Text

SR 3.3.6.1.5

≥ 177 107 inches

f. Drywell Pressure — High 1,2,3 2 F SR 3.3.6.1.1

SR 3.3.6.1.2

SR 3.3.6.1.5

≤ 2.7 psig

6. Shutdown Cooling System Isolation

a. Reactor Pressure — High

1,2,3

1

F

SR 3.3.6.1.1

SR 3.3.6.1.2

SR 3.3.6.1.5

≤ 74 psig

b. Reactor Vessel Water Level —

Low (Level 3)

3

2

J

SR 3.3.6.1.1

SR 3.3.6.1.2

SR 3.3.6.1.5

≥ 177 inches

(continued)

(d) SLC System Initiation only inputs into one of the two trip systems and only isolates one valve in the RWCU suction and return line.

ATTACHMENT 3

License Amendment Request

James A. FitzPatrick Nuclear Power Plant

Docket No. 50-333

Proposed Change to the Technical Specifications Allowable Value for Reactor Water

Cleanup (RWCU) System Primary Containment Isolation

Proposed Technical Specification Bases Marked-Up Page

(for information only)

Bases Page

B 3.3.5.2-5

B 3.3.6.1-4

B 3.3.6.1-18

B 3.3.6.1-19

RPV Water Inventory Control Instrumentation

B 3.3.5.2

BASES

APPLICABLE

SAFETY ANALYSIS,

LCO, and

APPLICABILITY

3.a - Reactor Vessel Water Level - Low, Level 3 (continued)

Instrumentation Reactor Vessel Water Level - Low, Level 3 Allowable

Value (LCO 3.3.6.1), since the capability to cool the fuel may be

threatened.

The Reactor Vessel Water Level - Low, Level 3 Function is only

required to be OPERABLE when automatic isolation of the associated

penetration flow path is credited in calculating DRAIN TIME. This

Function isolates the Group 11 valves.

Reactor Water Cleanup (RWCU) System Isolation

4.a - Reactor Vessel Water level -– Low Low, Level 32

The definition of Drain Time allows crediting the closing of penetration

flow paths that are capable of being isolated by valves that will close

automatically without offsite power prior to the RPV water level being

equal to the TAF when actuated by RPV water level isolation

instrumentation. The Reactor Vessel Water Level – Low Low (Level 32)

Function associated with RWCU System isolation may be credited for

automatic isolation of penetration flow paths associated with the

RWCU System.

Reactor Vessel Water Level -– Low Low, (Level 32) signals are

initiated from four level transmitters that sense the difference

between the pressure due to a constant column of water (reference

leg) and the pressure due to the actual water level (variable leg) in

the vessel.

While four channels (two channels per trip system) of the Reactor

Vessel Water Level – Low (Level 3) Function are available, only two

channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low (Level 3) Allowable Value was

chosen to be the same as the RPS Reactor Vessel Water Level – Low

Low (Level 32) Allowable Value (LCO 3.3.1.1), since the capability to

cool the fuel may be threatened. The allowable value is referenced

from a level of water 352.56 inches above ther lowest point in the

inside bottom of the RPV and also corresponds to the top of a 144

inch fuel column (Ref 6).

The Reactor Vessel Water Level – Low Low (Level 23) Function is only

required to be OPERABLE when automatic isolation of the associated

penetration flow path is credited in calculating DRAIN TIME. This

Function isolates the Group 5 valves.

(continued)

JAFNPP B 3.3.5.2-5 Revision 38

Primary Containment Isolation Instrumentation

B 3.3.6.1

BASES

BACKGROUND

3, 4. High Pressure Coolant Injection System Isolation and Reactor

Core Isolation Cooling System Isolation (continued)

two-out-of-two trip systems. The output of each equipment area

temperature channel is connected to one trip system so that any

channel will trip its associated trip system. This arrangement is

consistent with all other area temperature Functions, in that any

channel will trip its associated trip system.

