ML20024B689

Proposed Tech Specs Re Scram Discharge Vol Sys Mods

ML20024B689
Person / Time
Site:	FitzPatrick
Issue date:	07/07/1983
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
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ML20024B685	List: ML20024B684 ML20024B687 ML20024B689
References
NUDOCS 8307110233
Download: ML20024B689 (33)

Text

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. n APPACHMENT I PROPOSED TECHNICAL SPECIFICAfION CHANGES RELATED TO SCRAM DISCHARGE VOLUME SYSTEM MODIFICATIONS i .

l New York Poder Autnority James A. FitzPatricK Nuclear Poder Plant Docket No. 50-333 June 1983 8307110233 830707 PDR ADDCK 05000333 P PDR

JRFNPP t

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3.1 BASES The reactor protection system automatically initiates The outputs of the uubchannels are combined a reactor scram to: in a 1 out of 2 logic; i.e., an input signal on either one or both of the subchannels will cause

1. Preserve the integrity of the fuel cladding. a trip system' trip. The outFats of the trip systems are arranged so thss a trip on both

2. Preserve the integrity of the Reactor Coolant systems is required to prodaca e reactor scram.

System.

This system meets the intent of IEEE-279 (1971)

3. Minimize the energy which must be absorbed for Nuclear Power Plant Protection Systems. The following a loss of coolant accident, and system has a reliability greater than that of a prevent inadvertent criticality. 2 out of 3 system and somewhat less than that of a 1 out of 2 system.

This specification provides the limiting conditions for operation necessary to preserve the ability With the exception of the average power range of the system to perform its intended function monitor (APRM) channel the intermediate range even during periods when instrument channels may monitor (IRM) channels, the scram discharge volume, l be out of service because of maintenance. When the main steam isolation valve closure and the necessary, one channel may be made inoperable for turbine stop valve closure, each subchannel has brief intervals to conduct required functional -

one instrument channel. When the minimum tests and calibrations. condition for operation on the number of operable instrument qhannels per untripped protection The Reactor Protection System is of the dual channel trip system is met or if it cannot be met and the type (Reference subsection 7.2 FSAR) . The System affected protection trip system is placed in a is made up of two independent trip systems, each tripped condition, the effectiveness of the having two subchannels of tripping devices.Each protection system is preserved.

subchannel has an input from at least one instrument channel which monitors a critical parameter. Three APRM instrument channels are provided for each protection trip system. APRM's A and E operate contacts in one subchannel and APRM's C and E operate contacts in the other s'

Amendment No. ,

32

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JAFNPP i

3.1 BASES (cont'd)

I

.is discharged from the reactor by a scram can Thus, the IRM and APRM are required in the refuel and  ;

be accommodated-in the discharge piping. Each startup/ hot standby modes. In the power range scram discharge instrument volume accommodates the APRM System provides required protection in excess of 34 gallons of water and is the low (reference paragraph 7.5.7 FSAR) . Thus the IRM point in the piping. No credit was taken for this System is not required in the run mode. The APRM's volume in the design of the discharge piping as cover only the power range. The IRM's and APRM's c9ry; erns the. amount of water which must be accomodated provide adequate coverage in the startup and during a scram. intermediate range.

i i During normal operation the discharge volume 'The high reactor pressure, high drywell pressure,

! is empty; however, should it fill with water, reactor low water. level and scram discharge volume the water discharged to the piping from the high level scrams are required for startup and run

{

i reactor could not be accommodated, which would modes of plant operation. They are, therefore, result in slow scram times or partial control rod required to be operational for these modes of ,

[

! insertion. To preclude this occurrence, level reactor operation.

detection instruments have been provided in each .

! instrument volume which alarm and scram the reactor The requirement to have the scram functions

- when the volume of water reaches 34.5 gallons. indicated'in Table 3.1-1 operable in the refuel j

j As indicated above, there is sufficient volume in mode assures that shifting to the refuel mode b the piping to accommodate the scram without during reactor power operation does not diminish

' impairment of the scram times or amount of insertion the protection provided by the Reactor Protection of the control rods. This function shuts the reactor System.

down while sufficient volume remains to accomodate i the discharged water and precludes the situation Turbine stop valve closure occurs at 10 percent i

in which a scram would be required but not be able of valve closure. Bel'w o 217 psig turbine first to perform its function adequately. stage pressure (30 percent of rated) , the scram i signal due to turbine stop valve closure is l A Source Range Monitor (SRM) System is also provided bypassed because the flux and pressure scrams are +

i to supply additional neutron level information adequate to protect the reactor.

during startup but has no scram functions (reference paragraph 7.5.4 FSAR) . ,

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34 j Amendment No.

