Text

Forwards Proposed Amends 179 & 133 to Licenses NPF-14 & NPF-22,respectively.Amends Revise TS to Extend AOTs for Maint & Repair & Surveillance Test Intervals Between Channel Functional Tests for Listed Groups of Instruments
	ML18026A267
Person / Time
Site:	Susquehanna
Issue date:	02/10/1995
From:	Byram R; PENNSYLVANIA POWER & LIGHT CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17164A579	List: ML17164A578; ML17164A580; ML18026A267;
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	NUDOCS 9502170190
	Download: ML18026A267 (56)
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P RIC3RIT'Y (ACCELERATED RIDS PROCESSIX(

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ACCESSION NBR:9502170190 DOC.DATE: 95/02/10 NOTARIZED: YES DOCKET I FACIL:50-387 Susquehanna Steam Electric Station, Unit 1, Pennsylva 05000387 50-388 Susquehanna Steam Electric Station, Unit 2, Pennsylva 05000388 AUTH. NAME AUTHOR AFFILIATION BYRAM,R.G. Pennsylvania Power & Light Co. P RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards proposed amends 179 & 133 to licenss NPF-14 &

NPF-22,respectively. Amends revise TS to extend AOTs for I maint & repair & surveillance test intervals between channel functional tests for listed groups of instruments. 0 DISTRIBUTION CODE: AP01D TITLE: Proprietary Review COPIES RECEIVED:LTR Distribution Pre Operating g ENCL SIZE:

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TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL 11

Pennsylvania Power & Light Company Two North Ninth Street ~ Allentown, PA 18101-1179 ~ 610/774-5151 Robert G. Byram Senior Vice President Nuclear 610/774-7502 Fax: 610/774-5019 FEB 1 0 1995 U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Mail Station P1-137 Washington, D. C. 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED AMENDMENTNO. 179 TO LICENSE NPF-14 AND PROPOSED AMENDMENTNO. 133 TO LICENSE NPF-22: AOT/STI EXTENSIONS Docket Nos. 50-387/NPF-14 and 50-388/NPF-22

Dear Sir:

This letter proposes changes to the Susquehanna SES Units 1 and 2.Technical Specifications that:

1. Extend allowable out-of-service times (AOTs) for maintenance and repair and the surveillance test intervals (STIs) between channel functional tests for the following groups of instruments:

TS 3.3.1: Reactor Protection Systems Instrumentation TS 3.3.2: Isolation Actuation Instrumentation TS 3.3.3: Emergency Core Cooling System Actuation Instrumentation TS 3.3.4.1: ATWS Recirculation Pump Trip System Instrumentation TS 3.3.4.2: End-of-Cycle Recirculation Pump Trip System Instrumentation TS 3.3.5: Reactor Core Isolation Cooling System Actuation Instrumentation TS 3.3.6: Control Rod Block Instrumentation TS 3.3.7.1: Radiation Monitoring Instrumentation TS 3.3.9: Feedwater/Main Turbine Trip System Actuation Instruinentation SSES Technical Specifications, Units 1 and 2, already incorporated AOT and STI extensions into Section 3/4.3.1, Reactor Protection System Instrumentation, based on References 1 and 2. However, this proposed change revises RPS required actions to prevent an extended AOT from resulting in an extended loss of function based on guidance provided in References 12 and 13.

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2. Change required actions and AOTs for the instrumentation listed above to make requirements consistent with supporting analysis in General Electric Topical Reports and additional actions required to prevent extended AOTs &om resulting in extended loss of instrument function. These changes are consistent with NUREG-1433, Standard Technical Specifications for General Electric Plants, BWR/4, Revision 0.

3. Change required actions and AOTs for instrumentation associated with the ADS initiation, Recirculation Pump Trip, and pump suction lineup for HPCI and RCIC so that the required actions and AOTs are consistent with NUREG-1433, Standard Technical Specifications for General Electric Plants, BWR/4, Revision 0.

4, Change to Applicability requirements and Required Actions for the Reactor Vessel Water Level - Low, Level 3 Function that isolates the RHR System Shutdown Cooling System to be consistent with NUREG-1433 so that function is required to be OPERABLE in OPERATIONAL CONDITIONS 3, 4 and 5 to prevent inadvertent loss of reactor coolant via the RHR Shutdown Cooling System during these OPERATIONAL CONDITIONS.

5. Remove notes previously added to Table 3.3.2-1, 3.3.2-2, and 4.3.1-1 to support maintenance on leak detection temperature detectors and remove the Note to TS 3.3.6 (Unit1 only) that provided one time only relief from the requirements of TS 3.0.4 on September 14, 1987 for the IRM control rod block instruments.

6. Reformat, renumber, and/or reword existing requirements to incorporate the changes above into Susquehanna Technical Specifications.

Enclosure A to this letter is the "Safety Assessment" supporting this change. Enclosure B to this letter is the "No Significant Hazards Considerations" evaluation performed in accordance with criteria of 10 CFR 50.92. The proposed changes have been reviewed by the Susquehanna SES Plant Operations Review Committee (PORC) and the Susquehanna Review Committee (SRC).

The proposed changes are consistent with Improved Standard Technical Specification.

Enclosure C to this letter are the current pages of the Susquehanna SES Units 1 and 2 Technical Specifications marked up to show proposed changes.

PPkL is committed to making these changes to enhance plant performance, reduce unnecessary testing and maintenance activities, and to better use plant personnel and resources. The proposed changes are expected to reduce the cost required to perform related maintenance and testing activities by approximately $ 360,000 per year. Based upon those savings, the proposed change satisfies the Cost Beneficial Licensing Action Criteria.

FILES R41-I/A17-2 PLA-4249 Document Control Desk PP&L plans to implement the proposed changes as soon as possible but no later than 90 days after approval. We request NRC complete the review of this change request as soon as reasonably possible but no later than June 30, 1995. Any questions regarding this request should be directed to Mr. W.W. Williams at (610) 774-5610.

Very truly yours, R. ram CC: NRC Region I Mr. C. Poslusny, Jr., NRC Sr. Project Manager - OWFN Ms. M. Banerjee, NRC Sr. Resident Inspector - SSES Mr. W. P. Dornsife, Pa. DER

ENCLOSURE A TO PLA<249 SAFETY ASSESSMENT AOT/STIZXTENSIONS NRC Generic Letter (GL) 83-28, Item 4.53, required a review of Technical Specification required intervals for on-line functional tests of the Reactor Protection System. This review was intended to ensure that the intervals for such testing are consistent with the goal of achieving high RPS availability. To respond to this issue, the BWR Owners'roup (BWROG) developed a methodology to evaluate the impact of various parameters on instrumentation system reliability. The BWROG methodology systematically evaluated RPS reliability including the impact of: uncertainties associated with component and common mode failures; reduced redundancy during testing; operator enor during testing; and, component wear caused by testing.

The approach permitted the assessment of the impact of AOTs and STIs. 'IIie results of this analysis and the associated NRC Safety Evaluation Report (SER) are documented in Reference 1.

Development of the response to (GL) 83-28, Item 4.53, resulted in the recognition that improvements in plant safety and availability could be achieved by extending STls and AOTs associated with actuation instrumentation. To facilitate obtaining NRC approval for the Technical Specification changes needed to extend AOTs and STIs, the BWR Owners'. Group developed and the NRC subsequently evaluated and approved, a methodology and an analysis based on a generic BWR for each category of actuation instrumentation in the Technical Specifications. The methodologies and results of each of these generic analyses were published as Licensing Topical Reports (References 2 through 8).

I Subsequent to NRC generic approval of the above reports, a concern was raised by the NRC that the generically approved Tech Spec wording could allow a loss of instrument function that was not bounded by the analyses that had been performed. Reference 13 addresses the NRC position that in order to extend the AOT for inoperable channels beyond one hour, the instrument function must be assured to be maintained, in order to prevent the extended AOT from resulting in an extended loss of trip capability. The proposed changes therefore require instrument function, iflost, to be restored within one hour.

Subsequent to the issuance of References 2 through 8, NUREG 0123, BWR Standard Technical Specifications, was superseded by NUREG-1433, Standard'echnical Specifications for General Electric Plants, BWR/4 (Reference 12). Reference 12 incorporates all of the requirements established in References 2 through 8 and Reference 13. Therefore, incorporation of the extended STIs and AOTs into SSES Technical Specifications will be based on the guidance provided in NUREG-1433 (Reference 12).

Changes to the minimum surveillance test intervals (STIs) and maximum allowable out-of-service times (AOTs) for the testing and/or repair of instrumentation are based on and justified by the results of generic analyses in References 1 through 8. Safety Evaluations Reports (SERs), issued by the NRC and subsequently incorporated into each of the Licensing Topical Reports (References 1 through 8), approved using the generic analyses in References 2 through 8 to justify extending the AOTs and STls of individual

, plants provided that each plant:

.ISO>>7OISO Page 1 of 92

ENCLOSURE A TO PLA-4249 a) Confirm the applicability of the generic analyses to the specific plant for the iistruments covered by each of the Topical Reports; and, b) Confirm, based on the guidance provided in Reference 11, that any increase in instrument drift due to the extended test interval is properly accounted for in the setpoint calculation methodology.

The reviews performed to satisfy these iequirements for Susquehanna Steam Electric Station, Units 1 and 2, are contained in the following attachments to this Safety Impact Assessment: : Evaluation of the Applicability of Licensing Topical Reports as Justification for Extending STIs and AOTs for Technical Specification Instimnentation for Susquehanna Steam Electric Station, Units 1 and 2; and, ; Evaluation of the Effect of Increasing the Minimum Interval between Instrument Functional Tests on the Identification of Excessive Drift of Instrument Setpoints for Susquehanna Steam Electric Station, Units 1 and 2.

Attachments 1 and 2 incorporate by reference the safety assessments contained in References 1 through 10.

The required actions and AOTs for the condition of one or more inoperable RPS instimnent channels have been modified by Amendments 115 (Unit 1) and 84 (Unit2) to extend allowable out of service times. This proposed change will add specific provisions that ensure the extended AOT will not permit an extended loss of scram function. The proposed change will replace the LCO 3.3.1, ACTIONS a. and b. with required actions and AOTs that are consistent with the NUREG-1433 (Reference 12), Section 3.3.1.1, Reactor Protection System Instrumentation, Conditions A, B, C, and D. The proposed change involves no technical changes to existing Technical Specifications except for the additional requirement: "With one or more RPS Functions with RPS trip capability not maintained, restore RPS trip capability within one hour." Existing exceptions regarding the applicability of Specification 3.0.4 are maintained.

The proposed change has a positive impact on the margin of safety because operation with loss of scram function is prohibited. The proposed format and wording are consistent with NUREG-1433 (Reference 12) and have been determined to improve the clarity and usability ofthe specification.

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ENCLOSURE A TO PLA<249 The proposed change will modify Table 43.1.1-1, Function 4, Reactor Vessel Water Level - Low, Level 3, to identify the required frequency for CHANNEL FUNCTIONALTESTING as quarterly by marking the appropriate column with the letter "Q." The frequency is currently shown as "NA,"

This change will not affect the &equency for the performance of the CHANNEL FUNCTIONAL TEST because the CHANNEL CALIBRATION is performed quarterly and a CHANNEL FUNCTIONALTEST is performed as part of the quarterly calibration. This change will make the identification of the testing requirements for this function consistent with similar functions in Table 4.3.1.1-1. This is an administmtive change with no impact on margin of safety or operator performance.

