ML18039A477

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Supplemental Application for Amends to Licenses DPR-33, DPR-52 & DPR-68 to Change TSs for Instrument Calibration Surveillance Frequencies.Proposed Changes Decrease Frequency of once-per-cycle by Substituting 24 Months for 18 Months
ML18039A477
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 08/14/1998
From: Abney T
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18039A478 List:
References
NUDOCS 9808200141
Download: ML18039A477 (72)


Text

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1 ~ 2g AND 3 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-390S1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE INDEX I. DESCRIPTION OF THE PROPOSED CHANGES ....................... 2 II. REASON FOR THE PROPOSED CHANGE ... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 2 III. SAFETY ANALYSIS . ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 3 A. Instrument Calibration SRs . ~ ~ ~ 3 B. Discussion of Changes ~ ~ e 8 C. Bases Changes .... .. 44 IV. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION ....... 40 V. ENVIRONMENTAL IMPACT CONSIDERATION ....................... 41 VI. REFERENCES ............... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ 43

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2, AND 3 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-390S1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE DESCRIPTION OF THE PROPOSED CHANGES The proposed TS changes for Unit 2 and 3 operation consist of increasing nominal 18-month surveillance intervals to 24 months (30 months when employing SR 3.0.2). The proposed TS changes include changes for Unit 1 equipment required to support Units 2 and 3 operation and maintain Unit 1 in shutdown condition.

TVA divided the affected TS SRs into two groups. SRs for which the proposed change does not constitute a change to an instrument calibration interval (non-instrument calibration SRs) were designated Group 1. For example, pump and valve functional tests, flow tests, logic system functional tests and response time tests are Group 1 type SRs. Changes to the surveillance intervals for the Group 1 SRs were addressed in the submittal provided on June 12, 1998 (Reference 1).

All other SRs (i.e., those for which the proposed change constitutes an increased instrument calibration interval) were designated Group 2. The Group 2 SRs are listed in Table 1. TVA proposes to change the surveillance intervals for these SRs based on supporting information provided in accordance with the guidance of Generic Letter 91-04 (Reference 2).

REASON FOR THE PROPOSED CHANGE TVA intends to implement 24-month fuel cycles for BFN Units 2 and 3. However, a number of SRs can only be performed during a plant shutdown, while for other surveillances it is preferable to have the plant in a shutdown condition to avoid the possibility of unnecessary plant transients. The plant TSs currently require these SRs to be performed on an 18-month frequency, consistent with the current 18-month fuel cycles. Therefore, to synchronize these requirements with a 24-month fuel cycle, it is necessary to extend the existing 18-month surveillance frequencies to 24 months.

This change will allow BFN to take advantage of improved fuel designs which support a 24-month refueling interval.

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III. SAFETY ANALYSIS A. Instrument Calibration SRs To determine the effect of increasing the calibration intervals to 24-months, plant drift studies of the "as-found/as-left" surveillance data were performed for the instruments associated with the SRs listed in Table 1.

Setpoint calculations were evaluated to determine the effects of the increased calibration interval on instrument accuracy's.

To meet the guidance documented in NRC Generic Letter 91-04 (Reference 2), the plant drift studies were performed in accordance with the methodology in Reference 3. This methodology has been reviewed by the NRC and is consistent with NRC Regulatory Guide 1.105 (References 5 and 6). The statistical evaluation was made of both instrument component and loop surveillance data to predict, within a 95%/95% confidence level, the expected performance of an instrument component or loop based on the past performance of the instrument. In some cases, there was insufficient data to perform a statistical evaluation. For these instruments, vendor data or existing generic studies were used to conservatively determine a value for the drift.

Studies were performed for specific instruments where surveillance data was available. To provide an adequate basis for the plant drift studies, the data for loops and components with similar characteristics were combined. To compensate for variability in plant shutdowns, the studies were performed for 24 months +

25% (30 months total). The plant drift studies resulted in repeatability values and the determination of time dependency.

The drift study value, based on surveillance data for groups of instruments, was compared to the appropriate accuracy value used in the setpoint calculation for these instruments. If the plant data drift value was bounded by the current setpoint calculation value, no change in the current calculation was required. If the plant data resulted in a 30 month drift value greater than the value used in the setpoint calculation, the value derived from the drift study was applied to the existing calculation. If no drift study was available, an extended drift value was established from either vendor data or existing generic studies.

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When a new value for drift was determined, it was to revise the value in the instrument calculation. The used instrument setpoint and existing allowable value were then reconfirmed using the new drift value.

Figure 1 illustrates the relationship between the setpoint (SP), the minimum and maximum acceptable allowable values [Av(min) and Av(max)] and the analytical limit (AL). The upper half of the figure, starting with the SP, applies to a process that increases toward the AL. The lower half of the figure applies to a process that decreases toward the AL.

Instrument drift error is included in the "Region of normal measurable uncertainties." To provide operational reliability and ensure that the instrument will perform its design basis function, the TS allowable value is established within the "Av Band."

Based on the results of the studies described above, none of the instruments listed in Table 1 require a change in the TS allowable value to accommodate a 24 month-nominal (30 month-maximum) calibration interval.

The setpoint calculations included the effects of power uprate operation. Therefore, these results are applicable for 24-month calibration intervals considering power uprate operation. Revised allowable values for power uprate operation with the current 18-month calibration intervals were provided in the Reference 4 submittal. No additional TS allowable value changes are necessary to support power uprate operation with 24-month calibration intervals.

Generic Letter 91-04 Issues Generic Letter 91-04 (Reference 2) provides guidance for addressing the effect of increased surveillance intervals on instrument drift and safety analysis assumptions. The following subsections specifically address the seven issues in Enclosure 2 of the Generic Letter.

Issue 1: Confirm that instrument drift as determined by as-found and as-left calibration data from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limi ts for a cali brati on interval.

A review of historical plant surveillance and maintenance records confirms that most of the problems affecting instrument operability are found as a result of surveillance tests other than instrument

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calibration. A review of the BFN data base indicated that there were only two occasions, one on Unit 2, and one on Unit 3 since the restart of the units in 1991 and 1995 respectively, in which the as-found surveillance value was outside of the allowable values)",

Issue 2: Confirm that the'alues of drift for each instrument type (make, model, and range) and application have been determined with a high probabili ty and a high degree of confidence. Provide a summary of the methodology and assumptions used to determine the rate of instrument drift with time based upon historical plant calibration data.

The methodology used to perform the plant drift studies of the plant instrument surveillance data is documented in Reference 3. This methodology has been reviewed by the NRC and is consistent with NRC Regulatory Guide 1.105 (References 5 and 6). A statistical evaluation was made of both instrument component and loop surveillance data to predict, within a 95%/95%

confidence level, the expected performance of an instrument component or loop based on the past performance of the instrument. In some cases, there was insufficient data to perform a statistical evaluation. For these instruments, vendor data or existing generic studies were used to conservatively determine a value for the drift. To provide an adequate basis for the plant drift studies, the data for loops and component with similar characteristics were combined. The surveillance data was analyzed to determine if the data was normally distributed. A scatter plot of the data was developed and linear regression and least-squares curve analyses performed on the data to determine time dependency. The corresponding accuracy values used in the instrument calculations were compared with the values from the drift study, and revisions were made to the calculation as necessary.