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JAFNPP -

TABLE 3.1-1 (cont'd) 4 REACTOR PROTECTION SYSTEM (SCRAM) INSTRUMENTATION REQUIREMENT Minimum No. Modes in Which Total of Operable Function Must Be Number of Instrument Operable Instrument Channels Trip Fianction Trip Level Channels Action per Trip Setting ,

Provided (1)

System (1) by Design Refuel Startup Run for Both (6) Trip Systems e

2 APRM Downscale 12.5 indichted on X 6 Instrument A or B scale (9) Channels 2 liigh Reactor 51045 psig X (8) X X 4 Instrument A Pressure ' Channels 2 liigh Drywell 32.7 psig X (7) X (7) X 4 Instrument A Pressure Channels 2 Reactor Low Water 112.5 in. indicated ' X X X 4 Instrument A -

Level level Channels (2177 in. above the ,

top of active fuel) 3 Iligh Water Level 534.5 gallons per X(2) ~X X 8 Instrument A l in Scrain Discharge Instrument Volume Channels Volume Main Steam line X X, X 4 Instrument A 2'

$3x normal full Ifigh Radiation power background Channels -

4 Main Steam Line $10% valve X(3) (5) X(3) (5) X(5) 8 Instrument A Isolation Valve closure Channels Closure Amendment No. , p$ , 41a

( Table 4.1-1 .-

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REACTOR PROTECTION SYSTEM (SCRA!!) INSTRUMENT FUNCTIONAL TESTS MINIMUM FUNCTIONAL TEST FREQUENCIES FOR SAFETY INSTRUMENT AND CONTROL CIRCUITS j i

l Instrument Channel Group Functional Test

• Minimum Frequency (3)

Mode Switch in Shutdown A Place Mode Switch in Shutdown Each refueling outage.

Manual Scram A Trip Channel and Alarm Every 3 months.

RPS Channel Test Switch A Trip Chann'el and Alarm Every refueling outage or after channel maintenance.

IRM High Flux C Trip Channel and Alarm (4) Once per week during re-fueling or startup and g

before each startup.

Inoperative C Trip Channel and Alarm (4) Once per week during re-fueling or startup and before each startup.

APRM High Flux B Trip output Relays (4)

Inoperative Once/ week.

B Trip output Relays (4) Once/ week Downscale B Trip output Relays (4) Once/ week Flow Bias B Calibrate Flow Bias Signal (4)

High Flux in Startup or Refuel Once/ month (1)

C Trip Output Relays (4) Once per week during refueling or startup and before each startup. i High Reactor Pressure B Trip Channel and Alarm (4) Once/ month. (1) (Instrument check once per dag?

.High Drywell Pressure A Trip Channel and Alarm i Once/ month (1)

Reactor Low Water Level (5) A Trip Channel and Alarm Once/ month (1)

High Water Imvel in Scram A Trip Channel Discharge Instrument Volume Once/ month (7) l' High Water Level in Scram B Trip Channel.and Alarm Once/ month I Discharge Instrument v'oluIac Main Steam Line High Radiation B Trip Channel and Alarm (4) Once/ week.

Amendment No.df , {/I 44

JJFNPP Table 4.1-1 (cont'd) 4 REACTOR PROTECTION SYSTEM (SCRAM) INSTRUMENT FUNCTIONAL TESTS MINIMUM FUNCTIONAL TEST FREQUENCIES FOR SAFETY TNSTRUMENT AND CONTROL CIRCUITS NOTES FOR TABLE 4.1-1 (cont'd) , , ,

5. The water level in the reactor vessel will be perturbed and the corresponding level indicator changes will be monitored. This perturbation test will be performed every month after completion of the functional test program. ,

a 6. Deleted.

7. The funct onal test shall be performed utilizing a water column or similar device to provide assurance that damage to a float or other portions of the float assembly Will be detecte'd.