The proposed change will extend AOTs for isolation actuation instrument channels by replacing LCO 3.3.2, ACTIONS b. and c. with required actions and AOTs that are consistent with the NUREG-1433 (Reference 12), Section 33.6.1 (and 33.62), Primary (and Secondary) Containment Isolation Function, Conditions A, B, and C. Existing exceptions regarding the applicability of Specification 3.0.4 are maintained. The proposed change makes the following technical changes to the Technical Specifications:

The AOT before an inoperable channel must be placed in trip is increased from one hour to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for isolation instruments common to the reactor protection system (Table 3.32-1, functions l.a.l, l.b, l.e, 2.b, 3.b, 7.a, and 7.e) and from one hour to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for instruments not common to RPS (functions other than l.a.l, l.b, l.e, 2.b, 3.b, 7.a, and 7.e).

Justification for extending the AOTs, including the positive impact on the margin of safety and operator performance, is provided in References 5 and 6.

ii. The proposed change adds a requirement that specifically will not permit the extended AOTs to result in an extended loss of isohtion function.

The proposed change, in conjunction with other proposed changes that extend AOTs and STIs, has a positive impact on the margin of safety and operator performance for reasons described in References 5 and 6 and because operation with extended loss of any isolation function is prohibited.

The proposed format and wording are consistent with NUREG-1433 (Reference 12) and have been determined to improve the clarity and usability of the specification.

aild The proposed change adds a Note to the proposed actions for LCO 3.32 that specifies when a channel is placed in an inoperable status solely for performance of required surveillances, initiation of actions may be delayed for up to 6hours (instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months currently in Table 332-1, Note (b))

provided the associated trip function maintains isolation capability. Justification for extending this Page 3 of 92

ENCLOSURE A TO PLA-4249 AOT, including the positive impact on the margin of safety when considered in conjunction with other proposed changes, is provided in References 5 and 6.

The proposed change deletes two existing Notes associated with the existing required actions for LCO 332 and deletes Note (b) to Table 332-1. Justification for deletion of these thee notes is as follows:

The first note associated with LCO 332 and Note (b) to Table 332-1 both provide extended AOTs for special situations including: HPCI and RCIC isolation instrument channels when trip capability is maintained by the redundant function; inoperability caused by surveillance testing, and/or, situations where placing a channel in trip will result in an actuation. These notes are deleted because AOTs in the proposed required actions for LCO 3.32 are longer than those permitted by the existing notes. Therefore, removal of these notes is an administrative change with no effect on the margin of safety or operator performance.

The second note associated with LCO 332 requires that the trip system with the most inoperable channels be placed in trip when there are multiple inoperable channels. This note is deleted because, in conjunction with the proposed changes to required actions, it would have no effect on operator action. This change is consistent with NUREG-1433 (Reference 12). Deletion of this note has no effect on margin of safety of operator performance.

The proposed change changes Applicability requirements and required actions for the Isolation Trip Function 7.a, Reactor Vessel Water Level - Low, Level3. This function isolates the RHR System Shutdown Cooling System and is intended to isolate a potential leakage path in the event of a loss of reactor coolant during operation of the Shutdown Cooling (SDC) System. The Reactor Vessel Water Level - Low, Level 3 Function receives input from four reactor vessel water level channels.

The outputs from the reactor vessel water level channels are connected to two trout-of-two trip systems. Each of the two trip systems is connected to one of the two valves on each shutdown cooling penetration.

Currently, the Reactor Vessel Water Level - Low, Leve13 function is required to be OPERABLE in OPERATIONAL CONDITIONS 1, 2 and 3. In OPERATIONAL CONDITIONS 1, 2 and 3 another isolation (i.e., Reactor Steam Dome Pressure - High; setpoint E, 98 psig) and administrative controls ensure that this flow path remains isolated to prevent unexpected loss of inventory via this flow path. The proposed change will require that the Reactor Vessel Water Level - Low, Level3 Function be OPERABLE in OPERATIONAL CONDITIONS 3, 4, and 5 when it is possible that the SDC isolation valves are open and the safety function 'provided by this isolation function is needed to ensure that the RPV water level does not drop below the top of the active fuel during a vessel draindown event caused by a leak (e.g., pipe break or inadvertent valve opening) in the RHR Shutdown Cooling System. The Reactor Vessel Water Level - Low, Level3. function will no longer be required to be OPERABLE when RHR SDC isolation is already maintained by the Reactor Steam Dome Pressure - High Function. This change is more conservative than existing SSES Technical Specifications because the safety function provided by the Reactor Vessel Water Page 4 of 92

ENCLOSURE A TO PLA<249 Level - Low, Level 3 Function is extended to include OPERATIONAL CONDITIONS 4 and 5. In conjunction with this change, Table 432.1-1 will be changed to identify the "OPERATIONAL CONDEMNS for which Surveillance Required" consistent with the change in Applicability requirements, A new footnote to Table 332-1 will be added that "Only one trip system required in OPERATIONAL CONDITIONS 4 and 5 when RHR Shutdown Cooling System integrity maintained." System integrity is maintained provided the piping is intact and no maintenance is being performed that has the potential for draining the reactor vessel through the system. The requirement to have two OPERABLE Channels in one trip system ensures that the isolation function willbe available in OPERATIONAL CONDITIONS 4 and 5 although redundancy is reduced. 'Ibis change is more conservative than existing SSES Technical Specifications because currently there are no OPERABILITYrequirements for this function in OPERATIONAL CONDITIONS 4 and 5.

Required actions for an inoperable Reactor Vessel Water Level - Low, Leve13 instrument channel If will be revised by adding ACTION 27 to Table 332-1. the number of OPERABLE channels of Reactor Vessel Water Level - Low, Leve13 Function is less than required and cannot be restored within the AOTs specified in proposed Required ACTIONS b or c of Technical Specification 332, Table 3,3.2-1 will require entering ACTION27. ACTION 27 will require that plant personnel initiate action to restore channel(s) to OPERABLE status; or, initiate action to isolate the Residual Heat Removal (RHR) Shutdown Cooling System. To ensure proper interpretation of proposed ACTION 27, the Bases for Technical Specification 3.32 will be revised to provide the following guldailce:

Ifan inoperable channel(s) is not restored to OPERABLE status or placed in trip within the allowed completion time, the associated penetration flow path should be closed. However, if the shutdown cooling function is needed to provide core cooling, ACTION 27 allows the penetration fiow path to remain unisolated provided action is immediately initiated to restore the channel to OPERABLE status or to isolate the RHR Shutdown Cooling System (i.e., provide alternate decay heat removal capabilities so the penetration flow path can be isolated). ACTION 27 must continue until the channel(s) is restored to OPERABLE status or the RHR Shutdown Cooling System is isolated.

Each of the proposed changes to the Applicability requirements and Required Actions for the Isolation Trip Function 7.a, Reactor Vessel Water Level - Low, Level3 is consistent with Section 3.3.6.1 ofNUREG-1433 (Reference 12).

The proposed change increases the maximum interval between required performances of CHANNEL FUNCTIONAL TESTS for all isolation actuation instrumentation, except manual initiation, &om the current requirement for monthly (M) performance to a proposed requirement of quarterly (Q) performance. Justification for extending the CHANNEL FUNCTIONAL 'I%ST frequency, including the positive impact on the margin of safety and operator performance, is provided in References 5 and 6. The proposed change, in conjunction with other proposed changes Page 5 of 92

ENCLOSURE A TO PLA-4249 that extend AOTs and STIs, has a positive impact on the margin of safety and operator performance for reasons described in References 5 and 6.

The proposed change will delete notes to Table 332-1, Table 332-2, and Table 43.1-1 that were added by Amendment 94 (Unit 1) and 61 (Unit 2) to permit modifications to temperature instruments associated with leak detection during the period between October 19, 1989 and Janmuy 19, 1990. The time period specified by these notes has expired and the associated modifications are complete. This is an administrative change with no effect on margin of safety or operator perform alice.

The proposed change will modify required actions associated with inoperable emergency core cooling system actuation instnimentation that will:

extend AOTs before an inoperable channel must be placed in trip based on the analysis reported in Reference 3;

2) extend AOTs before an inoperable channel must be placed in trip to be consistent with NUREG-1433 (Reference 12), Section 3.3.5.1 and based on the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design; and,

3) ensure that the extended AOTs do not permit an extended loss of actuation capability.

Each of the proposed changes is consistent with NUREG-1433 (Reference 12), Section3.3.5,1, Conditions A, B, C, D, E, F, G and H, as appropriate. In some cases, the action statement assigned to specific functions are changed, consistent with NUREG-1433, to ensure that appropriate required actions are applied to each function.

The proposed change makes the following specific changes to the Technical Specifications:

The proposed change will replace the LCO 333, Table 333-1, ACTION 30 with required actions and AOTs that are consistent with the NUREG-1433 (Reference 12), Section 33.5.1, Conditions A, B and H (except HPCI). Existing ACTION 30 requires that: the inoperable channel be placed in trip or the associated ECCS be declared inoperable within one hour whenever the number of OPERABLE channels in one trip system is less than the required minimum number per trip system.

The proposed change results in the following technical changes:

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ENCLOSURE A TO PLA-4249 The AOT before an inoperable channel must be placed in trip is increased from one hour to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Justification for extending the AOTs, including the positive impact on the margin of safety and opemtor performance, is provided in References 5 and 6.

ii, The proposed change adds a requirement that specifically prohibits the extended AOTs from resulting in an extended loss of actuation function.

In conjunction with this change, the required action designated in Table 333-1 for an inoperable channel is changed from ACTION 32 to proposed ACTION 30 for the following functions:

Function l.c: Reactor Vessel Steam Dome Pressure Low (Pemiissive for System Initiation in OPERATIONAI. CONDITIONS 4 and 5);

Function 2.c. Reactor Vessel Steam Dome Pressure Low (Permissive for System Initiation and Recirculation Discharge Valve Closure in OPERATIONAL CONDITIONS 4 and 5).

Other than extending the AOT &om within one hour to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and preventing extended loss of function, assigning proposed ACTION 30 to these functions results in no technical change to the required actions and the assignment of proposed ACTION 30 to these functions is consistent with NUREG-1433 (Reference 12), Section 3.3.5.1.

The proposed changes to ACTION 30, in conjunction with other proposed dianges that extend AOTs and STIs, have a positive impact on the margin of safety and operator performance for reasons described in Reference 3 and because operation with extended loss of any isolation function is prohibited. The proposed format and wording are consistent with NUREG-1433 (Reference 12) and have been determined to improve the clarity and usability of the specification.

The proposed change will replace the LCO 3.33, Table 3.3.3-1, ACTION 31 with required actions and AOTs that are consistent with the NUREG-1433 (Reference 12), Section 3.3.5.1, Conditions A, C and H. Existing ACTION 31 requires that the associated ECCS be declared inoperable within whenever the number of operable channels is less than the required minimum number per trip system. The proposed change results in the following technical changes:

The AOT before an inoperable channel must be restored to OPERABLE status or the ECCS declared inoperable is increased from immediately to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Justification for extending the AOTs, including the positive impact on the margin of safety and operator performance, is provided in References 5 and 6.

ii. The pro'posed change adds a requirement that specifically prohibits the extended AOTs from resulting in an extended loss of actuation capability.

In conjunction with this change, the required ACTION designated in Table 333-1 for an inoperable channel is changed from ACTION 33 to proposed ACTION 31 for manual initiation of Core Spray (Table 3.3.3-1, Function 1.d), LPCI Mode of RHR (Table 33.3-1, Function 2.d) and High Pressure I

Page 7 of 92

ENCLOSURE A TO PLA<249 Coolant Injection gable 33.3-1, Function 3.f). Existing ACTION 33 requires that an inoperable channel be restored to OPERABLE within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or the associated ECCS declared inoperable.