For example: The current calculation for the Reactor Vessel Water Level-Low, Level 3 Automatic Depressurization System (ADS) confirmatory signal, used an accuracy value of 0.774 inches of Water Column (inWC). The drift study resulted in an accuracy value of 0.660 inWC. For this new accuracy value, revised calculations confirmed that the margin to the Analytical Limit remained acceptable and that the current TS allowable value is within the calculated AV band.

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0 Issue 3: Confirm that the magnitude of instrument drift has been determined with a high probability and a high degree of confidence for a bounding calibration interval of'0 months for each instrument type (make, model number, and range) and application that performs a safety function. Provide a list of'he channels by TS section that identifies these instrument appli cati ons.

The drift performance was predicted with a 95%/95%

confidence level. In some cases, there was insufficient data to perform a statistical evaluation.

For these instruments, vendor data or existing generic studies were used to conservatively determine a value for the drift. The drift studies were performed for a 30 month cycle for each instrument type. Where insufficient data existed to perform a drift study, instrument drift values were established from either vendor data or existing generic studies. The affected instrument applications are listed in Table 1.

Issue 4: Confirm that a comparison of the projected instrument drift errors has been made with the values of drift used in the setpoint analyses. If this results in revised setpoints to accommodate larger drift errors, provide proposed TS changes to update trip setpoints. If the drift errors result in a revised safety analysis to support existing setpoints, provide a summary of the updated analysi s conclusions to confirm that safety limi ts and safety analysis assumptions are not exceeded.

Statistical evaluations were made of the plant "as-found/as-left" surveillance data. The results of these evaluations were used to confirm that the theoretical drift used in determining the allowable value and setpoint bounded the plant data. In some cases, there was insufficient data to perform a statistical evaluation. For these instruments, vendor data or existing generic studies were used to conservatively determine a value for the drift. There was no impact on the instrument setpoints or TS allowable values.

There were no changes in the instrument analytical limits resulting from additional drift considerations; therefore, additional safety analyses were not required.

Issue 5: Confirm that the projected instrument errors caused by drift are acceptable for control of plant parameters to effect a safe shutdown with the associ a ted i ns trumen ta ti on.

0 The impact of the drift has been reviewed for each instrument setpoint calculation with a time dependent component. Instruments without a time dependent component will not be impacted by 24-month cycles. The calculations performed ensured that the current operating setpoints provide adequate margin to the TS allowable values and the analytical limits. Therefore, the projected instrument errors caused by drift are acceptable for control of plant parameters to achieve a safe shutdown.

Issue 6: Confirm that all conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for channel checks, channel functional tests, and channel cali bra ti ons.

The drift studies of the plant surveillance data and the setpoint analyses have been fully verified.

Results of setpoint calculation revisions will be incorporated into plant surveillance procedures prior to 24-month cycle operation.

Issue 7: Provide a summary description of the program f'r monitoring and assessing the effects of increased calibration surveillance intervals on instrument drift and i ts effect on safety.

Evaluation of a 30 month calibration interval showed that in essentially all cases the current values used in the setpoint calculations bound the derived field drift value. There were only two occasions, one on Unit 2 and one on Unit 3 since the restart of the units, in which the as-found surveillance value was outside of the allowable values. This low number of occurrences confirms the validity of the process used to set the instruments. Nevertheless, attention will continue to be paid to equipment performance by monitoring of affected instrument channels. Recording of as-found and as-left values will continue routinely through TVA's maintenance program. A review is continuously performed through the work order program and failures are addressed through the corrective action program.

Discussion of Chan es ITS: 3.3.1.1 Reactor Protection System (RPS)

Instrumentation E1-7

The impacted Reactor Protection System (RPS) instrumentation has been evaluated based on make, manufacturer and model number to determine that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation. The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, manufacturer and model number the drift evaluations performed.

SR 3.3.1.1.13, 2.a., APRM Neutron Flux High, Setdown This function is performed by In-core Neutron Detectors (Neutron Flux) providing inputs to a GE304A3719G005 NUMAC Power Range Neutron Monitor. This monitor system's stability was evaluated by the Vendor (GE).

The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.1.1.13, 2.b., APRM Flow Biased Simulated Thermal Power High This function is performed by a Rosemount 1153DB6 Transmitter. The transmitter was evaluated using the methodology as described in Reference 3 against Rosemount Report D8900126 data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.1.1.13, 2.c., APRM Neutron, Flux High This function is performed In-core Neutron Detectors (Neutron Flux) providing inputs to a GE304A3719G005 NUMAC Power Range Neutron Monitor. This monitor system's stability was evaluated by the Vendor (GE).

The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.1.1.13, 4., Reactor Vessel Water Level Low, Level 3 This function is performed by a Rosemount 1153DB4 Transmitter and 710DUOTT Trip Units. The transmitter

and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated.

more frequent testing requirements remain unchanged.

These Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.1..1.13, 5., MSIV Closure Since functional testing to confirm proper valve and limit switch operation is performed more frequently than every 18 months, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the limit switches with respect to drift. Note, for the limit switches which are mechanical devices, misalignment is a more applicable term than drift.

SR 3.3.1.1.13, 6., Drywell Pressure High This function is performed by a Rosemount 1153GB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and more frequent testing if necessary, recalibrated.

requirements remain These unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.1.1.13, 7.a., SDV Water Level High RTD This function is performed by a level measuring system (Fluid Components Inc. FR72-4HTRDLL) consisting of a sensor (RTD) and switch (Remote Electronics). The sensor/switch was evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the projected 30 month drift value for this instruments does not exceed the drift allowance provided in the setpoint calculation for this

instrument.

SR 3.3.1.1.13, 7.b., SDV Water Level High Float Switch This function is performed by a Magnetrol 402-EP/VPX-S1MD4H Switch which is a mechanical device in nature.

Therefore, there is no drift values associated with this function.

SR 3.3.1.1.13, 8., Turbine Stop Valve Closure An increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the limit switches with respect to drift. Note, for the limit switches -which are mechanical devices, misalignment is a more applicable term than drift.

SR 3.3.1.1.13, 9., TCV Fast Closure, Trip Oil Pressure Low This function is performed by a Barksdale TC 9622-3 Switch. The switch was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instruments does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.1.1.13, 13., Low Scram Pilot Air Header Pressure This function is performed by a Static-0-Ring 6N6-B3-NX-C1A-JJTTX6 Switch on Unit 2 and a Static-0-Ring 6N6-B3-NX-C1A-JJTTX12 Switch on Unit 3. The switches were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for these instruments do not exceed the drift allowance provided in the setpoint calculation for these instrument.