5.Reactor Water Cleanup System Isolation

The Reactor Vessel Water Level — Low Low (Level 32) and Drywell

Pressure

— High Isolation Functions (Functions 5.e and 5.f) receive input from

four channels. The outputs from these channels are connected into

two two-out-of-two trip systems for each function. The SLC System

Initiation Function (Function 5.d) receives input from two channels,

with both channels providing input to one trip system. Any channel will

initiate the trip logic. The Function is initiated by placing the SLC

System initiation switch in any position other than stop (start system A

or start system B). Therefore, a channel is defined as the circuitry

required to trip the trip logic when the switch is in position start system

A or start system B. The Area Temperature — High Functions

(Functions 5.a, 5.b and 5.c) receive input from eight temperature

monitors, four to each trip system. These are configured so that any

one input will trip the associated trip system. Each of the two trip

systems is connected to one of the two valves on the RWCU suction

penetration and only one trip system is connected to the RWCU return

penetration outboard valve. The trip system associated with the SLC

System Initiation Function is connected to the outboard RWCU suction

valve and the outboard RWCU return penetration valve.

6.Shutdown Cooling System Isolation

The Reactor Vessel Water Level — Low (Level 3) Function (Function

6.b) receives input from four reactor vessel water level channels. The

outputs from the reactor vessel water level channels are connected to

two two-out-of-two trip systems. Each of the two trip systems is

connected to one of the two valves on the RHR shutdown cooling

pump suction penetration and on one of the two inboard LPCI

injection valves if in shutdown cooling mode. The Reactor Pressure —

High Function (Function 6.a) receives input from two channels, with

each channel providing input into each trip system using a

one-out-of-two logic. However, only one channel input is required to be

OPERABLE for a trip system to be considered OPERABLE. Each of the

two trip systems is connected to one of the two valves on the

shutdown cooling pump suction penetration.

(continued)

JAFNPP B 3.3.6.1-4 Revision 38

Primary Containment Isolation Instrumentation

B 3.3.6.1

BASES

APPLICABLE

SAFETY ANALYSIS,

LCO, and

APPLICABILITY

(continued)

5.d. SLC System Initiation

The isolation of the RWCU System is required when the SLC System

has been initiated to prevent dilution and removal of the boron

solution by the RWCU System (Ref. 6). The RWCU isolation signal is

initiated when the control room SLC initiation switch is in any position

other than stop.

There is no Allowable Value associated with this Function since the

channels are mechanically actuated based solely on the position of

the SLC System initiation switch.

Two channels (start system A or start system B) of the SLC System

Initiation Function are available and are required to be OPERABLE

only in MODES 1 and 2, since these are the only MODES where the

reactor can be critical, and these MODES are consistent with the

Applicability for the SLC System (LCO 3.1.7).

As noted (footnote (d) to Table 3.3.6.1-1), this Function is only

required to close one of the RWCU suction isolation valves and one

return isolation valve since the signals only provide input into one of

the two trip systems.

5.e. Reactor Vessel Water Level — Low Low (Level 32)

Low RPV water level indicates that the capability to cool the fuel may

be threatened. Should RPV water level decrease too far, fuel damage

could result. Therefore, isolation of some interfaces with the reactor

vessel occurs to isolate the potential sources of a break. The isolation

of the RWCU System on Level 32 supports actions to ensure that the

fuel peak cladding temperature remains below the limits of

10 CFR 50.46. The Reactor Vessel Water Level — Low Low (Level 32)

Function associated with RWCU isolation is not directly assumed in

the UFSAR safety analyses because the RWCU System line break is

bounded by breaks of larger systems (recirculation and MSL breaks

are more limiting).

Reactor Vessel Water Level — Low Low (Level 32) signals are initiated

from four level transmitters that sense the difference between the

pressure due to a constant column of water (reference leg) and the

pressure due to the actual water level (variable leg) in the vessel.

Four channels of Reactor Vessel Water Level — Low Low (Level 32)

Function are available and are required to be OPERABLE to ensure

that no single instrument failure can preclude the isolation function.

The Reactor Vessel Water Level — Low Low (Level 32) Allowable Value

was chosen to be the same as the RPS Reactor Vessel Water Level —

Low Low (Level 2)

(continued)

JAFNPP B 3.3.6.1-18 Revision 38

Primary Containment Isolation Instrumentation

B 3.3.6.1

BASES

APPLICABLE

SAFETY ANALYSIS,

LCO, and

APPLICABILITY

5.e. Reactor Vessel Water Level — Low (Level 3) (continued)

(Level 3) Allowable Value (LCO 3.3.1.1), since the capability to cool

the fuel may be threatened. The Allowable Value is referenced from a

level of water 352.56 inches above the lowest point in the inside

bottom of the RPV and also corresponds to the top of a 144 inch fuel

column (Ref. 13).

This Function isolates both RWCU suction valves and the RWCU

return valve.