Other than extending the AOT from within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and preventing extended loss of function, assigning proposed ACTION 31 to these functions results in no technical change to the required ACTIONS and the assignment of proposed ACTION 31 to these functions is consistent with NUREG-1433 (Reference 12), Section 33.5.1.

Proposed ACTION 31 willbe modified by a footnote stating that ACTION 31 b is not applicable to Function 3.e, Reactor Vessel Water Level - High, Level 8. ACTION 31 b requires that HPCI be declared inoperable within one hour 60m discovery of loss of initiation capability by this trip function. This requirement is not applicable to Function3.e, HPCI Reactor Vessel Water Level High, Level 8, because this function is for equipment protection and is not assumed in the SSES safety analysis. ACTION 31 a will require that HPCI be declared inoperable iftrip capability for this function is not restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This change is consistent with NUREG-1433 (Reference 12), Section 33.5.1, Condition C.

The proposed changes to ACTION 31, in conjunction with other proposed changes that extend AOTs and STls, have a positive impact on the margin of safety and operator performance for reasons described in Reference 3 and because operation with extended loss of any isolation function is prohibited. The proposed format and wording are consistent with NUREG-1433 (Reference 12) and have been determined to improve the clarity and usability of the specification.

S,GXIQH32'he proposed change will replace the LCO 3.3.3, Table 333-1, ACTION 32 with required actions and AOTs that are consistent with the NUREG-1433 (Reference12), Section 3.3.5.1, Conditions A, F and H. Existing ACTION 32 requires that an inoperable channel be placed in trip within one hour whenever the number of operable channels is less than the required minimum number per trip system. The proposed change results in the following technical changes:

The proposed change adds a requirement that specifically prohibits extended AOTs &om resulting in an extended loss of ADS actuation capability. The change requires that ADS be declared inoperable within one hour from discovery of loss of ADS initiation capability, The AOT for an inoperable ADS initiation channel thatdoes not result in the loss of ADS initiation capability is extended from within one hour to: within 4 days with HPCI or RCIC inoperable; and, within 8days from discovery of inoperable channel if both HPCI and RCIC are OPERABLE. The extension of the AOTs is justified by: the redundancy and independence of sensors available to provide ADS initiation signals; the redundancy of the ECCS design; the requirement to declare ADS inoperable within one hour of the determination of loss of ADS initiation capability; and, the analysis in Reference 3.

Proposed ACTION 32 is worded so that the AOT limits the total time for an inoperable, untripped channel to less than 8 days even ifthe status of HPCI or RCIC changes following the discoveiy of the inoperable ADS channel. This change adds the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AOT extension justified by Reference 3 to the AOTs in the BWR Standard Technical Specifications. This combination of conditional AOTs and the length of the AOTs for ADS initiation is consistent with NUREG-1433, Section 3.3.5.1, Condition F.

Page 8 of 92

ENCLOSURE A TO PLA<249 In conjunction with this change, the required action designated in Table 333-1 for an inoperable channel is changed from ACTION 30 or ACTION 31 to proposed ACTION 32 for the following functions:

Function 4.a: ADS Reactor Vessel Water Level Low Low Low, Level 1; Function 4.b: ADS Diywell High Pressure; and Function 4.f: ADS Reactor Vessel Water Level Low, Level 1 (Permissive).

Existing ACTION 30, which was the required action for Functions 4.a and 4.b, and existing ACTION 31, which was the squired action for Function 4.f, both required that an inoperable channel be placed in trip within one hour. The proposed change maintains this limit and adds an extended AOT for an inoperable channel that does not result in loss of initiation capability for the reasons justified above. This change is consistent with NUREG1433, Section 33.5.1, Table 33.5.1-1.

The proposed changes to ACTION 32 to extend AOTs for inoperable ADS initiation channels that do not result in loss of ADS initiation capability are consistent with BWR Standard Technical Specifications for BWR4s with ADS initiation logic identical to SSES, Units 1 and 2. These AOT extensions, in conjunction with other proposed changes that extend AOTs and STIs, have a positive impact on the margin of safety and operator performance for reasons described in Reference 3 and because operation with extended loss of any isolation function is prohibited. The proposed format and wording are consistent with NUREG-1433 (Reference 12) and have been determined to improve the clarity and usability of the specification.

SGXIQK33; The proposed change will replace the LCO 33.3, Table 333-1, ACTION 33 with required actions and AOTs that are consistent with the NUREG-1433 (Reference 12), Section 3.3.5.1, Conditions A, G and H. Existing ACTION 33 requires that an inoperable channel be restored to OPERABLE within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or the associated ECCS (ADS) be declared inoperable.

The difference between proposed ACTION 32 and proposed ACTION 33 is that ACTION 32 allows inoperable channels to be placed in trip within the AOT while proposed ACTION 33 requires inoperable channels to be restored to OPERABLE status within the AOT. This difference recognizes that placing an inoperable channel in trip has two consequences: it provides greater assurance that an actuation will occur when required; and, it increases the potential for an inadvertent actuation. Therefore, proposed ACTION 33 does not permit continued operation with an inoperable channel in trip for an instrument channel that provides an interlock or permissive because both the failure to actuate and an inadvertent actuation are undesirable. Other than this difference, which is already recognized in existing ACTION 33, the proposed changes and the justification for proposed ACTION 33 are identical to the proposed changes and justification for proposed ACTION 32 above.

Page 9 of 92

ENCLOSURE A TO PLA<249 In conjunction with this change, the required action designated m Table 333-1 for an inoperable channel is changed Gom existing ACTION 31 to proposed ACTION 32 for the following functions:

Function 4.c: ADS Timer, Function 4,d: Core Spray Pump Discharge Piessure - High (Permissive);

Function 4,e: RHR LPCI Mode Pump Discharge Pressure - High (Permissive); and, Function 4.g: ADS Diywell pressure Bypass Timer.

Existing ACTION 31, which was the required action for the trip functions listed above, required that the associated ECCS (ADS) be declared inoperable within one hour following discoveiy of an inoperable channel. The proposed change, other than extending the AOT from one hour to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months which is justified by Reference 3, is not di6erent because it requires that the channel be restored to OPERABLE or ADS declared inoperable within the AOT. This change is consistent with NUREG-1433, Section 3.3.5.1, Table 33.5.1-1.

Justification for the proposed changes to ACTION 33 and the impact on margin of safety and operator performance are the same as for proposed ACTION 32 and are discussed earlier in this Safety Impact Assessment.

B,GEIQh~

The proposed change will replace the LCO 3,33, Table 333-1, ACTION 34 with required actions and AOTs that are consistent with the NUREG-1433 (Reference 12), Section 3.3,5.1, Conditions A, D and H. Existing ACTION 34 requires whenever the number of OPERABLE channels is less than the required minimum number per trip system that one inoperable channel be placed in trip within one hour (which results in an actuation, i.e., HPCI pump suction transfer to the suppression pool) or that HPCI be declared inoperable. The proposed change makes the following technical changes to the required action:

The AOT before an inoperable channel must be placed in trip or the HPCI declared inoperable is increased from within one hour to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Justification for extending the AOTs, including the positive impact on the margin of safety and operator performance, is provided in Reference 3.

ii. The proposed change adds a requirement that specifically prohibits the extended AOTs from resulting in an extended loss of actuation capability.

The proposed change provides the option of transferring pump suction to the suppression pool. Aligning the pump suction from the Condensate Storage Tank to the suppression pool is an acceptable alternative to placing the channel in trip or declaring HPCI inoperable because it completes the intended function of inoperable instrument.

The proposed changes to ACTION 34, in conjunction with other proposed changes that extend AOTs and STIs, have a positive impact on the margin of safety and operator performance for reasons described in Reference 3 and because operation with extended loss of any isolation function is ptohibited. The proposed format and wording are consistent with NUREG-1433 (Reference 12) and have been determined to improve the clarity and usability of the specification, Page 10 of 92

ENCLOSURE A TO PLA<249 The proposed change modifies Notes (a) and (f) for Table 333-1 to extend &om 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months the amount of time that initiation of required actions may be delayed when a channel is placed in an inoperable status solely for performance of required surveillances. Justification for extending this AOT, including the positive impact on the margin of safety when considered in conjunction with other proposed changes, is provided in Reference 3. In conjunction with this change, the following technical changes were made to proposed Note (a) and proposed Note (fj:

The wording of Note (a) was changed to provide an unambiguous requirement that the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AOT for surveillance testing was applicable only if the associated trip function maintains trip capability. The change in wording to unambiguously prohibit loss of function as a condition of the AOT permitted Table 33.3-1 to be modified to make Note (a)

(instead of Note (f)) applicable to the ADS trip functions. This change is consistent with NUREG-1433 (Reference 12).

The proposed change described above results in Note (f) no longer being applicable to the ADS functions in Table 333-1. Note (f) was modified to apply the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AOT for surveillance testing to those functions that do not depend on the condition that trip capability be maintained. Consistent with NUREG-1433, Table 3.3.3-1 was modified to make proposed Note (f) applicable to Function 3.e, HPCI Reactor Vessel Water Level High, Level 8, because this function is for equipment protection and is not assumed in the SSES safety analysis.

The proposed change increases the maximum interval between required performances of CHANNELFUNCTIONALTESTS for the following ECCS instrumentation:

l.a Reactor Vessel Water Level - Low Low Low, Level 1 l.b Diywell Pressure - High l.c Reactor Pressure Stream Dome Pressure - Low (Permissive) 2.a Reactor Vessel Water Level - Low Low Low, Level 1 2.b Diywell Pressure - High 2.c Reactor Pressure Stream Dome Pressure - Low (Permissive) 2.c.l) System Initiation 2.c.2) Recirculation Discharge Valve Closure Page 11 of 92

ENCLOSURE A TO PLA<249 33k Reactor Vessel Water Level - Low Low, Level 2 3.b Diywell Pressure - High 3.c Condensate Storage Tank Level - Low 3.d Suppression Pool Water Level - High 3.e Reactor Vessel Water Level - High, Level 8 4.a Reactor Vessel Water Level - Low Low Low, Level 1 4.b Diywell Pressure - High 4.c ADS Timer 4.d Core Spray Pump Discharge Pressuie - High (Permissive) 4.e RHR LPCI Mode Pump Discharge Pressure - High (Permissive) 4.f Reactor Vessel Water Level - Low, Level 3 (Permissive) 4,g ADS Drywell Pressure Bypass Timer The proposed change modifies Table 433.1-1 to change the required &equency for the instruinents listed above from the current requirement for monthly (M) performance to a proposed requirement of quarterly (Q) performance. Justification for extending the CHANNEL FUNCTIONAL TEST frequency, including the positive impact on the margin of safety and operator performance, is provided in Reference 3. The proposed change, in conjunction with other proposed changes that extend AOTs and STIs, has a positive impact on the margin of safety and operator performance for reasons described in Reference 3.

The proposed change willmodify required actions and extend AOTs for ATWS Recirculation Pump Trip Instrumentation by replacing LCO 33.4.1, ACTIONSb, c, d, and e with required actions and AOTs that are consistent with the NUREG-1433 (Reference 12), Section 33.42, ATWS-RPT Instrumentation, Conditions A, B, C and D. The proposed change makes the following specific changes to the Technical Specifications:

The proposed change adds a requirement that specifically prohibits extended AOTs from resulting in an extended loss of ATWS-RPT actuation capability. The change requires that ATWS-RPT be declared inoperable within one hour from discovery of loss of initiation capability for both the reactor steam dome pressure and reactor vessel water level trip function. Additionally, the proposed change prohibits satisfying required actions for an inoperable channel by placing the channel in trip if the inoperability is the result of an inoperable breaker.