SR 3.3.1.1.15, 8., Turbine Stop Valve Closure Bypass Function This function is performed by a Rosemount 1153GB8 Transmitter and 710DUOTT Trip Units. The transmitter and trip units were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the E1-10

projected 30 month drift values for these instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The trip units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated.

more frequent testing requirements remain unchanged.

These Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect these trip units with respect to drift.

SR 3.3.1.1.15, 9., TCV Fast Closure, Trip Oil Pressure Low Bypass Function This function is performed by a Rosemount 1153GB8 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an 'increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

ITS: 3.3.2.1 Control Rod Block Instrumentation The impacted Control Rod Block instrumentation has been evaluated based on make, manufacturer and model number to determine that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation. The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, manufacturer and model number the drift evaluations performed.

SR 3.3.2.1.4, 1.a., Rod Block Monitor Low Power Range-Upscale SR 3.3.2.1.4, 1.b., Rod Block Monitor Intermed. Power Range -- Upscale SR 3 3 2 1 4g 1 c Rod Block Monitor High Power Range

-- Upscale

~ g SR 3.3.2.1.4, 1.e., Rod Block Monitor. Downscale SR 3.3.2.1.8, 1.a., Rod Block Monitor Low Power Range Upscale (Bypass)

SR 3 3 2 1 8~ 1 b / Rod Block

~ Monitor Intermed. Power

Range -- Upscale (Bypass)

SR 3.3.2.1.8, 1.c., Rod Block Monitor High Power Range

-- Upscale (Bypass)

These functions are performed by In-core Neutron Detectors (Neutron Flux) providing inputs, (through the APRM's) to a GE 304A3720G005 NUMAC Power Range Neutron Monitor's Rod Block Monitor function. This monitor system's stability was evaluated by the Vendor (GE).

The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.2.1.5, 2., Rod Worth Minimizer 10% RTP Bypass Function This function is performed by Foxboro 823DP-D3S1SH2-M Transmitters (Feedwater Flow) as an input to the Foxboro Distributive System (Digital Feedwater Control). These transmitters are a recent plant modification and were initially evaluated, using the methodology as described in Reference 3, using a 30 month drift value.

ITS: 3.3.2.2 Feedwater and Main Turbine High Water Level Trip Instrumentation The impacted Feedwater and Main Turbine High Water Level Trip instrumentation has been evaluated based on make, manufacturer and model number to determine that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation.

The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, manufacturer and model number the drift evaluations performed.

SR 3.3.2.2.3, , FW and Main Turbine High Water Level Trip This function is performed by a Gould PD3200 Transmitter (Unit 2), Rosemount 1153DB4 Transmitter (Unit 3) and Rosemount 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for

0 the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified necessary, recalibrated.

more frequently, These more frequent and if testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

ITS: 3.3.3.1 Post Accident Monitoring Instrumentation The impacted Post Accident Monitoring instrumentation has been evaluated based on make, manufacturer and model number to determine that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation. The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, manufacturer and model number the drift evaluations performed.

SR 3.3.3.1.4, 2.a., Reactor Vessel Water Level Emergency Systems Range This function is performed by a Rosemount 1153DB5 Transmitter. This transmitter was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.3.1.4, 2.b., Reactor Vessel Water Level Post Accident Flood Range This function is performed by a Rosemount 1153DD5 Transmitter. This transmitter was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.3.1.4, 3., Suppression Pool Water Level This function is performed by a Rosemount 1154DP5 Transmitter. This transmitter was evaluated using the

methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.3.1.4, 4.a., Drywell Pressure Normal Range This function is performed by a Rosemount 1153DB6 Transmitter. This transmitter was evaluated using the methodology as described in Reference 3 against Rosemount Report D8900126 data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.3.1.4, 4.b., Drywell Pressure Wide Range This function is performed by a Rosemount 1154GP7 Transmitter. This transmitter was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.3.1.4, 5., Primary Containment Area Radiation This function is performed by a Victoreen 877-1/Victoreen 876A-1 Radiation Monitor (Unit 2), GE 237X731G009/ GE 304A3700G036 NUHAC Radiation Monitor (Unit 3). The Unit 2 monitor was evaluated using the methodology as described in Reference 3. The Unit 3 monitor was evaluated by the Vendor'(GE). The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.3.1.4, 6., PCIV Position An increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the limit switches with respect to drift. Note, for the limit switches which are mechanical devices, misalignment is a more applicable term than drift.

0 SR 3.3.3.1.4, 8., Suppression Pool Water Temperature This function is performed by a Weed 612D-1A Temperature Element and a Bailey Controls 740311CAAN2 Voltage Converter. The drift term for the converter was extrapolated linearly from 22.5 months to 30 months and evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the overall loop drift allowance provided in the setpoint calculation for this instrument.

0 SR 3.3.3.1.4, 9., Drywell Atmosphere Temperature This function is performed by a Weed SP611-lA Temperature Element and a Transmation Inc. S-650IT Current Converter. The drift term for the converter was extrapolated linearly from 24 months to 30 months and evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the overall loop drift allowance provided in the setpoint calculation for this instrument.

ITS: 3.3.3.2 Backup Control System Instrumentation The impacted Backup Control System instrumentation has been evaluated based on make, manufacturer and model number to determine that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation. The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, manufacturer and model number the drift evaluations performed.

SR 3.3.3.2.2 (Unit 3 only), Suppression Pool Water Level This function is performed by a Fluid Components Inc.,

CL86 Transmitter. This transmitter was evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed 0he drift allowance provided in the setpoint calculation for this instrument.

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0 SR 3.3.3.2.3, , Each required instrument channel except Supp. Pool Water Level (see Bases, Table B 3.3.3.2-1)

1. Reactor Water Level Indication
2. Reactor Pressure Indication
3. Suppression Pool Temperature Indication
4. Suppression Pool Level Indication (see SR 3.3.3.2.2)
5. Drywell Pressure Indication
6. RHR Flow Indication
7. RCIC Flow Indication
8. RCIC Turbine Speed Indication
9. Drywell Temperature Indication (Unit 2 only)
10. RHRSW Header Pressure
1. This function is performed by a Yarway 4418EC/4455 Level Transmitter/Indicator. This transmitter/indicator was evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the drift value for this instrument does not exist, the drift allowance is provided in the Readability term.
2. This function is performed by a Rosemount 1151GP9 Transmitter. This transmitter was evaluated using the methodology as described in Reference 3 against plant calibration data. .The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.
3. This function is performed by a American Standard Type T Thermocouple. This thermocouple was evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.
4. See SR 3.3.3.2.2
5. This function is performed by a Rosemount 1153DB6 Transmitter. The transmitter was evaluated using the methodology as described in Reference 3 against Rosemount Report D8900126 data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

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6. This function is performed by a GE 555 Transmitter (Unit 2), Rosemount 1153DF Transmitter (Unit 3) and Moore SRT Modifier. The transmitter was evaluated using the methodology as described in Reference 3 against Rosemount Report D8900126 data. The drift term for the modifier was extrapolated from 22.5 months to 30 months and evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.
7. This function is performed by a Rosemount 1153DF5TB Transmitter (Unit 2), GE 555 Transmitter (Unit 3) and a GEMAC 50-565100AACl Modifier. This transmitter was evaluated using the methodology as described in Reference 3. The drift term for the modifier was extrapolated linearly from 22.5 months to 30 months and evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the overall loop drift allowance provided in the setpoint calculation for this instrument.
8. This function is for confirmation of operation by a GE 180 Indicator. No drift analysis is necessary.
9. This function is performed by a Weed SP611-1A Temperature Element and a Transmation Inc. S-650T Current Converter. The drift term for the converter was extrapolated linearly from 24 months to 30 months and evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the overall loop drift allowance provided in the setpoint calculation for this instrument".'0.