5.f. Drywell Pressure — High

High drywell pressure can indicate a break in the RCPB inside the

primary containment. The isolation of some of the primary

containment isolation valves on high drywell pressure supports

actions to ensure that offsite dose limits of 10 CFR 100 are not

exceeded. The Drywell Pressure — High Function, associated with

isolation of the primary containment, is implicitly assumed in the

UFSAR accident analysis as these leakage paths are assumed to be

isolated post LOCA.

High drywell pressure signals are initiated from pressure transmitters

that sense the pressure in the drywell. Four channels of Drywell

Pressure — High are available and are required to be OPERABLE to

ensure that no single instrument failure can preclude the isolation

function.

The Allowable value was selected to be as low as possible without

inducing spurious trips. The Allowable Value is chosen to be the same

as the RPS Drywell Pressure — High Allowable Value (LCO 3.3.1.1),

since this may be indicative of a LOCA inside primary containment.

This Function isolates both RWCU suction valves and one RWCU

return valve.

6.a. Reactor Pressure — High

The Reactor Pressure — High Function is provided to isolate the

shutdown cooling portion of the Residual Heat Removal (RHR)

System. This interlock Function is provided only for equipment

protection to prevent an intersystem LOCA scenario, and credit for the

interlock is not assumed in the accident or transient analysis in the

UFSAR.

The Reactor Pressure — High signals are initiated from two

transmitters that are connected to different condensing chambers.

(continued)

JAFNPP B 3.3.6.1-19 Revision 38

ATTACHMENT 4

License Amendment Request

James A. FitzPatrick Nuclear Power Plant

Docket No. 50-333

Proposed Change to the Technical Specifications Allowable Value for Reactor Water

Cleanup (RWCU) System Primary Containment Isolation

Technical Specification Bases Pages Summarizing Setpoint Methodology

(for information only)

RPV Water Inventory Control Instrumentation

83.3.5.2

B 3.3 INSTRUMENTATION

B 3.3.5.2 Reactor Pressure Vessel (RPV) Water lnventary Control Instrumentation

BASES

BACKGROUND

The RPV contains penetrations below the top of the active fuel (TAF)

that have the potential to drain the reactor coolant inventory to below

the TAF. If the water level should drop below the TAF, the ability to

remove decay heat is reduced, which could lead to elevated cladding

temperatures and clad perforation. Safety Limit 2.1.1.3 requires the

RPV water level to be above the top of the active irradiated fuel at all

times to prevent such elevated cladding temperatures.

Technical Specifications are required by 10 CFR 50.36 to include

limiting safety system settings (LSSS) for variables that have

significant safety functions. LSSS are defined by the regulation as

•where a LSSS is specified for a variable on which a safety limit has

been placed, the setting must be chosen so that automatic protective

actions will correct the abnormal situation before a Safety Limit (SL)

is exceeded.• The Analytical Limit is the limit of the process variable

at which a safety action is initiated to ensure that a SL is not

exceeded. Any automatic protection action that occurs on reaching

the Analytical Limit therefore ensures that the SL is not exceeded.

However, in practice, the actual settings for automatic protection

channels must be chosen to be more conservative than the Analytical

Limit to account for instrument loop uncertainties related to the

setting at which the automatic protective action would actually occur.

The actual settings for the automatic isolation channels are the same

as those established for the same functions in MODES 1, 2, and 3 in

LCO 3.3.5.1, "Emergency Core Cooling System (ECCS)

Instrumentation.a or LCO 3.3.6.1, ff Primary Containment Isolation

instrumentation".

With the unit in MODE 4 or 5, RPV water inventory control is not

required to mitigate any events or accidents evaluated in the safety

analyses. RPV water inventory control is required in MODES 4 and 5

to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent

the release of radioactive material should a draining event occur.

Under the definition of DRAIN TIME, some penetration flow paths may

be excluded from the DRAIN TIME calculation if they will be isolated

by valves that will close automatically without offsite power prior to

the RPV water level being equal to the TAF when actuated by RPV

water level isolation instrumentation.

(continued)

83.3.5.2-1 Revision 38

BASES

BACKGROUND

(continued)

APPLICABLE

SAFETY ANALYSIS,

LCO,and

APPLICABILITY

RPV Water Inventory Control Instrumentation

B3.3.5.2

The purpose of the RPV Water Inventory Control Instrumentation is to

support the requirements of LCO 3.5.2, "Reactor Pressure Vessel

(RPV) Water Inventory Control," and the definition of DRAIN TIME.