=

Y Amendment'NO. p4' 45 a

JAFNPP

, Table 4.1-2 REACTOR PROTECTION SYSTEM (SCRAM) INSTRUMENT CALIBRATION MINIMUM CALIBRATION FREQUENCIES FOR REACTOR PROTECTION INSTRUMENT CHANNELS Instrument Channel Group (1) Calibration (4) Minimum Frequency Once/ week IRM liigh Flux C Comparison to APRM on Maximum frequency once/ week Controlled Shutdowns APRM liigh Flux Output Signal B Heat Balance Daily Flow Bias Signal B Internal Power and Every refueling outage Flow Test with Stan-dard Pressure Source LPRM Signal B TIP System Traverse Every 1000 effective full power hours Iligh Reactor Pressure B Standard Pressure Once/ operating cycle Source High Drywell Pressure A Standard Pressure Scurce Every 3 months Reactor Low Water Level A Pressure Standard Every 3 months High Water Level in Scram Dis- A Water Column, Note (6) Once/ operating cycle, Note (6) charge Ipstrument Volume High Water level in Scram Discharge B Standard Pressure Source Every 3 months i Instrument Volume Main Steam Line Isolation Valve A Note (5) Note (5)

Closure Main Steam Line High Radiation B Standard Current Source (3) Every 3 months Turbine Plant Stage Pressure A Standard Pressure Source Every 6 months Permissive Turbine Control Valve Past Closure A Standard Pressure Source Once/ operating cycle Oil Pressure Trip AmendmentNo.[, , 46

JAFNPP ..

TABLE 3.2-3 INSTRUMENTATION THAT INITIATES CONTROL ROD BLOCKS 1

Minimum no.

of Operable Total Humber of Instrument Instrument Trip Level Setting Instrument Channeld Action Channels Per Provided by Design Trip System for Both Channels APRM Upscale (Flow Biased) 6 Inst. Channels (1) 2 s f (0.66W+42%)xFRP MFLPD 6 Inst. Channels (1) 2 APRM Upscale (Start-up f12%

Mode) 2 APRM Downscale 12.5 indicated on scale 6 Inst. Channels (1) 1 (6) Rod Block Monitor Sj0.66W+K(8) 2 Inst. Channels (1)

(Flow Biased)

Rod Block Monitor 1 2.5 indicated 2 Inst. Channels (1) 1 (6)

(Downscale) on scale 3 IRM Downscale (2) 1 2% of tull scale 8 Inst. Channels (1)

IRM Detector not in (7) 8 Inst. Channels (1) .

3 a Start-up Position 8 Inst. Channels (1) 3 IRM Upscale 386.4% of full scale SRM Detector not in (3) 4 Inst. Channels (1) 2 (4)

Start-up position 5 SRM Upscale 4 Inst. Channels (1) 2 (4) (5) {l0 counts /sec 1 Scram Discharge Instrument f 26.0~ gallons per 2 Inst. Channels (9) (10)

Volume High Water Level instrument volume

_ NOTES FOR TABLE: 3.2-3 t.

1. For the Start-up and Run positions of the Reactor Mode Selector Switch, there shall be two operable or tripped trip systems for each function .' The SRM and 'IRM block need not be operable in run mode, and Amendment No.jr , 72

JAFNPP TABLE 3.2-3 (Cont'd) - ,

INSTRUMENTATION THAT INITIATES CONTROL ROD BLOCKS NOTES FOR TABLE 3.2-3 the APRM and RBM rod blocks need not be operable in start-up mode. From and after the time it is found that the first column cannot be met for one of the two trip systems, this condition may exist ,

for up to seven days provided that .during that time the operable system is functionally tested immediately and daily thereafters if this condition lasts longer than seven days, the system shall be tripped. From and after the time it is found that t.he first column cannot be met for both trip systems, the systems shall be tripped.

2. IRM downscale is bypassed when it is on its lowest range.

3. This function is bypassed when the count rate is ?_100 cps.

4. One of the four SRM inputs may be bypassed.

5. This SRM Function is bypassed when the IPM range switches are on range 8 or above.

6. The trip is bypassed when the reactor power is S 30%.

7. This function is bypassed when the Mode Switch is placed in Run.

8. S = Rod Block Monitor Setting in percent of initial.

W = Icop recirculation flow in percent of rated K = Intercept values of 39% 40%, 41% and 42% can be used with appropriate MCPR limits from Section 3.1.B.

9. When the reactor is subcritical and the reactor water temperature is less than 212 F, the control rod block is required to be operable only if any control rod in a control cell containing fuel is not fully inserted.