This function is performed by GE 50-551032EAAK1 Transmitters and Rosemount 1151GP8G22B2 Transmitter.

This GE transmitter was evaluated using the methodology as described in Reference 3 against plant calibration data. The drift term for the Rosemount 'transmitter was extrapolated linearly to 30 months and evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not El-17

exceed the overall loop drift allowance provided in the setpoint calculation for this instrument.

ITS: 3.3.4.1 End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation The impacted End of Cycle Recirculation Pump Trip (EOC-RPT) instrumentation has been evaluated based on make, manufacturer and model number to determine that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation. The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, manufacturer and model number the drift evaluations performed.

SR 3.3.4.1.2, , Turbine Stop Valve and TCV Closure Bypass Function This function is performed by a Rosemount 1153GB8 Transmitter and 710DUOTT Trip Units. The transmitter and trip units were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for these instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The trip units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated.

more frequent testing requirements remain unchanged.

These Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect these trip units with respect to drift.

SR 3.3.4.1.3, , Turbine Stop Valve Closure An increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the limit switches with respect to drift. Note, for the limit switches which are mechanical devices, misalignment is a more applicable term than drift.

SR 3.3.4.1.3, , TCV Fast Closure, Trip Oil Press.

Low This function is performed by a Barksdale TC 9622-3 Switch. The switch was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instruments

does not exceed the drift allowance provided in the setpoint calculation for this instrument.

ITS: 3.3.4.2 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation The impacted Anticipated Transient Without Scram Recirculation Pump Trip ATWS-RPT System instrumentation has been evaluated based on make, manufacturer and model number to determine that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation. The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, manufacturer and model number the drift evaluations performed.

SR 3.3.4.2.3, a., Reactor Vessel Water Level Low Low, Level 2 This function is performed by a Rosemount 1153DB5 Transmitter and GE MTU 184C5988 Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The GE Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the GE Trip Units with respect to drift.

SR 3.3.4.2.3, b., Reactor Steam Dome Pressure High This function is performed by a Rosemount 1153GB9 Transmitter--and GE 184C5988 Trip Units. The transmitter,and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation

'ndicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for. this instrument. The GE Trip Units are functionally checked and setpoint verified necessary, recalibrated.

more frequently, and if These more frequent testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month

fuel cycle does not affect the GE Trip Units with respect to drift.

ITS: 3.3.5.1 Emergency Core Cooling System (ECCS)

Instrumentation The impacted Emergency Core Cooling System (ECCS) instrumentation has been evaluated based on make, manufacturer and model number to determine that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation. The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, manufacturer and model number the drift evaluations performed.

SR 3.3.5.1.5, 1.a., Reactor Vessel Water Level Low Low Low, Level 1 This function is performed by a Rosemount 1153DB5 Transmitter and GE MTU 184C5988 Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The GE Trip Units are functionally checked and setpoint verified more frequently, and necessary, recalibrated.

if These more frequent testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the GE Trip Units with respect to drift.

SR 3.3.5.1.5, 1.b., Drywell Pressure High This function is performed by a Rosemount 1153GB4 Transmitter...and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated.

more frequent testing requirements remain unchanged.

These Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the E1-20

Rosemount Trip Units with respect to drift.

SR 3.3.5.1.5, 1.d., CS Pump Discharge Flow Low (Bypass)

This function is performed by a Static-0-Ring 103AS-B202-NX-JJTTX6 Switch. The switch was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instruments does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.5.1.5, l.e., CS Pump Start Time Delay Relay:

Pumps A, B, C, D (with diesel power)

This function is performed by a Agastat ETR14D3DNM015 time delay relay upon implementation of the modifications for 24 month fuel cycle. The new timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.5.1.5, 1.e., CS Pump Start Time Delay Relay:

Pump A (with normal power)

This function is performed by a Agastat ETR14D3ANM015 time delay relay. The timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.5.1.5, l.e., CS Pump Start Time Delay Relay:

Pump B (with normal power)

This function is performed by a Agastat ETR14D3DNM015 time delay relay. The timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this

instrument.

SR 3.3.5.1.5, 1.e., CS Pump Start Time Delay Relay:

Pump C (with normal power)

This function is performed by a Agastat ETR14D3DNM015 time delay relay. The timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3. 3. 5. 1. 5, l.e., CS Pump Start Time Delay Relay:

Pump D (with normal power)

This function is performed by a Agastat ETR14D3DNM015 time delay relay. The timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.5.1.5, 2.a., Reactor Vessel Water Level Low Low Low, Level 1 This function is performed by a Rosemount 1153DB5 Transmitter and GE MTU 184C5988 Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The GE Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the GE Trip Units with respect to drift.

SR 3.3.5.1.5, 2.b., Drywell Pressure High This function is performed by a Rosemount 1153GB4 Transmitter and 710DUOTT Trip Units. The transmitter II E1-22

and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more more frequently, and if necessary, recalibrated.

frequent testing requirements remain unchanged.

These Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.5.1.5, 2.e., Reactor Vessel Water Level-Level 0 This function is performed by a Rosemount 1153DD5 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the .setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.5.1.5, 2.f., LPCI Pump Start Time Delay Relay:

Pumps A, B, C, D (with diesel power)

This function is performed by a Agastat 7012SA time delay relay. The timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.5.1.5, 2.f., LPCI Pump Start Time Delay Relay:

Pump A (with normal power)

This function is performed by a Agastat ETR14D3ANM015 time delay relay. The timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for E1-23

this instrument does not exceed the drift .allowance provided in the setpoint calculation for this instrument.

SR 3.3.5.1.5, 2.f., LPCI Pump Start Time Delay Relay:

Pump B (with normal power)

This function is performed by a Agastat ETR14D3DNM015 time delay relay. The timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.5.1.5, 2.f., LPCI Pump Start Time Delay Relay:

Pump C (with normal power)

This function is performed by a Agastat ETR14D3DNM015 time delay relay. The timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.5.1.5, 2.f., LPCI Pump Start Time Delay Relay:

Pump D (with normal power)

This function is performed by a Agastat ETR14D3DNM015 time delay relay. The timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this ins trument-.--

SR 3.3.5.1.5, 3.a., Reactor Vessel Water Level-Low Low, Level 2 This function is performed by a Rosemount 1153DB5 Transmitter and GE MTU 184C5988 Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for El-24

the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The GE Trip Units are functionally checked and setpoint verified necessary, recalibrated.

more frequently, and if These more frequent testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the GE Trip Units with respect to drift.

