammonia in reference 2 and equal to the short term exposure limit of reference
- 4. The setpoints for radioactivity correspond to the maximum p ermissible concentrations of reference 3 for Cs-137, I-131 and Kr-85.
References
- l. Updated FSAR Section 7.2.
- 2. USNRC Regulatory Guide 1.78, June 1974, Assumptions for Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release.
- 3. 10 CFR 20 Appendix B, Table I.
- 4. Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment, 1982. Published by American Conference of Governmental Industrial Hygienists.
3.5-4 Proposed
P ll , ~
a'~
n ABLE 3.5-1 PROTECTION SYSTEM INSTRUMENTATION 5
OPERATOR ACTION TOTAL NO. of MIN. PERMISSIBLE IF CONDITIONS OF CHANNEL NO. of CHANNELS OPERABLE BYPASS COLUMN 1 OR 3 OPERABLE NO. FUNCTIONAL UNIT CHANNELS TO TRIP CHANNELS CONDITIONS CANNOT BE MET ABOVE 1,. Manual when RCCA is withdrawn
- 2. Nuclear Flux Power Range For low setting, 2 Note 1 when RCCA is low setting 4 3 2 of 4 power range withdrawn channels greater than 10/ F.P.
high setting 4 when RCCA is withdrawn 3: Nuclear Flux Intermediate of 4 power range 3 Note 1 is E.'ange
= 2 1 2 channels greater than 10/ F.P.
when RCCA withdrawn
- 4. Nuclear Flux Source Range 2 2 1 of 2 intermediate 4 Note 1 Note 2 range channels greater than 10 ]0 amps.
Note 3 5 ~ Overtemperature 6 T Hot Shutdown
- 6. Overpower b, T Hot Shutdown 0 7. Iow Pressurizer 5/ power
'Z$
0 Pressure 8
Q 8. Hi Pressurizer Pressure 3 Hot Shutdown
- 9. Pressurizer-Hi Water 5% power Level
- 10. Low Flow in one loop 3/loop 2/loop 2/loop 5% power
(> 50/ F.P.) (either loop) (both loops)
Low Flow both loops 3/loop 2/loop 2/loop 5% power (8.5%-50% F.P.) (both loops) (either loop)
k
't yA ft V
- 'vl pl
~h
TABLE 3.5-1 (Continued)
PROTECTION SYSTEM INSTRUMENTATION 5
OPERATOR ACTION TOTAL NO. of MIN. PERMISSIBLE IF CONDITIONS OF CHANNEL NO. of CHANNELS OPERABLE BYPASS COLUMN 1 OR 3 OPERABLE NO. FUNCTIONAL UNIT CHANNELS TO TRIP CHANNEIS CONDITIONS CANNOT BE MET ABOVE ll. Turbine Trip 50% Power-
- 12. Steam Flow Feedwater 2 SF-FF 1 SF-FF 2 SF-FF Hot Shutdown flow mismatch with and 2 SG coincident or 2 Io Lo Steam Generator level per w/ 1 Io SG SG level Level loop level in per loop same loop
- 13. To Lo Steam Genera- 3/loop 2/loop 2/loop Hot Shutdown -
late tor Mater Ievel Vl Ch I 14. Undervoltage 4 KV 2/bus 1/bus 2/bus 5/ Power Bus (both busses) {on either bus)
- 15. Underfrequency 4 KV 2/bus 1/bus 2/bus 5% Power Bus (both busses) (on either bus)
- 16. Quadrant power NA Log individual Hot Shutdown-tilt monitor upper 6 lower ion (upper 6 lower chamber currents ex-core neutron once/hr 8 after detectors) a load change of 0 1O% or after 30" d of control rod 0
motion S
Q
I't 1
I
'\
II
TABLE 3.5-1 (Continued)
PROTECTION SYSTEM INSTRUMENTATION 5
OPERATOR ACTION TOTAL NO. of MIN. PERMISSIBLE IF CONDITIONS OF CHANNEL NO. of CHANNELS OPERABLE BYPASS COLUMN 1 OR 3 OPERABLE NO. FUNCTIONAL UNIT CHANNELS TO TRIP CHANNELS CONDITIONS CANNOT BE MET ABOVE
- 17. Circulating Mater Flood Protection
- a. Condenser Power-.operation Hot Shutdown may be continued for a period of up to 7 days with 1 channel inoperable or for a period of 24 hrs. with two channels inoperable.
lA Otherwise be in Vl hot shutdown in an I additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
- b. Screenhouse 2< Power operation Hot Shutdown may be continued for a period of up to 7 days with 1 channel inoperable or for a period of 0 24 hrs. with two 0 channels inoperable.