The AOT for one or more inoperable ATWS-RPT initiation channels that do not result in the loss of initiation capability is extended from within one hour to within 14 days. This change is consistent with BWR Standard Technical Specifications, NUREG-1433 (Reference 12), and is justified based on the ATWS-RPT design and function. ATWSRPT Page 12 of 92

ENCLOSURE A TO PLAQ249 consists of two independent trip systems, with two channels of reactor steam dome pressure and two channels of reactor vessel water level in each trip system. Each ATWSRPT trip system is a tw~ut-of-two logic for each of these functions. Either two Reactor Water Level or two Reactor Pressure signals are needed to trip a trip system. The outputs of the channels in a trip system are combined in a logic so that either trip system will trip both recirculation pumps. The 14 day AOT for an inoperable channel is justified because of the diversity of sensors available to provide trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse functions, and the low probability of an event requiring the initiation ofATWS RPT.

This change includes the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AOT extension justified by Reference 7 and the AOTs in the BWR Standard Technical Specifications. Each ofthe proposed changes is consistent with NUREG-1433 (Reference 12), Section 33.4.2, Conditions A, B, C and D. The proposed change, extending the AOT for an inoperable ATWS-RPT channel that does not result in a loss of function, does not have a significant impact on margin of safety because of diversity of sensors, the low probability of multiple inoperabilities and the low probability of an event requiring the initiation of ATWSRPT.

The proposed format and wording are consistent with NUREG-1433 (Reference 12) and have been determined to improve the clarity and usability of the specification.

The proposed change modifies the Note to Table 3.3.4.1-1 that specifies when a channel is placed in an inoperable status solely for performance of required surveillances, initiation of actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months currently in Table 3.3.4.1-1) provided the associated trip function maintains ATWS-RPT capability. Justification for extending this AOT, including the positive impact on the margin of safety when considered in conjunction with other proposed changes, is provided in Reference 7.

The proposed change increases the maximum interval between required performances of CHANNEL FUNCTIONALTESTS for ATWS-RPT trip functions (reactor vessel level and reactor vessel pressure). This change modifies Table 4.3.4.1-1 to change the CHANNEL FUNCTION TEST frequency from the current requirement for monthly (M) performance to a proposed requirement of quarterly (Q) performance. Justification for extending the CHANNEL FUNCTIONALTEST frequency, including the positive impact on the margin of safety and operator performance, is provided in Reference 7. The proposed change, in conjunction with other proposed changes that extend AOTs and STls, has a positive impact on the margin of safety and operator performance for reasons described in Reference 7.

The proposed change willmodify required actions and extend AOTs for End-of-Cycle Recirculation Pump Trip (EOC-RPT) by replacing LCO 33.42, ACTIONSb, c, d, and e with required actions and AOTs that are consistent with the NUREG-1433 (Reference 12), Section 3.3.4.1, EOC-RPT Page 13 of 92

ENCLOSURE A TO PLA<249 Instrumentation, Conditions B, C and D. The proposed change makes the following specific changes to the Technical Specifications:

The AOT for placing one or more inoperable EOC-RPT channels in trip is increased from within one hour to within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This change adds the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AOT extension justified by Reference 7 to the AOTs allowed for in BWR Standard Technical Specifications for an inoperable EOC-RPT function. This change is justified because with one or more channels inoperable, but with EOC.RPT trip capability maintained, EOGRPT is capable of performing the intended function. However, the reliability and redundancy of the EOC-RPT instrumentation is reduced such that a single failure in the remaining trip system could result in the inability of the EOGRPT to perform the intended function. Therefore, only a limited time is allowed to restore compliance with the LCO. Because of the diversity of sensors available to provide trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse functions, and the low probability of an event requiYing the initiation of an EOC-RPT, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is provided to restore the inoperable channels or apply the EOC-RPT inoperable MCPR limit. Alternately, the inoperable channels may be placed in trip since this would restore capability to accommodate a single failure. Loss of function is prohibited by specifying that the LCO cannot be satisfied by placing a channel in trip ifthe inoperable channel is the result of an inoperable breaker.

ii. The proposed change prohibits the extended AOT from resulting in a loss of EOC-RPT function by specifically establishing an AOT of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months following the loss of EOC-RPT trip capability in one or both trip systems.

The proposed change is consistent with NUREG-1433 (Reference 12), Section 3.3.4.1, Conditions A, B, C and D. The proposed change, extending the AOT for an inoperable EOC-RPT channel that does not result in a loss of function, does not have a significant impact on margin of safety because of diversity of sensors, the low probability of multiple inoperabilities and the low probability of an event requiring the initiation of EOGRPT actuation. The proposed format and wording are consistent with NUREG-1433 (Reference 12) and have been determined to improve the clarity and usability of the specification.

The proposed change modifies the Note to Table 3.3.4.2-1 that specifies when a channel is placed in an inoperable status solely for performance of required surveillances, initiation of actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months currently in Table 33.4.2-1) provded the other trip system is OPERABLE. Justification for extending this AOT, including the positive impact on the margin of safety when considered in conjunction with other proposed changes, is provided in Reference 7.

The proposed change increases the maximum interval between required performances of CHANNEL FUNCTIONALTESTS for EOC-RPT trip functions (Turbine Stop Valve-Closure and Turbine Control Valve-Fast Closure). This change modifies Table 4.3.42-1 to change the CHANNEL FUNCTION TEST frequency from the current requirement for monthly (M)

Page 14 of 92

ENCLOSURE A TO PLA<249 performance to a proposed mquirement of quarterly (Q) performance. Justification for extending the CHANNELFUNCTIONALTEST frequency, including the positive impact on the margin of safety and operator performance, is provided in Reference 7. The proposed change, in conjunction with other proposed changes that extend AOTs and STIs, has a positive impact on the margin of safety and operator performance for reasons described in Reference 7.

The proposed change modifies Note (a) for Table 33.5-1 to extend from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months the amount of time that initiation of required actions may be delayed when a channel is placed in an inoperable status solely for performance of requited surveillances. Justification for extending this AOT, including the positive impact on the margin of safety when considered in conjunction with other proposed changes, is provided in Reference 7.

The proposed change willreplace LCO 33.5, Table 33.5-1, ACTION 50 with required actions and AOTs that are consistent with the NUREG-1433 (Reference 12), Section 3.3.52, Conditions B and E. Existing ACTION 50 requires that: the inoperable channel be placed in trip or RCIC declared inoperable within one hour whenever the number of operable channels in one trip system is less than the required minimum number per trip system. The proposed change results in the following technical changes:

The AOT before an inoperable channel must be placed in trip is increased from one hour to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Justification for extending the AOTs, including the positive impact on the margin of safety and operator performance, is provided in Reference 8.

The proposed change adds a requirement that specifically prohibits the extended AOTs from resulting in an extended loss of actuation function.

The proposed change willreplace LCO 3.3.5, Table 3.3.5-1, ACIION 51 with required actions and AOTs that are consistent with the NUREG-1433 (Reference 12), Section 3.3.5.2, Conditions C and E. Existing ACTION 51 requires that RCIC be declared inoperable within one hour whenever the number of OPERABLE channels in one trip system is less than the required minimum number per trip system. The proposed change results in the following technical change:

The AOT before an inoperable channel must be restored to OPERABLE or RCIC declared inoperable is increased from one hour to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Justification for extending the AOTs, including the positive impact on the margin of safety and operator performance, is provided in Reference 8.

Page 15 of 92

ENCLOSURE A TO PLAA249 The proposed change willreplace LCO 33.5, Table 3.3.5-1, ACTION 52 with required actions and AOTs that ate consistent with the NUREG-1433 (Reference 12), Section33.52, Conditions D and E. Existing ACTION 52 requires whenever the number of OPERABLE channels is less than the required minimum number per trip system that one inoperable channel be placed in trip within one hour (which results in an actuation, i.e., RCIC pump suction transfer to the suppression pool) or that RCIC be declared inoperable. The proposed change makes the following technical changes to the required action; The AOT before an inoperable channel must be placed in trip or the RCIC declared inoperable is increased &om within one hour to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Justification for extending the AOT, including the positive impact on the margin of safety and operator performance, is provided in Reference 8.

ii. The proposed change adds a requirement that specifically prohibits the extended AOTs

&om resulting in an extended loss of actuation capability.

iii. The proposed change provides the option of transferring pump suction to the suppression pool. Aligning the pump suction &om the Condensate Storage Tank to the suppression pool is an acceptable alternative to placing the channel in trip or declaring RCIC inoperable because it completes the intended function of inoperable instrument.

The proposed change willreplace LCO 33.5, Table 3.3.5-1, ACTION 53 with required actions and AOTs that are consistent with the NUREG-1433 (Reference 12), Section 3.3.5.2, Conditions C and E. Existing ACTION 53 requires whenever the number of OPERABLE channels is less than the required minimum number per trip system that the inoperable channel be restored to OPERABLE within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or that RCIC be declared inoperable. The proposed change makes the following technical changes to the required action:

The AOT before an inoperable channel must be restored to OPERABLE or the RCIC declared inoperable is increased from within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Justification for extending the AOT, including the positive impact on the margin of safety and operator performance, is provided in Reference 8. There is no requirement to prevent the extended AOT from causing an extended loss of actuation capability because this function is for equipment protection and is not assumed in the SSES safety analysis.

The proposed change increases the maximum interval between required performances of CHANNELFUNCTIONALTESTS for the following RCIC instrumentation:

Reactor Vessel Water Level - Low Low, Level 2 Reactor Vessel Water Level - High, Level 8 Condensate Storage Tank Water Level - Low Page 16 of 92

ENCLOSURE A TO PLA-4249 The proposed change modifies Table 4.3.5.1-1 to change the required &equency for theinstruments listed above &om the current requirement for monthly (M) performance to a proposed iequirement of quarterly (Q) perfonnance. Justi6cation for extending the CHANNEL FUNCTTONAL TEST

&equency, including the positive impact on the margin of safety and operator performance, is provided in Reference 8, The pmposed change, in conjunction with other proposed changes that extend AOTs and STIs, has a positive impact on the margin of safety and operator performance for reasons described in Reference 8.

D.7 The proposed change eliminates the footnote for LCO 4.3.6, ACTION a that states: "For the Intermediate Range Monitors the pmvisions of Specification 3.0.4 are not applicable for the purposed of entering OPERATIONAL CONDITION 5 &om OPERATIONAL CONDITION 4 on September 14, 1987." This is an administrative change with no effect on margin of safety or operator performance.

The proposed change adds a Note to the proposed actions for Surveillance Requirement 4.3.6 that specifies when a channel is placed in an inoperable status solely for performance of required surveillances, initiation of actions may be delayed for up to 6hours provided at least one other OPERABLE channel in the same trip system is monitoring that parameter. Justification for extending this AOT, including the positive impact on the margin of safety when considered in conjunction with other proposed changes, is provided in Reference 4.

The proposed change modifies ACTION 62 to extend the AOT before an inoperable channel must be placed in trip from one hour to within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ACTION 62 is applicable to the rod blocks associated with the scram discharge instrument volume high function and the Reactor Coolant System Recirculation Flow function. Justification for extending this AOT, including the impact on the margin of safety when considered in conjunction with other proposed changes, is provided in Reference 4.

The proposed change increases the maximum interval between required performances of CHANNELFUNCTIONALTESTS for the following Control Rod Block Instrumentation:

l.a Upscale 1.b Inoperative 1.c Downscale Page 17 of 92

ENCLOSURE A TO PLA-4249 The proposed change modifies Table 43.6-1 to change the required fiequency for the instruments listed above fiom the current requirement for monthly (M) performance to a proposed requirement of quarterly (Q) performance. Additionally, the requirement to perform CHANNEL FUNCTIONAL TEST "within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to startup, if not performed within the previous 7 days is being eliminated. This change is consistent with NUREG-1433. Justification for extending the CHANNEL FUNCTIONAL TEST &fluency, including the positive impact on the margin of safety and operator performance, is provided in Reference 4. The proposed change, in conjunction with other proposed changes that extend AOTs and STIs, has a positive impact on the margin of safety and operator performance for reasons described in Reference 4.