SR 3.3.5.1.5, 3.b., Drywel'1 Pressure-High This function is performed by a Rosemount 1153GB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated.

more frequent testing requirements remain unchanged, These Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.5.1.5, 3.c., Reactor Vessel Water Level-High, Level 8 This function is performed by a Gould PD3200 Transmitter (Unit 2), Rosemount 1153DB4 Transmitter (Unit 3) and Rosemount 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in-the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and necessary, recalibrated. These more frequent testing if requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount'rip Units with respect to drift.

SR 3.3.5.1.5, 3.f., HPCI Pump Discharge Flow-Low (Bypass)

This function is performed by a ITT Barton 289A Switch.

The switch was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instruments does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.5.1.5, 4.a., Reactor Vessel Water Level-Low Low Low, Level 1 This function is performed by a Rosemount 1153DB5 Transmitter and GE MTU 184C5988 Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The GE Trip Units are functionally checked and setpoint verified more frequently, and necessary, recalibrated.

if These more frequent testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the GE Trip Units with respect to drift.

SR 3.3.5.1.5, 4.b., Drywell Pressure-High This function is performed by a Rosemount 1153GB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation. for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.5.1.5, 4.c., ADS Initiation Timer This function is performed by a Agastat ETR14D3GNM015 time delay relay upon implementation of the

0 modifications for 24 month fuel cycle. The new timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.5.1.5, 4.d., Reactor Vessel Water Level-Low, Level 3 (Confirmatory)

This function is performed by a Rosemount 1153DB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount,Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.5.1.5, 4.g., ADS High Drywell Pressure Bypass Timer This function is performed by a Agastat ETR14D3GNM015 time delay relay upon implementation of the modifications for 24 month fuel cycle. The new timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.5.1.5, S.a., Reactor Vessel Water Level-Low Low Low, Level 1 This function is performed by a Rosemount 1153DB5 Transmitter and GE MTU 184C5988 Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance

provided in the setpoint calculation for this instrument. The GE Trip Units are functionally checked and setpoint verified necessary, recalibrated.

more frequently, and if These more frequent testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the GE Trip Units with respect to drift.

SR 3.3.5.1.5, S.b., Drywell Pressure-High This function is performed by a Rosemount 1153GB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to, accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.5.1.5, 5.c., ADS Initiation Timer This function is performed by a Agastat ETR14D3GNM015 time delay relay upon implementation of the modifications for 24 month fuel cycle. The new timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.5.1;-5, S.d., Reactor Vessel Water Level-Low, Level 3 (Confirmatory)

This function is performed by a Rosemount 1153DB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip

. Units are functionally checked and setpoint verified

more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.5.1.5, 5.g., ADS High Drywell Pressure Bypass Timer This function is performed by a Agastat ETR14D3GNM015 time delay relay upon implementation of the modifications for 24 month fuel cycle. The new timer was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

ITS: 3.3.5.2 Reactor Core Isolation Cooling (RCIC)

System Instrumentation The impacted Reactor Core Isolation Cooling (RCIC)

System instrumentation has been evaluated based on make, manufacturer and model number to determine that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation.

The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, manufacturer and model number the drift evaluations performed.

SR 3.3.5.2.3, 1., Reactor Vessel Water Level-Low Low, Level 2 This function is performed by a Rosemount 1153DB5 Transmitter and GE MTU 184C5988 Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The GE Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the GE Trip Units with respect to drift.

SR 3.3.5.2.3, 2., Reactor Vessel Water Level-High, Level 8 This function is performed by a Gould PD3200 Transmitter (Unit 2), Rosemount 1153DB4 Transmitter (Unit 3) and Rosemount 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint necessary, recalibrated.

verified more frequently, and These more frequent testing if requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

ITS: 3.3.6.1 Primary Containment Isolation System Instrumentation The impacted Primary Containment Isolation System instrumentation has been evaluated based on make, manufacturer and model number to determine that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation. The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, manufacturer and model number the drift evaluations performed.

SR 3.3.6.1.5, 1.a., MSL Isol: Reactor Vessel Water Level-Low Low Low, Level 1 This function is performed by a Rosemount 1153DB5 Transmitter-and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Ro'semount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the E1-30

Rosemount Trip Units with respect to drift.

SR 3.3.6.1.5, 1.b., MSL Isol: MSL Pressure-Low This function is performed by a Rosemount 1153GB9 (Modified to Range Code 8) Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3 3 6 1 Sg

~ 1 ~ c ~ g MSL Isol: MSL Flow-High This function is performed by a Rosemount 1153DD7 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.6.1.5, 1.d., MSL Isol: Main Steam Tunnel Temperature-High This function is performed by a Fenwall 17002-40 or EGS 01-170020-090 Switch. The switch was evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the projected 30 month drift value for this 'instruments does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.6.1.5, 2.a., PC Isol: Reactor Vessel Water

0 Level-Low, Level 3 This function is performed by a Rosemount 1153DB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.6.1.5, 2.b., PC Isol: Drywell Pressure High This function is performed by a Rosemount 1153GB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.6.1.5, 3.a., HPCI Isol: HPCI Steam Line Flow-High This function is performed by a Rosemount 1153DD7 Transmitter-and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rasemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the

Rosemount Trip Units with respect to drift.

SR 3.3.6.1.5, 3.b., HPCI Isol: HPCI Steam Supply Line Pressure-Low This function is performed by a Static-0-Ring 5N6-B3-NX-C1A-JJTTX6 Switch. The switch was evaluated using.

the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instruments does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.6.1.5, 3.c., HPCI Isol: HPCI Turbine Exhaust Diaphragm Pressure-High This function is performed by a ASCO S21AMR/TE20A32R Switch. The switch was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instruments does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.6.1.5, 4.a., RCIC Isol: RCIC Steam Line Flow-High This function is performed by a Rosemount 1153DB5 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.6.1.5, 4.b., RCIC Isol: RCIC Steam Supply Line Pressure-Low This function is performed by a Static-0-Ring 6N6-B3-NX-C1A-JJTTX6 Switch on Unit 2 and a Static-0-Ring 6N6-B3-NX-C1A-JJTTX12 Switch on, Unit 3. The switches were

evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for these instruments do not exceed the drift allowance provided in the setpoint calculation for these instrument.

SR 3.3.6.1.5, 4.c., RCIC Isol: RCIC Turbine Exhaust Diaphragm Pressure-High This'unction is performed by a Barksdale P-1H-M85-SS Switch. The 'switch was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instruments does not exceed the drift allowance provided in the setpoint calculation for this'nstrument.

SR 3.3.6.1.5, S.h., RWCU Isol: Reactor Vessel Water Level-Low, Level 3 This function is performed by a Rosemount 1153DB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values, for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.6.1.5, 6.a., SDC Isol: Reactor Steam Dome Pressure-High This function is performed by a Static-0-Ring 6N6-B5-NX-C1A-JJTTX12 Switch. The switch was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift value for this instruments does not exceed the drift allowance provided in the setpoint calculation for this instrument.