'0 0
Otherwise be in hot shutdown in an 8 additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
- 18. Ioss of Voltage 2 sets lof2 2of2 TRCS 350 F 480V Safeguards Bus of 2/bus in each in one set in of the one bus two sets
J H
I I
jt l
1t
TABLE 3.5-1 (Continued)
PROTECTION SYSTEM INSTRUMENTATION 5
OPERATOR ACTION TOTAL NO. of MIN. PERMISSIBIE IF CONDITIONS OF CHANNEL NO. of CHANNELS OPERABIE BYPASS COLUMN 1 OR 3 OPERABIE NO. FUNCTIONAL UNIT CHANNELS TO TRIP CHANNELS CONDITIONS CANNOT BE MET ABOVE
- 19. Degraded Voltage 2/bus 2/bus 1/bus T 350 F 480V Safeguards Bus 4J Vl I
CO NOTE 1: When block condition exists, maintain normal operation.
NOTE 2: Channels shall be operable at all modes below the bypass condition with the reactor trip system breakers in the closed position and control rod drive system capable of rod withdrawal.
0 NOTE 3: Channels shall be operable of all modes below the bypass condition
'd 0 except during refueling defined to be when fuel is in the reactor 8 vessel with the vessel head closure bolts less than fully tensioned A or with the head removed.
F.P. = Full Power Ad AA A channel is considered operable with 1 out of 2 logic or 2 out of 3 logic.
c C
I H I',4
> a
TABLE 3.5-2 ENGINEERED SAFETY FEATURE ACTUATION INSTRUMENTATION 2 3 4 5 OPERATOR ACTION TOTAL NO. of MIN. PERMISSIBLE IF CONDITIONS OF CHANNEL NO. of CHANNEIS OPERABLE BYPASS COLUMN 1 OR 3 OPERABLE NO. 'FUNCTIONAI UNIT CHANNELS TO TRIP CHANNELS CONDITIONS CANNOT BE MET ABOVE
- 1. SAFETY INJECTION
- a. Manual RCS
- b. High Containment RCS Pressure
- c. Steam Generator Primary TRCS 350 F Cow Steam pressure Pressure/Loop less than 4) 2000 psig Vl Pressurizer Low Primary T = 350 F I
Pressure pressure less than 2000 psig
= a. Manual 10 Cold Shutdown 2'of3
'0 b. Hi-Hi Containment 2 sets 2 per set Cold Shutdown 0
'6 Pressure (Contain- of 3 in both in either 0 ment Spray) sets set 8
0
="'""
Must actuate 2 switches simultaneously.
f,
'K t'
TABLE 3.5-2 (Continued)
ENGINEERED SAFETY FEATURE ACTUATION INSTRUMENTATION 4 5 OPERATOR ACTION TOTAL NO. of MIN. PERMISSIBLE IF CONDITIONS OF CHANNEL NO. of CHANNELS OPERABLE BYPASS COLUMN 1 OR 3 OPERABLE NO. FUNCTIONAL UNIT CHANNELS TO TRIP CHANNELS CONDITIONS CANNOT BE MET ABOVE
- 3. AUXILIARYFEEDWATER Motor and Turbine Driven a.. Manual 1/pump 1/pump 1/pump RCS
- b. Stm. Gen. Water Level-low-low
- i. Start Motor 3/stm.gen. 2/stm.gen. 2/stm.gen. TRCS 350 F 4J Driven Pumps either gen. both gen.
Vl I ii. Start Turbine 3/stm.gen. 2/stm.gen. 2/stm.gen. 12 RCS C) Driven Pump both gen. either gen.