10. Wnen one of the instruments associated with scram discharge instrument volume high water rod blocks is not operable, the trip system shall be tripped.

I AmendmentNo.%,pI,J2' 73

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b. The control rod directional control f. The scram dischakge volume drain and valves for inoperable control rods vent valves shall each be full-travel shall be disarmed electrically. cycled at least once per quarter to

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verify. that the valves close in less

c. Control rods with scram times greater than 30 seconds and to assure proper than those permitted by Specification valve stroke and operation.

3.3.C.3 are inoperable, but if they can be inserted with control rod drive pressure they need not be disarmed electrically.

d. Control rods with a failed " Full-in" or " Full-out" position switch may be cypassed in the Rod Sequence Control System and considered operable if the actual rod position is known. These rods must be moved in,

e. When it is initially determined that a control rod is incapable of normal insertion, an attempt to fully insert the control rod shall be made. If .

the control rod cannot be fully inserted:

shutdown margin test shall be made to demonstrate under this condition that the core can he made subcritical for any reactivity condition during the remainder of the operating cycle with the analytically determined, highest worth control rod capable of withdrawal, fully withdrawn, and all other control rods capable of in-sertion fully inserted. If Specification 3.3.A.1 and 4.3.A.1 are met, reactor startup may proceed.

Amendment NO. ,1$, pd

. 89a

JAFNPP ,

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3.3 (cont'd) 4.3 (cont'd)

2. The average of the scram insertion 2. At 8-week intervals, 15 percent of times for the three fastest the operable control rod drives shall operable control rods of all groups be scram timed above 950 psig. When-of four control rods in a two-by-two ever such scram time measurements are array shall be no greater than: made, an evaluation shall be made to provide reasonable assurance that Control Rod Average Scram proper control rod drive performance Notch Position Insertion Time is being maintained.

Observed ( Sec.)

3. All control rods shall be determined 46 0.361 operable once each operating cycle 38 0.977 be demonstrating the scram discharge 24 2.112 volume drain and vent valves operable 04 3.764 when the scram test initiated by placing the mode switch in the SHUTDOWN position is performed as required by Table 4.1-1 and by verifying that the drain and vent valves:

a. Close in les's'than 30 seconds after l receipt of a sional for control rods to scram, and

b. Open when the scram signal is

' reset or the scram discharge instrument volume trip is bypassed.

Amendment No. pf, d 96

. ' ,. g APTACHMENT II SAFETY EVALUATION RELAPSD TO SCRAM DISCHARGS VOLUMS SYSTSM l

MODIFICATIONS t .

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I New York Power Autnority i James A. FitzPatricK Nuclear Power Plant Docket No. 50-333

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June 198 3 .

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I. Drecription of tna Changas

., s Tne proposed enanges to the FitzPatricK Tecnnical Specifications revise operating and surveillance limits associated with Scram Discharge Volume (SDV) system modifications. Tnese modifications, described in Reference 1, are being made during tne ongoing Reload 5/ Cycle 6 refueling outage.

Specifically, tne single Scram Disenarge Instrument Vblume will be replaced ditn two instrument volumes of equal size, each located near its respective scram discharge header. Hydraulic coupling between tne discharge headers' and instrument volumes will be .

improved by replacing tne interconnecting 2-inen diameter pipe witn a LO-inch diameter pipe f rom each header. Redundant drain and vent valves and level instruments will oe provided for each instrument I volume to meet tne single' failure criterion specified by tne NRC.

4 Moreover, automatic scram (RPS), water level instrumentation in each instrument volume will consist

• of flost switches and analog (differential pressure) transmitters for diversity. Level instrumentation taps will be taken from tne instrument volumes catner than from connecting piping. Lastly, tne instrumentation will be capable of detecting water in the instrument volumes prior to scram initiation. As a result of these modifications, tne following Technical Specifications enanges are being proposed.

1. In section 3.L of tne bases on page 32, tne phrase, " scram disenarge volume, " is inserted in the tnird paragrapn of the righthand column.

2. In ecction 3.1 of tno cases on pago 34, first

's paragraph, tne sentence, "The scram disenarge volume accomodates in excess of 36 gallons of I water and is the los point in ene piping, " is enanged to read, "Sacn scram discharge instrument volume accommodates in excess of 34 gallons of water and is tne low point in tne piping."