E1-34

SR 3.3.6.1.5, 6.b., SDC Isol: Reactor Vessel Water Level-Low, Level 3 This function is performed by a Rosemount 1153DB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated.

more frequent testing requirements remain unchanged.

These Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.6.1.5, 6.c., SDC Isol: Drywell Pressure-High This function is performed by a Rosemount 1153GB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated.

more frequent testing requirements remain unchanged.

These Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.6.1.6, PC Isol: Logic System Functional Test.

This Logic System Functional Test (LSFT) includes a calibration--of Agastat time delay relays and timers necessary for proper functioning of the logic. The relays and timers were evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The effect of changing the LSFT interval to 24 months was addressed in the initial submittal, TS-390, which also provided the Tech Spec and Bases markups for this SR. Therefore, markups for this SR are not included in this supplemental submittal.

E1-35

ITS:3.3.6.2 Secondary Containment, System Isolation Instrumentation The impacted Secondary Containment System Isolation instrumentation has been evaluated based on make, manufacturer and model number to determine that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation. The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, manufacturer and model number the drift evaluations performed.

SR 3.3.6.2.3, 1., Reactor Vessel Water Level-Low, Level 3 This function is performed by a Rosemount 1153DB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.6.2.3, 2. Drywell Pressure-High This function is performed by a Rosemount 1153GB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The.results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

El-36

SR 3.3.6.2.3, 3. Reactor Zone Exhaust Radiation-High This function is performed by a GE 188C8941/

GE 304A3718G001 NUMAC Radiation Monitor. This monitor's stability was evaluated by the Vendor (GE).

The results of the evaluation indicated that the projected 30 month dri ft value for this instrument does not exceed the. drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.6.2.3, 4. Refueling. Floor Exhaust Radiation-High This function is performed by a GE 188C8941/GE 304A3718G001 NUMAC Radiation Monitor. This monitor's stability was evaluated by the Vendor (GE). The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

ITS: 3.3.7.1-Control Room Emergency Ventilation (CREV)

System Instrumentation The impacted Control Room Emergency Ventilation (CREV)

System instrumentation has been evaluated based on make, manufacturer and model number to determine that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation.

The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, manufacturer and model number the drift evaluations performed.

SR 3.3.7.1.5, 1. Reactor Vessel Water Level-Low, Level 3 This function is performed by a Rosemount 1153DB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the pro j ected 30 month drift values for the instruments do not exceed the drift, allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.7.1.5, 2., Drywell Pressure-High This function is performed by a Rosemount 1153GB4 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked arid setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

SR 3.3.7.1.5, 3., Reactor Zone Exhaust Radiation-High This function is performed by a GE 188C8941/GE 304A3718G001 NUMAC Radiation Monitor. This moni'tor's stability was evaluated by the Vendor (GE). The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

SR 3.3.7.1.5, 4. Refueling Floor Exhaust Radiation High This function is performed by a GE 188C8941/GE 304A3718G001 NUMAC Radiation Monitor. This monitor's stability was evaluated by the Vendor (GE). The results of the evaluation indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

ITS: 3. 4. 5-RCS Leakage Detection System Instrumentation The impacted RCS Leakage Detection System instrumentation has been evaluated based on make, manufacturer and model number to determi'ne that the instrumentation's actual drift falls within the assumed drift in the associated setpoint calculation. The following paragraphs, listed by Surveillance Requirement (SR) and Function identify by make, E1-38

manufacturer and model number the drift evaluations performed.

SR 3.4.5.4, Required leakage detection system instrumentation This function is performed by a Eberline SPING-3A Continuous Air Monitor (CAM). This monitor was evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation .indicated that the projected 30 month drift value for this instrument does not exceed the drift allowance provided in the setpoint calculation for this instrument.

ITS: 3.6.1.5-Reactor Bldg-to-Suppression Chamber Vacuum Breakers SR 3.6.1.5.3,-Reactor Bldg-to-Suppression Chamber Vacuum Breakers: open setpoint This function is performed by a Rosemount 1153DB3 Transmitter and 710DUOTT Trip Units. The transmitter and trip unit were evaluated using the methodology as described in Reference 3 against plant calibration data. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift.

ITS: 3.7.2-Emergency Equipment Cooling Water (EECW)

System and Ultimate Heat Sink (UHS)

SR 3.7.2.3,-EECW pump, Automatic Actuation This SR includes a functional'est and relay calibration of the EECW pump timers (both normal power and diesel power). The Agastat relays and timers were evaluated using the methodology as described in Reference 3. The results of the evaluation indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. The effect of changing the functional test interval to 24 E1-39

months was addressed in the initial submittal, TS-390, which also provided the Tech Spec and Bases markups for this SR. Therefore, markups for this SR are not included in this supplemental submittal.

C. Bases Chan es Section A above addresses those issues raised in Generic Letter 91-04 that involve specific changes to the TSs. The associated Bases changes follow directly from the proposed changes to the corresponding TS SR frequency and, therefore, require no additional clarification.

IV. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TVA has concluded that operation of Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3 in accordance with the proposed changes to the TSs does not involve a significant hazards consideration. TVA's conclusion is based on its evaluation, in accordance with 10 CFR 50.91(a)(1), of the three standards set forth in 10 CFR 50.92(c).

A. The ro osed amendment does not involve a si nificant increase in the robabilit or conse ences of an accident reviousl evaluated.

The proposed amendment changes the surveillance Frequency from 18 months to 24 months for SRs in the Units 2 and 3 TS that are normally a function of the refueling interval. In addition, the proposed amendment changes the surveillance Frequency from 18 months to 24 months for those SRs in the Unit 1 TS that control the test interval for components and systems that are common to Units 1, 2, and 3. Under certain circumstances SR 3.0.2 would allow a maximum surveillance interval of 30 months for these SRs. The evaluations in Section III have shown that the reliability of protective instrumentation will be preserved for the maximum allowable surveillance interval. The proposed changes do not involve any change to the design or functional requirements of plant systems, and the surveillance test methods will be unchanged. The proposed changes will not give rise to any increase in operating power level', fuel operating limits, or effluents. In addition, the proposed changes will not significantly increase any radiation levels. Based on the foregoing considerations and the evaluations completed in E1-40

accordance with the guidance of Generic Letter 91-04, it is concluded that the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

B. The ro osed amendment does not create the ossibilit of a new or different kind of accident from an accident reviousl evaluated.

The proposed amendment requires no change to the plant design or the mode of operation, for any item of equipment. The proposed changes do not create the possibility of any new failure mechanisms. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

C. The ro osed amendment does not involve a si nificant reduction in a mar in of safet The proposed amendment seeks to change instrument calibration surveillance intervals from 18 to 24 months. The primary consideration relative to safety margin is that of exceeding analytical limits for the current safety analyses as a result of increased instrument drift over the extended surveillance interval. The drift studies discussed in Section III.A have shown that the existing setpoints and TS allowable values can be retained without challenging the current analytical limits; thereby preserving the assumptions in the current safety analyses and ensuring that safety limits will not be exceeded.