Turbine Driven Pump
- d. Safety Injection (see Item 1)
Start Motor Driven 0 Pumps
'0 0
N 8 e. Trip of both Feed- 2/pump 1/pump 2/pump 5% power 0 water Pumps starts both pumps either pump Motor Driven Pumps Standb Motor Driven
- a. Manual 1/pump 1/pump 1/pump TRCS 350oF
C TABLE 3.5-2 (Continued)
ENGINEERED SAFETY FEATURE ACTUATION INSTRUMENTATION 4 5 OPERATOR ACTION TOTAI NO. of MIN. PERMISSIBLE IF CONDITIONS OF CHANNEL NO. of CHANNELS OPERABLE BYPASS COLUMN 1 OR 3 OPERABLE NO. FUNCTIONAL UNIT CHANNELS TO TRIP" CHANNELS CONDITIONS CANNOT BE MET ABOVE
- 4. CONTAINMENT ISOLATION 4.1 Containment Isolation
- a. Manual 10 Cold Shutdown
- b. Safety Injection (See Table 3.5-2, Item 1)
(Auto Actuation) 4J 4.2 Containment Ventilation Vl Isolation I
a Manual 13 Cold Shutdown
- b. High Containment 13 Cold Shutdown Radioactivity C. Manual Spray (See Table 3.5-2, Item 2a)
- d. Sa fety Inj ection (See Table 3.5-2, Item 1) 0
'6 0
Q
,,y TABLE 3.5-2 (Continued)
ENGINEERED SAFETY FEATURE ACTUATION INSTRUMENTATION 2 3 4 5 OPERATOR ACTION TOTAL NO. of MIN. PERMISSIBLE IF CONDITIONS OF CHANNEL NO. of CHANNELS OPERABLE BYPASS COLUMN 1 OR 3 OPERABLE NO. FUNCTIONAL UNIT CHANNEIS TO TRIP CHANNELS CONDITIONS CANNOT BE MET ABOVE
- 5. STEAM LINE ISOLATION
- a. Hi-Hi Steam Flow 2 Hi-Hi SF 1 SF with 12 ='T = 350 F with Safety Injection with S.I. S.I. in w/51V's open for each loop each loop
- b. Hi Steam'low and 2 Hi SF and 1 Hi SF and 12 '~T = 350oF 2 of 4- Low T with 4 low T 2Iow T w/5%V's open Safety Injec07on with S.I. Nr with S.k. for each loop each loop
- c. Containment T 350 oF Pressure w/5$ V's open d.. Manual 1/loop 1/loop 1/loop 35PoF w/%IV's open
- 6. FEEDWATER LINE ISOLATION
- a. Safety Injection (See Table 3.5-2, Item 1)
- b. Hi Steam Generator 3/loop 2/loop in 2/loop in 35PoF Level either loop both loops w/F5 ksol valves open
.RCS temperature may be above 350 F if MSIV's are closed.
RCS temperature may be above 350 F if FW Isol. valves are closed.
~ - Both trains must be capable of providing a S.I. signal to each loop.
e V
(,
L
ACTION STATEMENTS With the number of operable channels one less than the Minimum Operable Channels requirement, restore the inoperable channel .to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in hot shutdown with all RCCA's fully inserted within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
With the number of operable channels one less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the tripped condition within 1 houi and the requirements for the minimum number of channels operable are satisfied. However, the inoperable channel may be bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing of other channels.
With the number of operable channels less than the Minimum Operable Channels requirement, be at a condition where operability is not. required according to Column 6 of Table 3.5-1 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
With the number of operable channels one less than the Minimum Operable Channels requirement, suspend all operations involving positive reactivity changes and have all RCCA's fully inserted within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
With the number of operable channels one less than the Minimum Operable Channels requirement, suspend all operations involving positive reactivity changes. If the channel is not restored to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, open the reactor trip breaker within the next hour.