The proposed change increases the maximum interval between required performances of CHANNELFUNCTIONALTESTS for the following Control Rod Block Instrumentation:

BZEhi 2.a Flow Biased Neutron Flux - Upscale 2.b Inoperative 2.c Downscale 2.d Neutron Flux - Upscale, Startup s.a Water Level - High 6.a Upscale 6.b Inoperative 6.c Comparator The proposed change modifies Table 43.6-1 to change the required frequency for CHANNEL FUNCTIONAL TESTS for the instruments listed above from the current requirement for either weekly (W) or monthly (M) performance to a proposed requirement of quarterly (Q) performance.

Justification for extending the CHANNELFUNCTIONALTEST frequency, including the positive impact on the margin of safety and operator performance, is provided in Reference 4. The proposed change, in conjunction with other proposed changes that extend AOTs and STls, has a positive impact on the margin of safety and operator performance for reasons described in Reference4.

The proposed change adds new Note (c) to Table 33.7.1-1 for ACTION 70 which is associated with the Main Control Room Outside Air Radiation Monitor. 'Itus note specifies when a channel is placed in an inoperable status solely for performance of required surveillances, initiation of actions may be delayed for up to 6hours provided control room emergency ventilation capability is Page 18 of 92

ENCLOSURE A TO PLA<249 maintained. Justification for extending this AOT, including the positive impact on the margin of safety when considered in conjunction with other proposed changes, is provided in Reference 7.

The proposed change increases the maximum interval between required performances of CHANNEL FUNCTIONAL TESTS for the Main Control Room Outside Air Radiation Monitor fiem the current requirement for monthly (M) performance to a proposed requirement of quarterly (Q) performance. Justification for extending the CHANNEL FUNCTIONAL TEST frequency, including the positive impact on the margm of safety and operator performance, is provided in References 5 and 6. The proposed change, in conjunction with other proposed changes that extend AOTs and STIs, has a positive impact on the margin of safety and operator performance for reasons described in Reference 4.

The proposed change adds a new Note to LCO 3.3.9, ACTIONS b and c that specifies that when a channel is placed in an inoperable status solely for performance of required Surveillances, actions may be delayed for up to 6hours provided feedwater/main turbine trip capability is maintained.

Justification for extending this AOT, including the positive impact on the margin of safety when considered in conjunction with other proposed changes, is provided in Reference 7.

The proposed change increases the maximum interval between required performances of CHANNEL FUNCTIONAL TESTS for the Reactor Vessel Water level - High function of the Feedwater/Main Turbine Trip System fmm the current requirement for monthly (M) performance to a proposed requirement of quarterly (Q) performance. Justification for extending the CHANNEL FUNCTIONALTEST frequency, including the positive impact on the margin of safety and operator performance, is provided in References 5 and 6. The proposed change, in conjunction with other proposed changes that extend AOTs and STIs, has a positive impact on the margin of safety and operator performance for reasons described in Reference 7.

The Bases for each of the Technical Specification listed above were modified to identify that CHANNEL FUNCHONAL TEST frequencies and allowed out of service times for repair and surveillance testing have been determined in accordance with General Electric reports used to justify the changes in this Safety Assessment. As discussed in Section D.2.c, the Bases for Technical Specification 332, Isolation Actuation Instrumentation, were revised to provide guidance regarding implementation of ACTION 27 for inoperable instrument channels of the Reactor Vessel Water Level - Low, Level 3 Function.

Page 19 of 92

ENCLOSURE A TO PLA-4249

1. S, Visweswaran, et al., "BWR Owners'roup Response to NRC Generic Letter 83-28, Item 4.53,"

General Electric Company, NEDC-30844A, March 1988.

2. W. P. Sullivan, et al., "Technical Specification Improvement Analyses for BWR Reactor Protection System," General Electric Company, NEDC-30851P-A, March 1988.

3. D. B. Atcheson, et al., "BWR Owners'roup Technical Specification Improvement Methodology with Demonstmtion for BWR ECCS Actuation Instrumentation," Parts 1 and 2, General Electric Company, NEDC-30936P-A, December 1988.

4. S. Visweswaran, et al., "Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation," General Electric Company, NEDC-30851P-A, Supplement 1, October 1988.

L. G. Frederick, et al., "Technical Specification Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation," General Electric Company, NEDC-30851P, Supplement 2, July 1986.

6. W. P. Sullivan, et al., "Technical Specification Improvement Analyses for BWR Isolation Actuation Instrumentation," General Electric Company, NEDC-31677P-A, July1990.

7. "Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," General Electric Company, GENE-770-06-1A, December 1992.

8. "Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," General Electric Company, GENE-770-06-2A, December 1992.

9. "Technical Specification Improvement Analysis for the Reactor Protection System for Susquehanna Steam Electric Station, Units 1 and 2," General Electric Company, MDE-79-0485, April 1985).

10. "Technical Specification Improvement Analysis for the Emergency core Cooling System Actuation Instrumentation for Susquehanna Steam Electric Station, Units 1 and 2," General Electric Company, RE-022 (DRF AOO 02558E), dated Janmuy 1987.

Page 20 of 92

ENCLOSURE A TO PLA<249

11. C. E. Rossi, NRC, to R. F. Janacek, BWROG, "Staff Guidance for Licensee Determination that the IMt Characteristics for Instrumentation Used in RPS Channels are Bounded by NEDC-30851P Assumptions when the Functional Test Interval is Extended fiem Monthly to Quarterly," April 27, 1988.

12. NUREG 1433, "Standard Technical Specifications, General Electric Plants BWR/4," Revision 0, September 1992.

13. Letter, C. L. Tully, BWROG, to B. K. Grimes, NRC, "BWR Owners'roup (BWROG) Topical Reports on Technical specification Improvement Analysis for BWR Reactor Protection systems-Use for Relay and solid State Plants (NEDC-30884 and NEDC-30851P)," November 4, 1992.

Page 21 of 92

ENCLOSURE A TO PLA-4249 LIST OF ATI'ACHMtENTS Evaluation ofthe Applicability of Licensing Topical Reports as Justification for Extending STIs and AOTs for Technical Specification Instrumentation for Susquehanna Steam Electric Station, Units 1 and 2.

Evaluation of the Effect of Increasing the Minimum Interval between Instrument Functional Tests on the Identification of Excessive Drift of Instrument Setpoints for Susquehanna Steam Electric Station, Units 1 and 2.

"Technical Specification Improvement Analysis for the Reactor Protection System for Susquehanna Steam Electric Station, Units 1 and 2," General Electric Company, MDE-79-0485, April 1985).

"Technical Specification Improvement Analysis for the Emergency core Cooling System Actuation Instrumentation for Susquehanna Steam Electric Station, Units 1 and 2," General Electric Company, RE-022 (DRF AOO 02558E), dated Januaiy 1987.

Page 22 of 92

ENCLOSURE A TO PLA-4?49 ATTACHMENT1 TO THE SAFETY ASSESSMENT FOR PROPOSED TECHNICALSPECIFICATION CHANGE FOR AOT/STI KCIZNSIONS Evaluation of the Applicabilityof Licensing Topical Reports as Justification for Extending STIs and AOTs for Technical Specification Instrumentation for Susquehanna Steam Electric Station Units 1 and 2 Page 23 of 92

ENCLOSURE A TO PLAN?A9

=-;e 0 b'av'vtpvee eeae+e ~ tees ooeoooooooooosoooooooooooeooooooooooeooooooooosooooosooeooooeoooeooo ~ oooo ~ ~ ~ ~ ~ ~ ~ oo ~ oo os ~ 1 Verification of Applicabilityof References 1 through 8 to Susquehanna, Units 1 and 2:...........,. 2

1. Reactor Protection System:

(Verification of the Applicability of References 1 and 2) ............, ....,.......... 2

2. ECCS Actuation Instrumentation:

(Verification of the Applicabilityof Reference 3).........................................................,.............,.. 3

3. Control Rod Block (CRB) Instrinnentation:

(Verification of the Applicability of Reference 4).......................................,..........,....................... 4

4. Isolation Instrumentation Common to ECCS or RPS:

(Verification of the Applicabilityof Reference 5).........................,.............,...............,........,....... 5

5. Isolation Instrumentation not Common to ECCS or RPS:

(Verification of the Applicability of Reference 6) ...,, ..........,...,..., . .. ., 7

6. Selected Instrumentation:

(Verification of the Applicabilityof Reference 7)............ ~ ~ ~ ssoooao ~~~ ~ ooo ~~ ao ~ ~ ao ~ aooooooos 8

7. RCIC Actuation Instrumentation:

(Verification of the Applicability of Reference 8 ),.......,.........................,.....,.......,.......... 9 C OileluS10neo seel ~

~~ ~~~~ oo ~ ~ ~ ~~ ~ ~ oooooooo ~~ asses 'ssess ~~ ~ ~ assess oooooooo ~~~ oo ~~ ~ ~ ~ oooo ~ ~ ~ ~ ~ ~o ~~ ~ 10 Page 24 of 92

ENCLOSURE A TO PLA<249 Justification for Extending STIs and AOTS for Susquehanna Technical Specification Instrumentation Objective:

This evaluation demonstrates that the analyses in General Electric Licensing Topical Reports (LTR) referenced in this proposed technical specification change (References 1 through 8) are applicable to Susquehanna Steam Electric Station (Susquehanna), Units 1 and 2, and provide justification for proposed changes to the Susquehanna Technical Specifications (TS) extending surveillance test intervals (STls) and allowable outwf-service times (AOTs) for the following:

TS 33.1: Reactor Protection System Instnunentation TS 33.2: Isolation Actuation Instnunentation TS 3.3.3: Emergency Core Cooling System Actuation Instrumentation TS 33.4.1: ATWS Recirculation Pump Trip System Instrumentation TS 33.4.2: End-of~cle Recircuhtion Pump Trip System Initiation TS 3.3.5: Reactor Core Isolation Cooling System Actuation Instrumentation TS 3.3.6: Control Rod Block Instrumentation TS 3.3.7.1: Radiation Monitoring Instrumentation (Main Control Room Outside AirIntake Radiation Monitor)

TS 3.3.9: Feedwater/Main Turbine Trip System Actuation Instrumentation This evaluation was performed because Safety Evaluations Reports (SER), issued by the NRC and subsequently incorporated into each of the Licensing Topical Reports (References 1 through 8),

approve using these analyses of a generic General Electric BWR in the associated Licensing Topical Reports to justify extending the AOTs and STIs for a specific plant provided that each plant:

a) Confirms the applicability of the generic analyses to the specific plant for the instruments covered by the Licensing Topical Reports; and, b) Confirms, based on the guidance provided in Reference 11, that any increase in instrument drift due to the extended test interval is properly accounted for in the setpoint calculation methodology.

This evaluation satisfies the first of these two requirements and confirms the applicability of the generic analyses to Susquehanna Steam Electric Station, Units 1 and 2, for the instruments covered by the Licensing Topical Reports.

Susquehanna Technical Specifications for Units 1 and 2, already incorporated AOT and STI extensions into Section 3/43.1, Reactor Protection System Instrumentation, based on References 1 and 2. Therefore, the applicability of those Licensing Topical Reports governing the Reactor Protection System are included for completeness and because the applicability of References 1 and 2 to the Susquehanna RPS is a prerequisite for the verification of the applicability of subsequent Licensing Topical Reports to instrumentation other than RPS.