To confirm that the drift errors remain within projected values, instruments subjected to the longer interval between calibrations will continue to be monitored as required by current plant procedures.

This practice will assure that no significant reduction in safety margin is incurred by adoption of the proposed amendment.

Therefore, it is concluded that the proposed amendment does not involve a significant reduction in a margin of safety.

ENVIRONMENTAL IMPACT CONSIDERATION The proposed change does not involve a significant hazards consideration, a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, or a significant increase in individual or cumulative occupational radiation exposure.

Therefore, the proposed change meets the eligibility

criteria for categorical exclusion set forth in 10 CFR 51.22(c) (9) . Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.

E1-42

VI . REFERENCES

1. TVA letter to NRC dated June 12, 1998, in regards to Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3 Technical Specification (TS) Change TS-390 Request For License Amendment to Support 24-Month Fuel Cycles.
2. NRC Generic Letter 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle (Generic Letter 91-04)," April 2, 1991.
3. EEB-TI-28, "Setpoint Calculations," Branch Technical Instruction, Revision 2, Tennessee Valley Authority, October 6, 1992.
4. TVA letter to NRC dated October 1, 1997, in regards to Browns Ferry Nuclear Plant (BFN) Units 2 and 3 Technical Specification (TS) Change TS-384 Request For License Amendment For Power Uprate Operation.
5. NRC Regulatory Guide 1.105, "Instrument Setpoints for Safety-Related Systems," Revision 2, February 1986
6. NRC letter to TVA dated May 8, 1989, in regards to. Notice of Violation (NRC Inspection Report Nos. 50-259/89-06, 50-260/89-06, and 50-296/89-06).

El-43

Table 1 Instrument Calibration Surveillances

+ Unit1 Surveillance Re uirements that su ort Units 2 and 3 o eration Surveillance Item Function System SR 3.3.1.1.13 2.a. APRM Neutron Flux - High, Setdown RPS SR 3.3.1.1.13 2.b. APRM Flow Biased Simulated Thermal Power - High RPS SR 3.3.1.1.13 2.c. APRM Neutron Flux - High RPS SR 3.3.1.1.13 Reactor Vessel Water Level - Low, Level 3 RPS SR 3.3.1.1.13 MSIV - Closure RPS SR 3.3.1.1.13 Drywell Pressure - High RPS SR 3.3.1.1.13 7.a. SDV Water Level - High, RTD RPS SR 3.3.1.1.13 7.b. SDV Water Level - High, Float Switch RPS SR 3.3.1.1.13 Turbine Stop Valve - Closure RPS SR 3.3.1.1.13 TCV Fast Closure, Trip Oil Pressure - Low RPS SR 3.3.1.1.13 13. Low Scram Pilot Air Header Pressure RPS SR 3.3.1.1.15 Turbine Stop Valve Closure Bypass Function RPS SR 3.3.1.1.15 TCV Fast Closure, Trip Oil Pressure - Low Bypass Function RPS SR 3.3.2.1.4 1.a. Rod Block Monitor Low Power Range Upscale Control Rod Block SR 3.3.2.1.4 1.b. Rod Block Monitor Intermed. Power Range Upscale Control Rod Block SR'3.3.2.1.4 1.c. Rod Block Monitor High Power Range Upscale Control Rod Block SR 3.3.2.1.4 SR 3.3.2.1.5 1.e.

2. R dW rthM' '0/

Rod Block Monitor Downscale RTPB F ct'ontrol C t Rod Block IR dBI k SR 3.3.2.1.8 1.a. Rod Block Monitor Low Power Range Upscale (Bypass) Control Rod Block SR 3.3.2.1.8 1.b. Rod Block Monitor Intermed. Power Range Upscale (Bypass) Control Rod Block SR 3.3.2.1.8 1.c. Rod Block Monitor High Power Range Upscale (Bypass) Control Rod Block SR 3.3.2.2.3 FW and Main Turbine High Water Level Trip FW & Main Turbine SR 3.3.3.1.4 2.a. Reactor Vessel Water Level - Emergency Systems Range PAM SR 3.3.3.1.4 2.b. Reactor Vessel Water Level - Post Accident Flood Range PAM SR 3.3.3.1.4 Suppression Pool Water Level PAM SR 3.3.3.1.4 4.a. Drywell Pressure - Normal Range PAM SR 3.3.3.1.4 4.b. Drywell Pressure - Wide Range PAM SR 3.3.3.1.4 Primary Containment Area Radiation PAM SR 3.3.3.1.4 PCIV Position PAM SR 3.3.3.1.4 Suppression Pool Water Temperature PAM SR 3.3.3.1.4 Drywell Atmosphere Temperature PAM SR 3.3.3.2.2 Suppression Pool Water Level Backup Control Sys (Unit 3 only)

El-44

Table 1 (continued)

Instrument Calibration Surveillances

+ Unit1 Surveillance Re uirementsthatsu ort Units 2 and 3o eration Surveillance Item Function System SR 3.3.3.2.3 Each required inst. channel except Supp. Pool Water Level Backup Control Sys (see Bases, Table B 3.3.3.2-1)

1. Reactor Water Level Indication
2. Reactor Pressure Indication
3. Suppression Pool Temperature indication
4. Suppression Pool Level Indication (see SR 3.3.3.2.2)
5. Drywell Pressure Indication
6. RHR Flow indication
7. RCIC Flow Indication
8. RCIC Turbine Speed Indication
9. Drywell Temperature Indication (Unit 2 only)
10. RHRSW Header Pressure SR 3.3.4.1.2 Turbine Stop Valve and TCV Closure Bypass Function EOC-RPT (covered by SR 3.3.1.1.15, items 8 8 9 above)

SR 3.3.4.1.3 Turbine Stop Valve - Closure (RPS item 8 Inst.) EOC-RPT SR 3.3.4.1.3 TCV Fast Closure, Trip Oil Press. - Low (RPS item 9 Inst.) EOC-RPT SR 3.3.4.2.3 a. Reactor Vessel Water Level - Low Low, Level 2 ATWS-RPT SR 3.3.4.2.3 Reactor Steam Dome Pressure - High ATWS-RPT SR 3.3.5.1.5 1.a. Reactor Vessel Water Level - Low Low Low, Level 1 ECCS: Core Spray SR 3.3.5.1.5 1.b. Drywell Pressure - High ECCS: Core Spray SR 3.3.5.1.5 1.d. CS Pump Discharge Flow - Low (Bypass) ECCS: Core Spray SR 3.3.5.1.5 1.e. CS Pump Start Time Delay Relay: ECCS: Core Spray

- Pumps A, B, C, D (with diesel power)