With the number of operable channels one less than the Total Number of Channels, operation may proceed until the next Channel Functional Test provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. With the number of operable channels one less than the Minimum Operable Channels requirement, or at the time of the next required Channel Functional Test, referenced above, be at a condition where channel operability is not required according to Column 6 of Table 3.5-1 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
With the number of operable channels less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Should the next Channel Functional Test require the bypass of an inoperable channel to avoid, the generation of a reactor trip signal, operation may proceed until this Channel Functional Test. At the time of this next Channel Functional Test, or if at any time the number of operable channels is less than the Minimum Operable Channels, be at a condtion where channel operability is not required according to Column 6 of Table 3.5-1 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
3.5-'13 Proposed
t
, v. With the number of operable channels less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Should the next Channel Functional Test require the bypass of an inoperable channel to avoid the generation of a trip signal, operation may proceed until this Channel Functional Test. At the time of this Channel Functional Test, or any time the number of operable channels is less than the if at Minimum Operable Channels, either a) be at Hot Shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and and RCS temperature less than 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or b) energize the affected bus with a diesel generator.
- 8. With the number of operable channels one less than the Minimum Operable Channels required, restore the inoperable channel to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in Hot Shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
With the number of operable channels one less than the Total Number of Channels required, operation may proceed until the next Channel Functional Test provided the inoperable channel is placed in the tripped position within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. At the next Channel Functional Test, or at any time the number of operable channels is less than the Minimum Operable Channels required, be at Hot Shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
With the number of operable channels one less than the Minimum Operable Channels required, restore the -inoperable channel to operable status within',48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or, be in, Hot Shutdown within an additional ',30 h'ours.
With the number of operable channels less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Should the next Channel Functional Test require the bypass of an inoperable channel to avoid the generation of an actuation signal, operation may proceed until this Channel Functional Test. At the time of this Channel Functional Test, or if at any time the number of operable channels is less than the Minimum Operable Channels required, be at Hot, Shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
3.5-14 Proposed
I' c, y, e k
- 12. With the nubmer of operable channels less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Should the next Channel Functional Test require the bypass of an inoperable chanlel to avoid the generation of an actuation signal, operation may proceed until this Channel Functional Test. At the time of this Channel Functional Test, or if at any time the number of operable channels is less than the Minimum Operable Channels required, be at hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350'F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
- 13. With the number of operable channels less than the Minimum Operable Channels required, operation may continue provided the containment purge and exhaust valves are maintained closed.
pl f
3.5-15 Proposed
1 C'
f A'
Table 3.5-3 Accident Monitorin Instrumentation TOTAL REQUIRED MINIMUM NO. OF CHANNELS INSTRUMENT CHANNELS (7) OPERABLE (7)
- 1. Pressurizer Water Level (1) 2 1
- 2. Auxiliary Feedwater Flow Rate (2)(3) 2/steam generator 1/steam generator
- 3. Steam GeneratoriWater Level- ,1/steam generator '/steam generator Wide Range (3)
- 4. Reactor Coolant System Subcooling Margin Monitor (4)
- 5. Pressurizer PORV Position 2/Valve 1/Valve Indicator (5)
- 6. PORV Block Valve Position 1/Valve 0/Valve Indicator (1)
- 7. Pressurizer Safety Valve 2/Valve 1/Valve Position Indicator (5)
- 8. Containment Pressure (8)
- 9. Containment Water Level (Narrow 1(6) 1(6)
Range, Sump A)
- 10. Containment Water Level (Wide Range, Sump B) ll. Core-Exit Thermocouples 4/core quadrant 2/core quadrant Notes (1) Emergency power for pressurizer equipment, NUREG-0737, item II.G.l.
(2) Auxiliary feedwater system flow indication, NUREG-0737, item II.E.1.2.
(3) Only' out of the 3 indications (two steam generator auxiliary feedwater flow and one wide-range steam generator level) are required to be operable, NUREG-0737, item II.E.1.2.
(4) Instrumentation for detection of inadequate core cooling, NUREG-0737, item II.F.2.1.
(5) Direct indication of relief and safety valve position, NUREG-0737, item II.D.3. Two channels include a primary detector and RTD as the backup detector.
(6) Operation may continue with less than the minimum channels operable provided that the requirements of Technical Specification 3.1.5.1 are met.
(7) See Specification 3.5.3 for required action.
(8) Containment pressure monitor, NUREG-0737, item II.F.1.4.