Page 25 of 92

a ENCLOSURE A TO PLA<249 Verification ofApplicabilityof References 1 through 8 to Susquehanna, Units 1 and 2:

Reactor Protection System (Verification ofthe Applicability ofReferences 1 and 2)

References 1 and 2 (NEDC-30844A, "BWR Owners'roup Response to NRC Generic Letter 83-28, Item 4,5.3" and NEDC-30851P-A, "Technical Specification Improvement Analyses for BWR Reactor Protection System" ) provide justification for extending AOTs and STIs for Reactor Protection System Instruinentation for a generic BWR 4. Appendix L of Reference 2 identifies Susquehanna, Units 1 and 2, relay type BWR4s, as participants in the development of the Technical Specification Improvement Analysis discussed in Reference 2. Verification of applicability of References 1 and 2 to a specific plant is based on verification that the specific design of the plant and the reactor protection system are bounded by the assumptions and conditions used in the analyses. Appendix K to Reference 2 provides for the Reactor Protection System a "step-by-step procedure used in the plant specific application of the generic results ... of this report." Reference 9

("Technical Specification Improvement Analysis for the Reactor Protection System for Susquehanna Steam Electric Station, Units 1 and 2," General Electric Company, MDE-79-0485, April 1985) was prepared in accordance with the requirements of Appendix K to Reference 2 and constitutes a plant specific verification that Susquehanna Units 1 and 2 are bounded by the analyses conditions, assumptions and results. Reference 9 was prepared for Susquehanna by the General Electric Company as part of the development of Reference 2 and used design information listed in the report. Reference 9 concluded that the generic analysis in Reference 1 is applicable to Susquehanna and that each of the differences between the generic model and Susquehanna would not significantly affect the improvements in plant safety resulting &om the proposed changes to AOTs and STIs for the Reactor Protection System.

The generic analysis in References 1 and 2 used component failure data based on industry experience. This assumption is applicable to Susquehanna without verification because the results of the analysis were determined to be insensitive to instniment reliability and uncertainty in component failure rates does not significantly affect the results of the analysis. The conclusions in References 1 and 2 regarding the impact of common cause failure rates, component wear caused by testing, reduced redundancy during testing, and sensitivity to human error rates during testing are generic and are assumed to be applicable to Susquehanna.

As part of this verification of the applicability of Reference 2 to Susquehanna, IP&L reviewed References 1, 2 and 9 and appropriate supporting information to verify that: design information used in the preparation of Reference 9 was correct and appropriate; Susquehanna design changes implemented since the completion of References 1, 2 and 9 do not invalidate the conclusions; and, the results are reasonable, The PAL review of References 1, 2, and 9 and supporting documentation, did not identify any discrepancies that would invalidate the conclusion that the results of the generic analyses in References 1 and 2 and the Susquehanna specific analysis in Reference 9 are applicable to Susquehanna Units 1 and 2.

Page 26 of 92

'i q ENCLOSURE A TO PLA-4249 ECCS Actuation Instrumentation:

(Verification ofthe Applicability of Reference 3)

Reference 3 (NEDC-30936P-A, "BWR Owners'roup Technical Specification Improvement Methodology with Demonstration for BWR ECCS Actuation Instrumentation," Parts 1 and 2) provides justification for extending AOTs and STIs for Emergency Core Cooling System actuation instruinentation for a generic BWR 4. Appendix N of Part 1 and Appendix B of Part 2 of Reference 3 identifies Susquehanna, Units 1 and 2, relay type BWR4s, as participants in the development of the Technical Specification Improvement Analysis discussed in Reference 3. Part 2 of Reference 3 applied the generic analysis in Part 1 of Reference 3 to six "envelope cases" intended to ensure that all plants of each GE product line are bounded by the analysis and conclusions for the generic model. The SER supporting Reference 3 (Part 2) states that the review of Reference 3 resulted in "full confidence that the envelope models do, in fact, bound all parts of a particular product line..."

The SER further states that "In order for a licensee to use the generic analysis as justification for ECCS actuation instrumentation STI and AOT changes, the licensee should provide verification that either the BWR product line generic model or one of the envelope cases provides an accurate representation of its plant ..."

Reference 10 ("Technical Specification Improvement Analysis for the Emergency Core Cooling System Actuation Instrumentation for Susquehanna Steam Electric Station, Units 1 and 2," General Electric Company, RE-022 (DRF AOO-02558E), dated January 1987) was prepared in accordance with the requirements of Appendix F to Reference 2 and constitutes a plant specific verification that Susquehanna, Units 1 and 2, are bounded by the analyses, conditions, assumptions and results of Reference 3. Reference 10 was prepared for Susquehanna by the General Electric Company as part of the development of Reference 3. Reference 3 used design information as listed in the report.

Reference 10 concluded that the differences between Susquehanna, Units 1 and 2, and the generic BWR are enveloped by a combination of the analyses for BWR 3/4 case 4A and BWR 5/6 case SC described in Reference 3. This conclusion demonstrates the impact of the proposed changes to the ECCS actuation instrumentation Technical Specifications on ECCS water injection function failure meets the acceptance criteria in Reference 3, Parts 1 and 2. Therefore, the generic analysis is applicable to Susquehanna.

As part of this verification of the applicability of Reference 3 to Susquehanna, PP&L reviewed References 3 and 10 to verify that: design information used in the preparation of Reference 10 was correct and appropriate; Susquehanna design changes implemented since the completion of References 3 and 10 do not invalidate the conclusions of References 3 or 10; and, the conclusions in References 3 and 10 are reasonable. This review identified design changes implemented after the completion of Reference 10 and other differences between Reference 10 and the Susquehanna Individual Plant Evaluation (IPE). These differences were evaluated in Calculation EC-RISK-1046, dated 9/15/94, which concluded that the differences between the current SSES design and the design input assumptions used in Reference 10 have an insignificant impact on the analyses in References 3 and 10 and do not affect the conclusions of References 3 and 10 that AOT and STI extensions are justified.

Page 27 of 92

ENCLOSURE A TO PLA-4249 Except as identified and dispositioned above, the PP&L review of References 3 and 10 did not identify any discrepancies that would invalidate the conclusion that the results of the generic analyses in References 3 and the Susquehanna specific analysis in Reference 10 are applicable to Susquehanna Units 1 and 2.

Control Rod Block (CRB) Instrumentation:

(Verification ofthe Applicabilityof Reference 4)

Reference 4 (NEDC-30851P-A, Supplement 1, "Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation" ) provides justification for extending AOTs and STIs for instrumentation that initiate Control Rod Blocks. Reference 4 identifies Susquehanna, Units 1 and 2, BWR4s which utilize a solid-state Reactor manual Control System (RMCS), as participants in the development of the Technical Specification Improvement Analysis discussed in Reference 4.

Although reliability studies in Reference 1 and 2 justHy extendng AOTs and STIs for the RPS, the full benefits of these extensions cannot be utilized unless the extensions can be justified for the control rod block functions that share common instniments with the reactor protection system. The objective of Reference 4 is to establish a basis for extending AOTs and STIs to the following control rod block instrumentation; Rod Block Monitor, APRM Rod Block, Scram Discharge Volume Water Level Rod Block, and Reactor Coolant System Recirculation Flow.

Although the SER associated with Reference 4 requires confirmation of the applicability of the generic analyses to a specific plant, no guidance is provided in Reference 4 or the SER for performing this verification. Therefore, PP&L's verification of applicability of Reference 4 to Susquehanna, Units 1 and 2, is based on verification that the Susquehanna is consistent with the design, conditions and any other assumptions used in the generic analysis contained in Reference 4.

The results ofthis review are presented below:

The generic analysis in Reference 4 is based on the assumption that the analyses and conclusions of References 1 and 2 which justify extensions to RPS AOTs and STls are applicable. As determined in Reference 9 and confirmed above in Section Il.l of this evaluation, the analyses and conclusions of References 1 and 2 are applicable to Susquehanna Units 1 and 2.

The generic analysis is based on Control Rod Block (CRB) function designs as described in Section 3 of Reference 4. The design of the each of CRB functions at Susquehanna is consistent to the level of detail presented with the design as described in Section 3 of Reference 4. Susquehanna Units 1 and 2 utilize a flow biased APRM Rod Block Monitor system which does not incorporate the APRM/RBM/1'echnical Specification (ARTS) improvement program modifications.

The generic analysis in Reference 4 assumes that the component failure data used in the RPS study in References 1 and 2 is applicable to instruments common to RPS and CRB and the failure rates for other instruments are assumed to be in the same range as the common instruments based on their physical similarities. The same assumptions are applicable to the CRB systems at Susquehanna.

Page 28 of 92

ENCLOSURE A TO PLA-4249 The generic analysis in Reference 4 (Section 5) justifies extending AOTs and STIs based on a qualitative review of the consequences of a failure of each of the CRB functions. All aspects ofthe discussions in Reference 4, Section 5, Justification for Extending Surveillance Test Intervals, are applicable to Susquehanna, Units 1 and 2.

'Ihe PP&L review of Refeience 4 and supporting documentation, did not identify any discrepancies that would invalidate the conclusion that the results of the generic analyses in Reference 4 are applicable to Susquehanna, Units 1 and 2.

Isolation Instrumentation Common to ECCS or RPS:

(Verification ofthe Applicabilityof Reference 5)

Reference 5 (NIH)C-30851P, "Technical Specification Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation, Supplement 2 (SER dated January 6, 1994)) provides justification for extending AOTs and STIs for'solation actuation instrumentation that utilize instruments that are common to RPS or ECCS. Appendix B of Reference 5 identifies Susquehanna, Units 1 and 2, relay type BWR4s, as participants in the development of the Technical Specification Improvement Analysis discussed in Reference 5.

Although reliability studies in Reference 1, 2, 3 and 4 justify extending AOTs and STIs for the RPS and ECCS, the full benefits of these extensions cannot be utilized unless the extensions can be justified for the instrinnentation used to initiate containment or reactor pressure vessel isolation functions that are common to RPS and/or ECCS. The objective of Reference 5 is to establish a basis for extending AOTs and STIs for Susquehanna isolation instruinentation that is common to ECCS and RPS. The isolation instrumentation on Table 332-1 that is common with the Reactor Protection System includes Functions l.al, I.b, 1.e, 2.b, 3.b, 7.a, and 7.e. The isolation instrumentation on Table 3.3.2-1 that is common with the ECCS instrumentation includes Functions 1.a1, l.a3, 1.b, S.j (HPCI vacuum breaker), and 6.j (RCIC vacuum breaker) and 7a.

Although the SER associated with Reference 5 requires confirmation of the applicability of the generic analyses to a specific plant, no guidance is provided in Reference 5 or the SER for perfoiming this verification. Therefore, PP&L's verification of applicability of Reference 5 to Susquehanna is based on verification that Susquehanna is consistent with the design, conditions and any other assumptions used in the generic analysis contained in Reference 5. The results of this review are presented below:

The generic analysis in Reference 5 is based on the assumption that the analyses and conclusions of References 1, 2 and 3 that justify extensions to RPS and ECCS AOTs and STIs are applicable. As determined in References 9 and 10 and confirmed above in Sections II.l and H2 of this evaluation, the analyses and conclusions show that References 1, 2 and 3 are applicable to Susquehanna, Units 1 and 2.

The generic analysis in Reference 5 assumes that the component failure data used in the RPS and ECCS reliability studies in References 1, 2 and 3 is applicable to instruments common to RPS and ECCS. This assumption is applicable to Susquehanna. No verification of this assumption was performed because the conclusion is generic to all Page 29 of 92

ENCLOSURE A TO PLAA249 BWR4 plants, Additionally, the results of the generic analysis were generally insensitive to instrumentation reliability.