There are functions that are required for manual initiation or

operation of the ECCS injection/spray subsystem required to be

OPERABLE by LCO 3.5.2 and other functions that support automatic

isolation of Residual Heat Removal subsystem and Reactor Water

Cleanup system penetration flow path(s) on low RPV water level.

The RPV Water Inventory Control Instrumentation supports operation

of core spray (CS) and low pressure coolant injection (LPCI). The

equipment involved with each of these systems is described in the

Bases for LCO 3.5.2.

With the unit in MODE 4 or 5, RPV water inventory control is not

required to mitigate any events or accidents evaluated in the safety

analyses. RPV, LCO, water inventory control is required in MODES 4

and 5 to protect and Safety Limit 2.1.1.3 and the fuel cladding barrier

to prevent the release of radioactive material should a draining event

occur.

A double-ended guillotine break of the Reactor Coolant System (RCS)

is not postulated in MODES 4 and 5 due to the reduced RCS

pressure, reduced piping stresses, and ductile piping systems.

Instead, an event is postulated in which a single operator error or

initiating event allows draining of the RPV water inventory through a

single penetration flow path with the highest flow rate, or the sum of

the drain rates through multiple penetration flow paths susceptible to

a common mode failure (e.g., seismic event, loss of normal power,

single human error). It is assumed, based on engineering judgment,

that while in MODES 4 and 5, one low pressure ECCS injection/spray

subsystem can be manually initiated to maintain adequate reactor

vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience

has shown RPV water inventory to be significant to public health and

safety. Therefore, RPV Water Inventory Control satisfies Criterion 4 of

10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as

nominal values without regard to measurement accuracy.

(continued)

B3.3.5.2-2 Revision 38

BASES

BACKGROUND

(continued)

APPLICABLE

SAFETY ANALYSIS,

LCO, and

APPLICABI LllY

Primary Containment Isolation Instrumentation

B3.3.6.1

7. Traversing lncore Probe System Isolation

The Reactor Vessel Water Level - Low (Level 3) Isolation Function

receives input from two reactor vessel water level channels. The

outputs from the reactor vessel water level channels are connected

into one two-out-of-two logic trip system. The Drywell Pressure- High

Isolation function receives input from two drywell pressure channels.

The outputs from the drywell pressure channels are connected into

one two-out-of-two logic trip system.

When either Isolation Function actuates, the TIP drive mechanisms

will withdraw the TIPs, if inserted, and close the inboard TIP system

isolation ball valves when the TIPs are fully withdrawn. The outboard

TIP system isolation valves are manual shear valves.

The isolation signals generated by the primary containment isolation

instrumentation are implicitly assumed in the safety analyses of

References 2 and 3 to initiate closure of valves to limit offsite doses.

Refer to LCO 3.6.1.3, "Primary Containment Isolation Valves (PCIVs),"

Applicable Safety Analyses Bases for more detail of the safety

analyses.

Primary containment isolation instrumentation satisfies Criterion 3 of

10 CFR 50.36(c)(2)(ii) (Ref. 4). Certain instrumentation Functions are

retained for other reasons and are described below in the individual

Functions discussion.

The OPERABILllY of the primary containment instrumentation is

dependent on the OPERABILllY of the individual instrumentation

channel Functions specified in Table 3.3.6.1-1. Each Function must

have a required number of OPERABLE channels, with their setpoints

within the specified Allowable Values, where appropriate. A channel is

inoperable if its actual trip setpoint is not within its required Allowable

Value. The actual setpoint is calibrated consistent with applicable

setpoint methodology assumptions. Each channel must also respond

within its assumed response time, where appropriate.

Allowable Values are specified for each Primary Containment Isolation

Function specified in the Table. Nominal trip setpoints are specified in

the setpoint calculations. The nominal setpoints are selected to

ensure that the setpoints do not exceed the Allowable Value between

CHANNEL CALIBRATIONS. Operation with a trip setpoint less

conservative than the nominal trip setpoint, but within its Allowable

Value, is acceptable. Trip setpoints are those predetermined values of

output at which an action should take place. The setpoints are

(continued)

B3.3.6.1-5 Revision 38

BASES

APPLICABLE

SAFETY ANALYSIS,

LCO,and

AP PU CAB I LITY

(continued)