3.5-16 Amen)ment No.g Proposed
r hg w t H
ABLE 3.5-4 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS FUNCTIONAL UNIT TRIP SETPOINT ALI,OWABIE VALUES"=
1.. = SAFETY .INJECTION AND FEEDWATER ISOLATION
- a. Manual Initiation Not Applicable Not Applicable
't
- b. High Containment Pressure < 4.0 psig < 5.0 psig
- c. Low Pressurizer Pressure 1723 psig 1715 psig
- d. Iow. Steam Line Pressure > 514 psig > 500 psig
'a. Manual Initiation Not Applicable Not Applicable 4J Ul
,b. High-High Containment Pressure < 28 psig < 30 psig I
3".=- CONTAINMENT ISOI ATION
= .-" a. Containment Isolation
- 1. Manual Not Applicable Not Applicable
- 2. From Safety Injection Not Applicable Not Applicable 0 Automatic Actuation Iogic
'0 0
8 b. Containment Ventilation Isolation
- 1. Manual Not Applicable Not Applicable
- 2. High Containment Note 3 Not Applicable Radioactivity
- 3. From Safety Injection Not Applicable Not Applicable
- 4. Manual Spray Not Applicable Not Applicable
C f>
t f
)(
N p
~(
I l)
I'
TABIE 3.5-4 (Continued)
ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS FUNCTIONAL UNIT TRIP SETPOINT ALIOWABLE VALUES"'.
- 4. STEAM LINE ISOLATION Manual Not Applicable Not Applicable
- b. High Containment Pressure < 18 psig < 20 psig C. High Steam Flow, Coincident dp corresponding to dp correspogding to with, Low T and SI < 0.49 x 10 lbs/hr < 0.55 x 10 lbs/hr avg at 755 psig at 755 psig T > 545oF T > 543oP avg avg
- d. High-High Steam Line Flow dp correspgnding dp corresponding Coincident with SI < 3.6 x 10 lbs/hr to < 3.7 x 10 lbs/hr 4J at 755 psig at 755 psig Vl I
I 5. PEED WATER ISOLATION co
- a. High Steam Generator Water < 67/ of narrow range < 68/ of narrow range Ievel instrument span each instrument span each steam generator steam generator
- 6. AUXILIARYPEEDWATER 0- a. Iow-Iow Steam Generator > 17/ of narrow'ange > 16/ of narrow range Water Level instrument span each instrument span each 0 steam generator steam generator. See 8 Note 1.
- b. From Safety Injection N.A. N.A.
C. Loss of 4 kV Voltage 62/ of 4160 volts (Start TAPP) Note 2 Note 2
- d. Peedwater Pump Breakers Not Applicable Not Applicable Open (start MAFP)
TABLE 3.5-4 (Continued)
ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS FUNCTIONAL UNIT TRIP SETPOINT ALLOWABLE VALUES
- 7. LOSS OF VOLTAGE
- a. 480 V Safeguards Bus Under- see Figure 2.3-1 voltage (Loss of Voltage)
- b. 480 V Safeguards Bus Under- see Figure 2.3-1 voltage (Degraded Voltage)
- 8. ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INTERLOCKS
- a. Pressurizer Pressure, 52000 psig $ 2000 psig lA (block, unblock SI)
Vl I
Note 1: A positive 11% error has been included in the setpoint to account for errors which may be introduced into the steam generator level measurement system at a containment temperature of 286~F as determined by an evaluation performed on temperature effects on level systems as required by IE Bulletin 79-21.
Note 2: This setpoint value is from inverse time curve for CVT relay (406C883) with tap setting of 82 volts and time dial setting of 1. Delay at 62/ voltage is 3.6 seconds. The allowable values are +A/ of the trip setpoint.
0
'0 0
m Note 3: The trip setpoints for containment ventilation isolation while purging shall be established to 8 correspond to the limits o'f 10 CFR Part 20 for unrestricted areas. The setpoints are determined 0 procedurally in accordance with Technical Specification 3.9.2 by calculating effluent monitor count rate limits,'hich take into account appropriate factors for detector calibration, ventilation flow rate, and average site meteorology.
=""Allowable, Values are those values assumed in accident analysis.