In section 3.1 of the cases on page 34, second 3.

paragraph, tne sentence, "To preclude tnis occurrence, level switenes nave been provided in the instrument volume wnien alarm and scram the reactor when the volume of water reaches 36 gallons," is replaced by tne sentence, "To preclude this occurrence. level detection instruments nave been provided in eacn instrument volume wnich alarm and scram tne reactor dnen the volume of water reacnes 34. 5 gallons. "

4. In Taole 3.1-L on page 4La, tne specifications for tne "Hign dater Level in Scram Disenarge Volume" trip function are changed. Tne minimum l

number of operable instrument channels por trip system is enanged from 2 to 3. The trip level setting is changed from " i 36 gallons" to f

" $ 34. 5 gallons per instrument volume. " And tne number of instrument channels provided by design for botn trip systems is enanged f rom 4 to 8.

& In Table 4.1-1 on page 44, tne label, " Instrument Channel," is added to tne lefthand column. In this column, an additional reference to "High dater Level in Scram Discharge Instrument Volume" is added. This added circuit is in Group 8 and nas functional test requirements for tne trip cnannel and tne alarm of once eacn montn.. Also in this table, tne " alarm" functional test for the Group A RPS circuit for Hign dater Level in

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Scran Dicchargo Instrument Vblume io doloted.

Also for this circuit, the functional test requirement of "before eacn startup" is deleted, along with the reference to Note 6 accompanying tnis requirement.

6. In the notes for Taote 4. L-L on page 4 Ea, Note 6 is deleted.

7. In Taole 4.1-2 on page 46, an additional reference to'"Hign dater Level in Scram Discharge Instrument ,

Volume" is added to the column under tne heading,

" Instrument Channel." Tnis added circuit is assigned to Group B and must be calibrated once every 3 months using a standard pressure source.

8. In Table 3.2- 3 on page 7 2, the speci'fications for

" Scram Discharge Instrument Vblume Hign dater Level" are cnanged. The minimum number of operable instrument enannels per trip system remains L. The trip level setting, however, is changed from " f 18 gallons" to"[g 26. 0 gallons per instrument volume." The total number of instrument channels provided by design for botn enannels is changed from L to 2.

9. In the notes for Table 3. 2- 3 on page 7 3, Note 10 is replaced by the following: "Wnen one of the instruments associated witn scram discnarge instrument volume hign dater level rod clock is not operable, the trip system shall be tripped."

L O. Section 4. 3. A.2. f on page 89a is revised to read as follows: "Tne scram disenarge volume drain and vent valves shall oe full-travel cycled at least once per quarter to verify tnat tne valves close in less than 20 seconds and to assure proper valve stroke and operation."

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11. In section 4. 3.C. 3a on page 96, une specification for closure time of drain and vent valves is enanged f rom 80 seconds to 30 seconds.

II. Purpose of the Cnanges In June 1980, during a routine shutdown of tne Browns ,

Ferry Unit 3 reactor, a manual scram from 36 percent power f ailed to insert 40 percent of tne reactor's control rods. Subsequent investigations revealed tne cause of tne problem to be an accumulation of water in the Scram Discharge Header, wnich reduced tne available free volume for disenarge water. Wnile it was oelieved that the Scram Disenarge Vblume (SDV) water level instrumentation was designed to scram tne reactor before water could accumulate in tne header, the level instr.umentation at Browns Ferry did not detect the water. .

As a result of this event and tne discovery of otner

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SDV system deficiencies at adR sites around tne country, a BWR Owners ' Group was formed in conjunction witn an NRC task force to develop revised design, safety, operational and performance criteria for long-term modifications of tne SDV system. Tne coquirements of IS Bulletins 8 0-14 (Ref. 2) and 8 0-17 (Ref. 3), with supplements, provided a technical basis for interim operation until tne long-term modifications could be completed.

Tne various criteria developed of the Owners' Group, as supplemented by additional NRC requirements for diversity of instrumentation, formed the oasis for tne permanent, Long-term modifications of tne FitzPatrick SDV system described in Section I and in Ref erence 1.

These criteria were formally specified in tne NRC's Generic Safety Evaluation Report (SER), "BWR Scram

- . . . - . ~.- _

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Discnarge System, " dated Dscamber L, 1980 and amanded s

by Generic Letter 81-18, dated Maren 30, L98L.