The generic analysis in Reference 5 included a bounding analysis using a conservatively assumed single sensor controllmg a single isolation valve. The results of extending AOTs and STIs on this simple instruinent configuration were acceptable based on the observation that the impact of actuation device reliability, which is not affected by the proposed changes to AOTs and STIs, was dominant. Since the simple model determined the pmposed AOT/STI extensions were acceptable, penetrations protected by multiple actuation devices (valves) and multiple instiinnents channels are bounded by the conclusions.

The PP8'cL review of Reference 4 and supporting documentation, did not identify any discrepancies that would invalidate the conclusion that the results of the generic analyses in Reference 5 are applicable to Susquehanna, Units 1 and 2.

Isolation Instrumentation not Common to ECCS or RPS:

(Verification of the Applicabilityof Reference 6)

Reference 6 (NEDC-31677P-A, "Technical Specification Improvement Analyses for BWR Isolation Actuation Instiuinentation") provides justification for extending AOTs and STIs for isolation actuation instriunentation that is not common to either RPS or ECCS. Appendix E of Reference 6 identifies Susquehanna, Units 1 and 2, relay type BWR4s, as a participant in the development of the Technical Specification Improvement Analysis discussed in Reference 6. The isolation instrumentation on Table 332-1 not common to ECCS and RPS include functions: 1.a2; 1.c; 1.d; 2.a; 2.c; 2.d; 2.e; 2.f; 3.a; 3.c; 3.d; 3.e; 3.f; 3.g; 3h; 3i; 4.a through 4.g; S.a through S.i; 6.a thmugh 6.i; 7b; 7.c; and 7d..

Although the SER associated with Reference 6 requires confirmation of the applicability of the generic analyses to a specific plant, no guidance is provided in Reference 6 or the SER for performing this verification. Therefore, PP85Ls verification of applicability of Reference 6 to Susquehanna is based on verification that Susquehanna is consistent with the design, conditions and any other assumptions used in the generic analysis contained in Reference 6. The results of this review are presented below:

The generic analysis in Reference 6 assumes that the component failure data used in the RPS and ECCS reliability studies in References 1, 2 and 3 is also applicable to instruments not common to RPS and ECCS. This assumption is applicable to Susquehanna without verification for the following reasons:

a) The generic analysis in Reference 6 assumes that the component failure data used in the RPS study in References 1 and 2 is applicable to instruments common to RPS and Contml Rod Block and the failure rates for other instruments are assumed to be in the same range as the common instruinents based on their physical similarities.

Page 30 of 92

ENCLOSURE A TO PLA-4249 b) As stated in the SER for Reference 6, "to 'envelope'he effect of the variations in failure rates and number of components within a logic channel, GE increased the sensor and relay failure rates by a factor of 3...;" and, c) The results of the analysis were determined to be insensitive to instriunent reliability and uncertainty in component failuie rates does not significantly affect the results ofthe analysis.

The conclusions in Reference 6 regarding the impact of common cause failure rates, component wear caused by testing, reduced redundancy during testing, and sensitivity to human error rates during testing are generic and are assumed to be applicable to Susquehanna. These same assumptions are applicable to the Control Rod Block systems at Susquehanna.

Reference 6, Section 5.5, Application of Results to Other Plants, discusses the instrumentation configurations including variations in number of sensors and logic designs which are enveloped by the generic analysis. This discussion demonstrates that the generic analysis e'nvelopes all isolation instrumentation not common to RPS or ECCS at Susquehanna, Units 1 and 2.

The PP&L review of Reference 6 and supporting documentathn, did not identify any discrepancies that would invalidate the conclusion that the results of the generic analyses in Reference 6 are applicable to Susquehanna, Units 1 and 2.

Selected Instrumentation:

(Verification of the Applicability of Reference 7)

Reference 7 (GENF 770-06-1A, "Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications" (SER dated July 21, 1992)) provides justification for extending AOTs and STIs for miscellaneous actuation instrumentation (except RCIC) for the following plant systems:

Feedwater System/Main Turbine Trip; ATWS/RPT and AIU/RPT; Refueling Floor Radiation Monitoring; Control Room Inlet Radiation Monitoring; and, Control Rod Block Instrumentation not common to RPS.

Although the SER associated with Reference 7 requires confirmation of the applicability of the generic analyses to a specific plant, no guidance is provided in Reference 7 or the SER for performing this verification. Therefore, PP&L's verification of applicability of Reference 7 to Susquehanna is based on verification that the Susquehanna is consistent with the design, conditions and any other assumptions used in the generic analysis contained in Reference 7. The results of this review are presented below:

Page 31 of 92

ENCLOSURE A TO PLAA249 The generic analysis in Reference 7 assumes that the component failure data used in the RPS and ECCS reliability studies in References 1, 2 and 3 is also applicable to instimnents not common to RPS and ECCS. This assumption is applicable to Susquehanna without verification, The ge'neric analysis in Reference 6 assumes that the component failine data used in the RPS study in References 1 and 2 is applicable to instruments common to RPS and ECCS and the failure rates for other instruments are assumed to be in the same range as the common instruments based on their physical similarities.

The approach used in Reference 7 to justify the AOT/STI extensions for the selected instrumentation listed above differed Som the approach used in References 1 through 6.

Instead of applying criteria consisting of specific percent limits on changes in system unavailability or failure &equency due to AOT and STI extensions, the results of References 1 through 6 were determined to be applicable based on the assumption of the similarity (components, configurations, redundancy, and required actions) between the instruments covered in Reference7 and those previously analyzed in References 1 through 6.

Additionally, the SER associated with Reference 7 justified extending AOTs and STIs based on a qualitative review of the consequences of a failure of each of the instrument functions covered by Reference 7.

Based on the approach used in Reference 7, PP&L confirmed the applicability of Reference 7 to Susquehanna, Units 1 and 2, as follows:

a) PP&L confirmed the similarity (components, configurations, redundancy, and required actions) between the instruments covered in Reference 7 and those previously analyzed in References 1 through 6.

b) PP&L confirmed that the qualitative evaluations of the consequences of a failure of each of the instrument functions covered by Reference 7 were consistent with the discussions in Section IV of Reference 7 and were also applicable to Susquehanna Units 1 and 2.

The PP&L review of Reference 7 and supporting documentation, did not identify any discrepancies that would invalidate the conclusion that the results of the generic analyses in Reference 7 are applicable to Susquehanna, Units 1 and 2.

RCIC Actuation Instrumentation:

(Verification of the Applicability of Reference 8 )

Reference 8 (GENE-770-06-2A, "Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications" (SER dated July 21, 1992)) provides justification for extending AOTs and STls for RCIC actuation instrumentation. The specific instruments and corresponding Technical Specification line items covered by this review of Reference 8 are also used to actuate HPCI and were included in the evaluation of Reference 3.

Therefore, the applicability of both References 3 and 8 to Susquehanna must be confirmed to use either as the justification for extending STIs and AOTs for HPCI or RCIC.

Page 32 of 92

ENCLOSURE A TO PLA-4249 The SER associated with Reference 8 requires confirmation of the applicability of the generic analyses to a specific plant by verification that either the appropriate BWR product line generic model or one of the enveloped cases provides an accurate or conservative repiesentation of the plant. The results of PPM.'s verification of applicability of Reference 8 to Susquehanna Units 1 and 2 are presented below:

The generic analysis in Reference 8 assumes that the plant is enveloped by either the appropriate BWR product line generic model or one of the enveloped cases provides an accurate or conservative representation of the plant. Susquehanna Units 1 and 2 satisfy this assumption as discussed in the evaluation of the applicability of Reference 3 for the ECCS actuation instnunentation.

The generic analysis in Reference 8 assumes RCIC actuation instiuinentation is seismically and environmentally qualified. Susquehanna satisfies this assumption.

The generic analysis in Reference 8 assumes RCIC actuation instrumentation is directly comparable to the HPCI actuation instrumentation. These assumptions include: that transmitters are all located in the reactor building outside the diywell and not subjected to harsh environments; initiation is based on a one outwf-two twice logic for reactor vessel low-low water level; and, redundant instrumentation is physically separated and meets single failure criteria up to the final actuated device. Susquehanna satisfies these assumptions.

The generic analysis in Reference 8 assumes that the component failure data used in the RPS and ECCS reliability studies in References 1, 2 and 3 is also applicable to RCIC actuation instrumentation. Susquehanna meets this criteria because the HPCI and RCIC share common instrumentation.

The PP&L review of Reference 8 and supporting documentation did not identify any discrepancies that would invalidate the conclusion that the results of the generic analyses in Reference 8 are applicable to Susquehanna, Units 1 and 2.

==

IV. Conclusion:==

The PAL review of References 1 through 8 and supporting documentation, did not identify any discrepancies that would invalidate the conclusion that the results of the generic analyses in Reference 1 through 8 are applicable to Susquehanna, Units 1 and 2.

Page 33 of 92

ENCLOSURE A TO PLA-4249 ATTACHMPG' TO THE SAFETY ASSESSMENT FOR PROPOSED TECHNICALSPECIFICATION CHANGE FOR AOT/STI EXIZNSIONS Evaluation of the Effect of Increasing the Minimum Interval between Instrument Functional Tests on the Identification of Excessive Driftof Instrument Setpoints for Susquehanna Steam Electric Station Units 1 and 2 Page 34 of 92

ENCLOSURE A TO PLA-4249 Evaluation of the Effect of Increasing the Minimum Interval between Instiuinent Functional Tests on the Identification of Excessive IMtofInstmnent Setpoints PP8hL evaluated and determined that there would be no effect on the identification of excessive instrument setpoints drift as a result of extending the minimum interval between iiistrument functional tests from monthly to quarterly. This conclusion is applicable to the instrumentation in the following Susquehanna systeins:

TS 3.3.1: Reactor Protection System Instrumentation TS 332 Isolation Actuation Instmnentation TS 3.33: Emergency Core Cooling System Actuation Instrumentation TS 33.4.1: ATWS Recirculation Pump Trip System Imp~mentation TS 3.3.4.2: End-of-Cycle Recirculation Pump Tiip System Initiation TS 33.5: Reactor Core Isohtion Cooling System Actuation Instrumentation 3.3.6: Control Rod Block Instrumentation 3.3.7.1: Radiation Monitoring Instrumentation 3.3.9: Feedwater/Main Turbine Trip System Actuation Instriunentation BACKGROUND This document evaluates proposed changes to the Susquehanna Technical Specifications (TS) that extend the minimum Surveillance Test Intervals (STIs) for channel functional tests from monthly to quarterly. The justification for extending instrumentation STIs is the analyses in various Licensing Topical Reports (References 1 through 8). Safety Evaluations Reports (SER), issued by the NRC and subsequently incorporated into each of these Licensing Topical Reports, approved using the Licensing Topical Reports to justify extending the STls for BWR plants for which the analyses are applicable. One of the prerequisites for using these Licensing Topical Reports as justification for extending STIs is that each plant must confirm that any increase in instrument drift due to the extended test interval is properly accounted for in the setpoint calculation methodology. Guidance for performing this evaluation is provided in a letter from CZ. Rossi, NRC, to R. F. Janacek, BWROG, "Staff Guidance for Licensee Determination that the Drift Characteristics for Instrumentation Used in RPS Channels are Bounded by NEDC-30851P Assumptions When The Functional Test Interval is Extended &om Monthly to Quarterly," April27, 1988 (Reference 11).