Iy l
f
< I El
TABLE 3.5-5 Radioactive Effluent Monitorin Instrumentation Minimum Channels
~Oerable Acti'on
- 1. Gross Activity Monitors (Liquid)
- a. Liquid Radwaste (R-18)
- b. Steam Generator Blowdown (R-19)'.
Turbine Building Floor Drains (R-21)
- d. High Conductivity Waste (R-22)
- e. Containment Fan Coolers (R-16)
- f. Spent Fuel Pool Heat Exchanger (R-20)
- 2. Plant Ventilation
- a. Noble Gas Activity (R-14) (Providing Alarm and Isolation of Gas Decay Tanks)
- b. Particulate Sampler (R-13)
- c. Iodine Sampler (R-10B or R-14A)***
- 3. Containment Purge Vent
- a. Noble Gas Activity (R-12) (see Table 3.5-2 6 Action 13 thereto)
- b. Particulate Sampler (R-11) 1+ ~ (see Table 3.5-2 & Action 13 thereto)
- c. Iodine Sampler (R-10A or R-12A)***
- 4. Air Ejector Monitor (R-15 or R-15A)***
- 5. Waste Gas System Oxygen Monitor
- Not required when Steam Generator Blowdown is being recycled (i.e. not released)
~
Required only during containment purges Not required during Cold or Refueling Shutdown See Table 3.5-6
~
- 3. 5-20 Proposed
1l l
TABLE 3.5-5 Continued Table Notation If the number of operable channels is less than required by the Minimum Channels Operable require-ment, effluent releases from the tank may continue for up to 14 days, provided that prior to initiating a release:
- l. At least two independent, samples of the tank's contents are analyzed, in accordance with Specification 4.12.1.1.a, and
- 2. At. least two technically qualified members of the Facility Staff independently verify the release rate calculations and discharge line valving; Otherwise, suspend release of radioactive effluents via this pathway.
When Steam Generator Blowdown is being released (not recycled) and the number of channels operable is less than required by the Minimum Channels Operable requirement, effluent releases via this pathway may continue for up to 31 days, provided grab samples are analyzed for gross radioactivity (beta or gamma) at a limit of detection of at most 10-7 uCi/gram:
- l. At least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when the concentration of the secondary coolant is > 0.01 uCi/gram dose equivalent I-131.
- 2. At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the concentra-tion of the secondary coolant is < 0.01 uCi/gram dose equivalent I-131.
If the number of operable channels is less than required by the Minimum Channels operable require-ment, effluent releases via this pathway may continue for up to 31 days provided that at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> grab samples are analyzed for gross radioactivity (beta or gamma) at a limit of detection of at most 10-7 uCi/gm.
If the number of operable channels is less than required by the Minimum Channels Operable require-ment, effluent. releases via this pathway may continue for up to 31 days provided grab samples are taken at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and these samples are analyzed for isotopic activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or R14A is operable and readings are reviewed at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
3 o)~21 Proposed
r
TABLE 3.5-5 Continued Table Notation If the number of operable channels is less than required. by the Minimum Channels Operable require-ment, effluent releases via this pathway may continue for up to 31 days,'rovided samples are continuously collected as required by Table 4.12-2 Item I with auxiliary sampling equipment.
If the number of operable charm'els is less than required by the Mini.mum Channels Operable and the Secondary Activity is < 1 x 10 uCi/gm, effluent releases may continue via this pathway provided grab samples are analyzed for gross radioactivity (beta or gamma) at least once per 24 hourg. If the secondary activity is greater than 1 x 10 uCi/gm, effluent releases via this pathway may continue for up to 31 days provided grab samples are taken every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and analyzed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
If the channel gas from the is inoperable, a sample of the in service gas decay tank shall be analyzed for oxygen content at least once every 4 hours.
Proposed
c C
s <"
.P 1
Table 3.5-6 Radiation Accident Monitorin Instrumentation Minimum Channels Instrument ~Oerable Action
- 1. Containment Area (R-29 and R-30)
,2. Noble Gas Effluent Monitors i Plant Vent (R-14A) *
~
ii. Main Steam Line (R-31)
A iii. Main Steam Line (R-32)
B iv ~ Containment Purge (R-12A)*
v ~ Air Ejector (R-15A)*
Action Statements 0 Action 1 With the number of operable channels less than required by the Minimum Channels Operable requirements, either restore the inoperable channel(s) to operable status within 7 days of the event, or prepare and submit a Special Report to the Commission within 30 days following the event outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to operable status.