Tne principal design deficiencies identified by tne SSR were:

L) Inadequate hydraulic coupling between tne Scram Disenarge Header and tne Instrument Volume.

2)

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A complex connection of piping to the vent and drain of tne SDV system tnat could compromise

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tneir intended functions.

. 3) Common-cause failure mecnanisms for tne Instrument Volume water level switenes.

4) The possibility enat control air system failure, ,

compounded by inadequate hydraulic coupling, could cause ene inaoility to scram tne reactor.

The modifications of tha FitzPatrick SDV system being undertaken during the Reload 5/ Cycle 6 outage will resolve all the above deficiencies in a manner defined as " Acceptable Compliance" in tne SSR (for a detailed analysis, see Attacnment III). Hence, interim modifications required by Bulletins 80-L4 and 80-17, as enforced by NRC Orders of October 1980 (Ref. 4) and

^

i January L981 (Ref. 5) are being removed concurrent witn the installation of tne long-term SDV modifications. The first Order required continuous water level monitoring instrumentation, wnile tne second required automatic scram on low air pressure in.

the control air neader. Tne planned removal of tnese modifications was described in Reference L.

As modified, tne SDV system-provides a controlled, near-atmospheric volume for tne accumulation of scram disenarge water wnien is released from eacn control I

rod Hydraulic Control Unit (HCU) upon initiation of a reactor scram.

There are 69 HCU's on tne east side of tne Reactor Building and 68 HCU's on tne west side. Tne near-atmospneric volume availacle for scram located in the SDV above and naar eacn bank of .CU's provides

3. 34 gallons per HCU during the worst-case fast-fill event (when each HCU scram outlet valve laaKs 6.4 gpm into the associated Scram Discharge Header and tne ,

associated vent and drain valves are closed)'.

Sach Instrument Volume (east and west) nas four scram level instruments ( RPS channels A1, al, A2 and 82) individually connected via one-inen diameter lines and Two of enese instruments are 4

root valves.

float-operated level switenes.and two are differential pressure transmitters. Tne scram level specified in the proposed Tecnnical Specifications (accumulation of

34. 5 gallons in ene 24-inch diameter Instrument Volume) nas been determined utilizing results from open-cnannel flow analysis and RPS system time delay I in scram outlet valve actuation. Tnus, adequate

• volume for scram, under tne worst c.ondi-tions, remains i

in the modified system. Tne setpoints for the diverse instruments were determined cased on qualified parameters such as accuracy and reset.

The modified SDV system functions in eitner of two f

situations:

1) A reactor scram actuated by water level sensing trip switches / trip units connected to tne Instrument Volumes, based on attainment of a nign ,

N\

water level.

l 2) A reactor scram initiated _by RPS sensors outside of tne SDV system.

P 6-y,-. - y +-.-r-- g-- --y--, - m.

't Tne attainment of a nign water level in tne Inctrumsnt Vblume sufficient to actuate an instrument in both tne A and B trip systems wiLL cause tne respective RPS trip system to be de-energized; tnus caasing the respective Sov- 31 air control valve to enange position. dith both RPS trip systems tripped, SOV- 3t A and 31B will, in concert, cause tne. air, whien nolds

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the vent and drain valves open, to be dumped., This action closes tne , vent and drain valves on botn

. Instrument Volumes witnin a time interval not te exceed 30 seconds. Concurrent witn tne de-energization of SOV-3tA & 318,' the individual .HCU scram solenoids arelatso de-energized, causing tne scram outlet valves to open and exnaust tne scram discnarge water to the associated Scram Disenarge the Header. With tne continued passing of water past

~~ scram outlet . valve and to tne Scram Disenarge deader, rs the entire _SDV system is pressurized to reactor pressure. .

Pne System is emptied _(upon clearing of tne condition causing the scram) of actuation of tne Discaarge Vblume Lev'el Trip Bypass and Reset switen, located on the main control boa'rd, while the Mode Selector Switch

~ is in " Refuel" or " Shutdown". Witn this action, the, =

RPS circuits are re-energized and tne air-operated valves (vents and drains <xt botn Sast and West sides) opened, allowing tne accumulated water to drain to tne

' associated Reactor 'Bu'ilding equipment drain sumps.

s

1. nen tne Instrument Vblume water Level nas dropped sufficiently to allow tn'o re-estaotianment of tne scram level instrument circuit?s, tne oypass switen can l

' be returned to its standard position and the reactor moved into a mode otner tnan Refuel or Snutdown, as required. The function of tne vent and drain valves can also be ascertained via the SOV-29 test solenoid

^ - .=

Tno initial cwitch located on tan Main Control Pannt.

procence of water in tne Instrumsnt Volumse is t

't i annunciated to the control room and to the plant The computer via non-safety related slave trip units.

defined water accumulation point for this alarm is 17.4 5 gallons. A further levet increase above tne alarm point will actuate a rod block. Tne defined rod block . water accumulation Levet is 26.0 gallons.