EVALUATION:

The conclusion that there is no effect on the identification of excessive instrument setpoint drift as a result of extending the minimum interval between instrument functional tests from monthly to quarterly is based on information given below. The surveillance test intervals (STI) that willbe extended are for the performance of instrument CHANNEL FUNCTIONAL TESTS, During the performance of instrument channel functional tests, the instrument functions, e.g., alarms and/or trips, are verified but instrument setpoints are not verified. Instrument setpoints are verified during instrument CHANNEL CALIBRATIONS. The Page 35 of 92

ENCLOSURE A TO PLA-4249 proposed amendment to the Susquehanna Technical Specifications does not make any changes to the

&equency for performing instrument CHANNEL CALIBRATION. 'Iherefore, the proposed change which extends the interval between instrument CHANNEL FUNCTIONAL TESTS but does not affect the Gequency of CHANNEL CALIBRATIONSwill not have any affect on the timeliness of the identification and/or correction of instrument setpoint errors resulting Gem drift Page 36 of 92

0 ENCLOSURE A TO PLA<249 ATI'ACHMENT3 TO THE SAFETY ASSESSMENT FOR PROPOSED TECHNICALSPECIFICATION CHANGE FOR AOT/STI EXI'ENSIONS General Electric Company MDF 79-0485 April 1985 TECHNICALSPECIFICATION IMPROVEMENTANALYSIS FOR THE REACTOR PROTECTION SYSTEM FOR SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 Page 37 of 92

ENCLOSURE B TO PLA-4249 NO SIGNIFICANT HAZARDS CONSIDERATIONS Page 1 of 7

ENCLOSURE B TO PLA-4249 Pennsylvania Power &. Light Company has evaluated each of the proposed Technical Specification changes in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. This evaluation is applicable to each of the following changes:

1. Extending Allowable Out-of-Service Times (AOTs) and Surveillance Test Intervals (STIs) between CHANNEL FUNCTIONAL TESTS for selected instrumentation, based on Licensing Topical Reports (References 1 through 8);

2. Changing required actions and AOTs for the selected instrumentation to make requirements consistent with the assumptions used in the analyses in References 1 through 8 and additional actions required to prevent extended AOTs from resulting in extended loss of instrument function;

3. Changing required actions and completion times for instrumentation associated with the ADS initiation, Recirculation Pump Trip, and pump suction lineup for HPCI and RCIC; 4, Changing Applicability requirements and required actions for the Reactor Vessel Water Level-Low, Level 3 function that isolates the RHR Shutdown Cooling System so that this function is required to be OPERABLE in OPERATIONAL CONDITIONS 3, 4, and 5 which will prevent inadvertent loss of reactor coolant via the RHR Shutdown Cooling System during these OPERATIONAL CONDITIONS;

5. Removing notes added to support maintenance on leak detection temperature detectors and removing a Note (Unit 1 only) that provided one time only relief from the requirements of TS 3.0.4 for the IRM control rod block instruments; and,

6. Reformatting, renumbering, and/or rewording existing requirements to incorporate the changes above into Susquehanna Technical Specifications for Unit 1 and Unit 2.

The bases for the determination that the proposed changes do not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below.

The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed TS changes increase the AOTs and STIs for actuation instrumentation intended to detect or mitigate accidents; establish required actions consistent with NUREG-1433 for some instruments that are more specific but equivalent to existing required actions; establish new requirements to prevent inadvertent loss of reactor coolant via the RHR Shutdown Cooling System during OPERATIONAL CONDITIONS 3, 4 and 5; and, eliminate notes that were

~

intended to provide one time only exemptions from certain requirements. The proposed changes I ~~

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ENCLOSURE B TO PLA<249 affect only those Technical Specification requirements that govern operability, required actions and routine testing of plant instruinents that detect or mitigate accidents. The proposed changes do not affect any equipment or requirements that are assumed to be initiators of any analyzed events. Therefore, the proposed changes will not involve an increase in the probability of occurrence of an accident previously evaluated.

The proposed changes will not increase the consequences of an accident previously evaluated because the changes will not involve any physical changes to plant systems, structures, or components (SSC), or the manner in which these SSC are operated, maintained, modified, tested or inspected. The proposed changes will not alter the operation of equipment assumed to be available for the mitigation of accidents or transients by the plant safety analysis or licensing basis. The proposed changes extend the intervals between required performances of routine instrument testing. The proposed changes also modify time limits allowed for operation with inoperable instrument channels in situations when an inoperable instrument channel would not prevent actuation of the associated equipment. These changes are based on the demonstrated reliability of these instruments and are justified by the analysis in References 1 through 8. The small increases in the probability that the proposed changes will result in an equipment actuation failure has been determined in References 1 through 8 to be offset by safety benefits such as a reduction in the number of inadvertent actuations, a reduction in wear due to excessive testing, and better utilization of plant personnel and resources. These changes will not allow continuous plant operation with plant conditions such that a single failure will result in a loss of any safety function.

Proposed changes to required actions and completion times for instrumentation associated with the ADS initiation, Recirculation Pump Trip, and pump suction lineup for HPCI and RCIC make the required actions and completion times consistent with NUREG-1433, Standard Technical Specifications for General Electric Plants, BWR/4, Revision 0 (Reference 12). These changes are also consistent with the assumptions used in References 1 through 8. Therefore, these changes establish or maintain adequate assurance that components are operable when necessary for the prevention or mitigation of accidents or transients and that plant variables are maintained within limits necessary to satisfy the assumptions for initial conditions in the safety analysis. In addition, the proposed change provides the benefit of avoiding an unnecessary shutdown transient when appropriate measures are available to compensate for the inoperable instrumentation. Therefore, the proposed changes willnot increase the consequences of an accident previously evaluated.

There is no significant increase in the probability or consequences of an accident previously evaluated resulting from changes that reformat, renumber, and/or reword existing requirements to incorporate the changes above or from the removal of notes that were intended for one time only use and are no longer applicable.

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ENCLOSURE B TO PLA<249 The proposed changes do not create the possibility of a new or diferent kind of accident Pom any accident previously evaluated.

This proposed change will not involve any physical changes to plant systems, structures, or components (SSC), or the manner in which these SSC are operated, maintained, modified, tested, or inspected. The changes in normal plant operation are consistent with the current safety analysis assumptions. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes do not involve a significant reduction in a margm ofsafety.

The proposed TS changes: increase the AOTs and STIs for actuation instrumentation intended to detect or mitigate accidents; establish required actions consistent with NUREG-1433 for some instruments that are more specific but equivalent to existing required actions; establish new requirements to prevent inadvertent loss of reactor coolant via the RHR Shutdown Cooling System during Operational Conditions 3, 4 and 5; and, eliminate notes that were intended to provide one time only exemptions from certain requirements.

There is no significant reduction in the margin of safety resulting from changes to the minimum surveillance test intervals (STIs) and allowable out-of-service times (AOTs) for the testing and/or repair of instrumentation, This conclusion is based on the demonstrated reliability of these instruments and is justified by the analysis in References 1 through 8. The small increases in the probability that the proposed changes will result in an equipment actuation failure has been determined in References 1 through 8 to be offset by safety benefits such as a reduction in the number of inadvertent actuations, a reduction in wear due to excessive testing. These changes will not allow continuous plant operation with plant conditions such that a single failure will result in a loss of any safety function.

There is no significant reduction in the margin of safety resulting from changes to required actions and completion times for instrumentation associated with the ADS initiation, Recirculation Pump Trip, and pump suction lineup for HPCI and RCIC. These changes make the required actions and completion times consistent with NUREG-1433, Standard Technical Specifications for General Electric Plants, BWR/4. These changes are also consistent with the assumptions used in References 1 through 8. Therefore,.these changes establish or maintain adequate assurance that components are operable when necessary for the prevention or mitigation of accidents or transients and that plant variables are maintained within limits necessary to satisfy the assumptions for initial conditions in the safety analysis. In addition, the proposed change provides the benefit of avoiding an unnecesmy shutdown transient when appropriate measures are available to compensate for the inoperable instrumentation. Additionally, the proposed required actions ensure that actions to mitigate loss of single failure tolerance are initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for RPS) in accordance with the results of the analyses in References 1 through 8 and action to mitigate a loss of instrument function is initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Therefore, these changes will not allow continuous plant operation with plant conditions such that a single failure will result in a loss of any safety function. The Pennsylvania Power & Light Company performed reviews that confirmed the analyses in References 1 through 8 are applicable to SSES and that there would be no effect on the identification of excessive instrument setpoint drift as a Page 4 of 7

ENCLOSURE B TO PLAA249 result of increasing the minimum interval between instnnnent functional tests from monthly to quarterly.

There is no significant reduction in the margin of safety resulting Rom changes that reformat, renumber, and/or reword existing requirements to incorporate the changes above or from the removal of notes that were intended for one time only use and are no longer applicable.

An environmental assessment is not required for the proposed changes because the requested changes conform to the criteria for actions eligible for categorical exclusion as specified in 10 CFR 5122(c)(9).

The requested changes will have no impact on the environment. The proposed changes do not involve a significant hazards consideration as discussed in the preceding section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any e6luents that may be released offsite. In addition, the proposed changes do not involve a significant increase in individual or cumulative occupational radiation exposure.

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ENCLOSURE B TO PLA<249 REFERENCES

1. S. Visweswaran, et al., "BWR Owners'roup Response to NRC Generic Letter 83-28, Item 4.53,"

General Electric Company, NEDC-30844A, March1988.

2. W. P. Sullivan, et al., "Technical Specification Improvement Analyses for BWR Reactor Protection System," General Electric Company, NEDC-30851P-A, Miuch 1988.

3. D. B. Atcheson, et al"BWR Owners'roup Technical Specification Improvement Methodology with Demonstration for BWR ECCS Actuation Instriunentation," Parts 1 and 2, General Electric Company, NEDC-30936P-A, December 1988.

4. S. Visweswaran, et al., "Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation," General Electric Company, NEDC-30851P-A, Supplement 1, October 1988.

5. L. G. Frederick, et al., "Technical Specification Improvement Analysis for BWR Isolation Instnunentation Common to RPS and ECCS Instrumentation," General Electric Company, NEDC-30851P, Supplement 2, July 1986.

6. W. P. Sullivan, et al., "Technical Specification Improvement Analyses for BWR Isolation Actuation Instrumentation," General Electric Company, NEDC-31677P-A, July 1990.

"Bases for Changes to Surveillam Test Intervals and Allowed Outwf-Service Times for Selected Instrumentation Technical Specifications," General Electric Company, GENE-770-06-1A, December 1992.

8. "Bases for Changes to Surveillance Test intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," General Electric Company, GENE-770-06-2A, December 1992.

"Technical Specification Improvement Analysis for the Reactor Protection System for Susquehanna Steam Electric Station, Units 1 and 2," General Electric Company, MDE-79-0485, April 1985).

10. "Technical Specification Improvement Analysis for the Emergency core Cooling System Actuation Instrumentation for Susquehanna Steam Electric Station, Units 1 and 2," General Electric Company, RE-022 (DRF AOO 02558E), dated January 1987.

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'ENCLOSURE B TO PLAA249

11. C. E. Rossi, NRC, to R. F. Janacek, BWROG, "Staff Guidance for Licensee Determination that the Drift Characteristics for Instriimentation Used in RPS Channels ate Bounded by NEDC-30851P Assumptions when the Functional Test Interval is Extended Gem Monthly to Quarterly," April 27, 1988.

12. NUREG 1433, "Standard Technical Specifications, General Electric Plants BWR/4," Revision 0, September 1992.

13. Letter, C. L. Tully, BWROG, to B. K. Grimes, NRC, "BWR Owners'roup (BWROG) Topical Reports on Technical specification Improvement Analysis for BWR Reactor Protection systems-Use for Relay and solid State Plants (NEDC-30884 and NEDC-30851P)," November 4, 1992.

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ML18026A267

Text

SUBJECT:

Dear Sir:

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