- See Table 3.5-5 3.5-23 Amendment No.
Proposed
P'
' ~
I p 0 5 T
AUXILIARYELECTRICAL SYSTENS A licabilit Applies to the availability of electrical power for the operation of plant auxiliaries.
~b'o define those conditions of electrical power avail-ability necessary (1) to provide for safe reactor operation, and (2) to provide for the continuing availability of engineered safeguards.
The reactor shall not be maintained above cold shutdown w1thou t:
I'
- a. The 34.5 KV-4160 Volt. station service transformer in service.
- b. 480-volt buses 14, 16, 17 and 18 energized.
- c. 4160-volt buses 12A and 12B energized.
- d. Two diesel generators operable with onsite supply of 10,000 gallons of fuel available.
- e. Both batteries and both d.c. systems operable, and battery chargers with a capacity of at least 150 amps in service for each battery.
During reactor operation the requirements of 3.7.1 may be modified as follows:
3 7 1
~ Amendment No.
Proposed
r I'
I Il 't
Operation may continue with the station service transformer inoperable provided both diesel generators are operable. Otherwise the reactor shall be placed in hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdown within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Ope'ration may continue C
1
~ )1 if,one, diesel generator is inoperable provided (a) the remaining diesel generator is run continuously, and (b) the station service transformer is operable and (c) such operation is not in excess of 7 days (total for both diesels) during any month. Otherwise be in hot, shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdown within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
One of the required battery banks may be inoperable provided that within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> either:
- 1. restore the inoperable battery bank to operable status, or
- 2. verify that the output voltage of the Technical Support Center battery bank is greater than 125 volts and 150 amps of charging capacity is available and substitute it for the inoperable Amendment. No.
3~7 2 Proposed
I I
battery bank. Operation in this mode may continue for a period of no more than 7 days.
If neither 1. or 2. above are satisfied then be in at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- d. With less than 150 amps of battery charging capacity to one d.c. system, either restore 150 amps of charging capacity within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or declare the battery bank inoperable.
3.7.3 With the reactor at cold shutdown or during refueling:
- a. A 34.5KV-4160 volt station auxiliary transformer (12A or 12B) shall be in service with 4160 volt buses 12A and 12B energized.
- b. One diesel',generator shall be operable with onsite supply of 5,000 gallons of fuel available.
K c ~ Twod.c.,systems and associated battery banks lt sh'all"be operable each;with",150 amps of battery charging capacity, available. 'The Technical Support Center battery bank and charger may be used to satisfy this requirement provided the output voltage is greater than 125 volts.
3.7.4 If the requirements of 3.7.3 cannot be satisfied then immediately suspend all operations involving positive reactivity changes, core alteration, and movement of irradiated fuel, and immediately initiate corrective action to restore the required power sources to operable status.
Basis The electrical system equipment is arranged so that no single contingency can inactivate enough safeguards equipment, to jeopardize the plant safety. The 480-volt equipment. is arranged 3 7 2a
% Proposed
V I',
h
'i
, e f (
Control Rod and Power Distribution Limits A licabilit Applies to the operation of the control rods and power distribution limits.
~b'o,ensure (1) core subcriticality after a reactor ll t ll rf trip, (2)'limited potential reactivity insertions from a hypothetical control rod ejection, and (3) an acceptable core power distribution during power operation.
'f'.10.1 Control Rod Insertion Limits 3.10.1.1 When the reactor is subcritical prior to startup, the hot shutdown margin shall be at least that shown in Figure 3.10-2. The shutdown margin as used here is defined as the amount by which the reactor core would be subcritical at hot shutdown conditions (547'F) if all control rods were tripped, assuming that the highest worth control rod remained fully withdrawn, and assuming no changes in xenon or boron.
3.10-1 Proposed
I' 1 H g 'I J
l I II II
.a
3.10.1.2 When the reactor is critical except. for physics tests and control rod exercises, the shutdown control rods shall be fully withdrawn.