SR 3.3.5.1.5 1.e. - Pump A (with normal power) ECCS: Core Spray SR 3.3.5.1.5 1.e. - Pump B (with normal power) ECCS: Core Spray SR 3.3.5.1.5 1.e. - Pump C (with normal power) ECCS: Core Spray SR 3.3.5.1.5 1.e. - Pump D (with normal power) ECCS: Core Spray SR 3.3.5.1.5 2.a. Reactor Vessel Water Level - Low Low Low, Level 1 ECCS: LPCI SR 3.3.5.1.5 2.b. Drywell Pressure - High ECCS: LPCI SR 3.3.5.1.5 2.e. Reactor Vessel Water Level - Level 0 ECCS: LPCI SR 3.3.5.1.5 2.f. LPCI Pump Start Time Delay Relay: ECCS: LPCI

- Pumps A, B, C, D (with diesel power)

SR 3.3.5.1.5 2.f - Pump A (with normal power) ECCS: LPCI SR 3.3.5.1.5 2.f. - Pump B (with normal power) ECCS: LPCI SR 3.3.5.1.5 2.f - Pump C (with normal power) ECCS: LPCI SR 3.3.5.1.5 2.f. - Pump D (with normal power) ECCS: LPCI SR 3.3.5.1.5 3.a. Reactor Vessel Water Level - Low Low, Level 2 ECCS: HPCI SR 3.3.5.1.5 3.b. Drywell Pressure - High ECCS: HPCI SR 3.3.5.1.5 3.c. Reactor Vessel Water Level - High, Level 8 ECCS: HPCI SR 3.3.5.1.5 3.f. HPCI Pump Discharge Flow - Low (Bypass) ECCS: HPCI El-45

Table 1 (continued)

Instrument Calibration Surveillances

+ Unit 1 Surveillance Re uirements that su ort Units 2 and 3 o eration Surveillance Item Function System SR 3.3.5.1.5 4.a. Reactor Vessel Water Level - Low Low Low, Level 1 ECCS: ADS-A SR 3.3.5.1.5 4.b. Drywell Pressure - High ECCS: ADS-A SR 3.3.5.1.5 4.c. ADS Initiation Timer ECCS: ADS-A SR 3.3.5.1.5 4.d. Reactor Vessel Water Level - Low, Level 3 (Confirmatory) ECCS: ADS-A SR 3.3.5.1.5 4.g. ADS High Drywell Pressure Bypass Timer ECCS: ADS-A SR 3.3.5.1.5 5.a. Reactor Vessel Water Level - Low Low Low, Level 1 ECCS: ADS-B SR 3.3.5.1.5 5.b. Dfywell Pressure - High ECCS: ADS-B SR 3.3.5.1.5 5.c. ADS Initiation Timer ECCS: ADS-B SR 3.3.5.1.5 5.d. Reactor Vessel Water Level - Low, Level 3 (Confirmatory) ECCS: ADS-B SR 3.3.5.1.5 5.g. ADS High Dfyweil Pressure Bypass Timer ECCS: ADS-B SR 3.3.5.2.3 1. Reactor Vessel Water Level - Low Low, Level 2 RCIC SR 3.3.5.2.3 2. Reactor Vessel Water Level - High, Level 8 RCIC SR 3.3.6.1.5 1.a. MSL Isol: Reactor Vessel Water Level - Low Low Low, Level 1 Primary Containment SR 3.3.6.1.5 1.b. MSL Isol: MSL Pressure - Low Primary Containment SR 3.3.6.1.5 1.c. MSL Isol: MSL Flow - High Primary Containment SR 3.3.6.1.5 1.d. MSL Isol: Main Steam Tunnel Temperature - High Primary Containment 1.5 2.. PCI I.R ct V Iwt L I L,L I3 P' SR 3.3.6.1.5 2.b. PC Isol: Dfywell Pressure - High Primary Containment SR 3.3.6.1.5 3.a. HPCI Isol: HPCI Steam Line Flow - High Primary Containment SR 3.3.6.1.5 3.b. HPCI Isol: HPCI Steam Supply Line Pressure - Low Primary Containment SR 3.3.6.1.5 3.c. HPCI Isol: HPCI Turbine Exhaust Diaphragm Pressure - High Primary Containment SR3.3.6.1.5 4.a. RCIC Isol: RCICSteamLine Flow-High Primary Containment SR 3.3.6.1.5 4.b. RCIC Isol: RCIC Steam Supply Line Pressure - Low Primary Containment SR 3.3.6.1.5 4.c. RCIC Isol: RCIC Turbine Exhaust Diaphragm Pressure - High Primary Containment SR 3.3.6.1.5 5.h. RWCU Isol: Reactor Vessel Water Level - Low, Level 3 Primary Containment SR 3.3.6.1.5 G.a. SDC Isol: Reactor Steam Dome Pressure - High Primary Containment SR 3.3.6.1.5 G.b. SDC Isol: Reactor Vessel Water Level - Low, Level 3 Primary Containment SR 3.3.6.1.5 6.c. SDC Isol: Drywell Pressure - High Primary Containment SR 3.3.6.1.6 PC Isol: Logic System Functional Test. Primary Containment Note: This Logic System Functional Test (LSFT) includes a calibration of time delay relays and timers necessary for proper functioning of the logic. The effect of changing the LSFT interval to 24 months was addressed in the initial submittal, TS-390, which also provided the Tech Spec and Bases markups for this SR.

Therefore, markups for this SR are not included in this supplemental submittal SR 3.3.6.2.3 1. Reactor Vessel Water Level - Low, Level 3 Second. Containment SR 3.3.6.2.3 2. Dfywell Pressure - High Second. Containment SR3362.3 3. Reactor Zone Exhaust Radiation - High Second. Containment SR 3.3.6.2.3 4. Refueling Floor Exhaust Radiation - High Second. Containment El-46

Table 1 (continued)

Instrument Calibration Surveillances

+ Unit 1 Surveillance Re uirements that su ort Units 2 and 3 o eration Surveillance Item Function System SR 3.3.7.1.5 Reactor Vessel Water Level - Low, Level 3 CREV SR 3.3.7.1.5 Drywell Pressure - High CREV SR 3.3.7.1.5 Reactor Zone Exhaust-Radiation - High CREV SR 3.3.7.1.5 Refueling Floor Exhaust Radiation - High CREV SR 3.4.5.4 Required leakage detection system instrumentation RCS Leak Detection SR 3.6.1.5.3 Reactor Bldg-to-Suppression Chamber Vacuum Breakers: open Primary Containment setpoint SR 3.7.2.3+ EECW pump, Automatic Actuation EECW and UHS Note: This SR includes a functional test and relay calibration of the EEGW pump timers (both normal power and diesel power). The effect of changing the functional test interval to 24 months was addressed ln the initial submittal, TS490, which also provided the Tech Spec and Bases markups for this SR. Therefore, markups for this SR are not included in this supplemental submittal.

El-47

AL (upper)

Region of unmeasurable uncertainties Av (max)

Av Band Av (min)

Region of normal Setpoint (SP) measurable uncertainties Av (min)

Av Band Av (max)

Region of unmeasurable uncertainties AL (lower)

Figure 1. Instrument Value Relationships E1-48