3.10.1.3 When the reactor is critical, except for physics tests and control rod exercises, each group of control rods shall be inserted no further than the limits shown by the lines on Figure 3.10-1 and moved sequentially with a 100 (25) step overlap between successive banks.
3.10.1.4 During control rod exercises indicated in Table 4.1-2, the insertion limits need not be observed but the Figure 3.10-2 must be observed.
3.10.1.5 During measurement of control rod worth and shutdown margin, the shutdown margin requirement, Specification 3.10.1.1, need not be observed provided the reactivity equivalent to at least the highest estimated control rod worth is available for trip insertion. Each control rod not fully inserted, that is, the rods available for trip insertion, shall be demonstrated capable of full insertion when tripped from at least the 50% withdrawn position within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing the shutdown margin to less than the limits of Specification 3.10.1.1. The position of each control rod not fully inserted, that is, available for trip insertion, shall be determined at least once per 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
3.10-2 Proposed
4 lt Wl
'I 1
I 4
C 0
A
'l
TABLE 1 (CONTINUED)
RADIOI,OGICAL ENVIRONMENTAL MONITORING PROGRAM Number of Sam les Ex osure Pathwa and Sam lin and T e and Fre uenc andor Sam le Sam le Locations Collection Fre uenc of Anal sis
- 4; INGESTION
- a. Milk 1 control At least once per 15 Gamma isotopic and 3 indicator days. I-131 analysis of June thru October each sample.
each of 3 farms 1 control At least once per 31 Gamma isotopic and 1 indicator days. I-131 analysis of November thru May each sample.
one of the farms 4)
- b. Fish 4 control Twice during fishing Gamma isotopic 4 indicator (Off season including at analysis on edible I shore at Ginna) least four species. portions of each sample.
- c. Food Products 1 control Annual at time of Gamma isotopic 2 indicator (On harvest. Sample from analysis on edible site) two of the following: portion of sample.
- 1. apples
- 2. cherries
- 3. grapes 0 1 control At time of harvest. Gamma isotopic 0 2 indicator (On One sample of: analysis on edible 8
site garden or 1 ~ broad leaf portions of each 9 nearest offsite vegetation sample.
garden within 5 2. other vegetable miles in the highest D/Q meteorological sector)
C t.
I lit "k
H
Attachment B
'+0 In April, 1980 the NRC requested that all licensees review their Technical Specifications to insure that the term "OPERABLE" was appropriately employed to preserve the single failure criterion for safety-related systems and components. RG&E conducted a review of the Ginna Technical Specifications and noted a lack of specific ACTION statements and an inconsistency between the Limiting Condition for Operation (LCO's) of the various systems and components.
As a result of this review a proposed change to the Technical Specifications was submitted to the NRC on November 10, 1983.
The comments received from the NRC staff have been incorporated into this revision as have'several other changes that were a result of further review of LCO's, ACTION statements and surveillance requirements. Attachment B to the original submittal provides the basic safety analysis of the proposed chan'ges. Additional discussion on a section by section basis is outlined, below.
3.1.1.1f This is a restatement of the paragraph for additional clarity.
There is no change in the LCO requirement.
This section was completely rewritten to conform more closely to Standard Technical Specifications and to reflect NRC staff comments.
a e 3.1-27 The definition of a significant increase in leakage was deleted from the basis because the term was deleted from the specification.
This section was also completely rewritten to conform more closely to Standard Technical Specifications and reflect NRC staff comments.
Table 3.5-5, Action 4 The option of using R-14A instead of grab samples to monitor releases, if R14 was not operable, w'as added. R-14A is redundant to R-14 with the exception that no control functions are provided when R-14A is alarmed. R-14A has a noble gas channel with the same range as R-14 and in addition incorporates two higher range channels for noble gas, an iodine channel, and a particulate channel. Data and alarms for all channels are available in the control room and the technical support center. Setpoints will provide alarms well below release rate limits.
h
'4~
lt g V t'I
Table 3.16-1, 4c This item in the Radiological Environmental Monitoring Program specified a sampling of two of a listed group of fruits. Previously only two fruits were listed. The proposed change adds grapes to the list to allow a choice of two of three.
I A safety evaluation on a section-by-section basis is outlined CI below. lf 4
P sf I