The proposed Tecnnical Specification changes described I are designed to in Section I and in Attacnment accompany the above Long-term SDV system modifications and to meet the surveillance criteria of the NRC's Generic SSR. ,

Specifically, tne proposed change on Page 32 is required to include tne Scram Discnarge Volume in the List of instrumentation systems having more than one instrument channet in each tripping device subcnannel l

per RPS trip system.

The changes on Page 34 are required because the Scram Discharge Volume system nas been modified to.have one l

l Instrument Volume per Scram Discharge Header, each I

capable of accomodating in excess of 34 gallons and each provided witn diverse level instrumentation.

The changes on Page 41a reflect enanges in the SDV i hign water level instrumentation, which, as modified, requires a minimum of 3 operable enannels per trip system. Une total number of instrument channels provided by design per trip system is 4, eacn .

containing 2 float switches and 2 differential pressure-actuated switenes per trip system, for a total of 8 operable channels containing 4 float I switches and 4 diffbrential pressure-actuated switches

(

Phe-objective of these changes is to

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! per trip system. 3 guarantee redundancy and diversity in tne Instrument f

_ . . _ . , _ _ _ ~ . .

Volumo levol instrumsntation. Signals from thoco l

t 1 instruments are arranged in a one-out-of-two-taken-twice logic for tne Reactor Protection System. Float level switches and analog type (differential pressure) seitenes on each Instrument Volume in eacn cnannel are combined in a l'ogic "OR" gate sucn that a single failure of one sditen will not prevent actuation of the associated protective j

channel.

A common mode failure of all level instruments of the aame

- type will not result in the inability :to provide a full scram actuation signal. Tne redundant instrumentation is powered from separate and redundant vital 115 volt A-C electrical busses. Loss of power in one bus will I

de-energize ene trip relays on that bus and cause a

- nalf-scram signal actuation. The trip level setting for scram initiat. ion is 34. 5 gallons per Instrument Volume.

Because tne instrument referred to by Note 6 on page 4 5a is functionally tested eacn montn, tne additional testing requirement of "before eacn startup" is deleted in Table 4.1-1 on page 44, along with Note 6.

The enanges on pages 44 and 46 provide specifications for functional testing for the two RPS circuits for Hign dater Level in Scram Discnarge Instrument Volume. Tnese cnanges prescribe montnly trip cnannel functional tests of RPS cnannel A level instruments (float switches) and require that channel calibration be performed once per operating cycle using a water column. Trip cnannel and alarm functional tests of RPS cnannel 8 level instruments

(differential pressure-actuated switches) must be performed l

l monthly, and enannel calibration must be performed every three montna using a standard pressure source.

The'cnange on Page 72 prescribes a minimum of 1 operabis instrument channel per cod block trip system to initiate a

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i

w control rod block at Instrument Vblume nigh water level.

l '5 Tho FitzPatrick SDV sistem, howevor, has 2 instrunent channels provided by design for botn trip systems, as well as 4 float switches and 4 differential pressure-actuated switenes with settings at tnree different water levels.

These settings guard against operation of tne reactor witnout sufficient free volume in the scram discharge headers to accept scram discnarge water in the event of a scram. Tne signals for tne first two levels (alarm and rod block) are received from eitner one of two slave trip units which are activated by tneir respective analog (differential pressure) transmitters on tne attainment of ,

the high level alarm set point or rod block set point. Tne setting for rod block is 26.0 gallons per Instrument Volume. The hignest level setpoint, to initiate a reactor scram, is 34. 5 gallons per Instrument Volume. At tnis

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setting, the eight level switenes (4 for eacn RPS trip system) initiate a scram to snut down the reactor snile sufficient volume remains to receive tne scram discnarge water.

As required by Design Criterion 9 in tne Generic SER, instrumentation has oeen provided to aid tne operator in ene detection of water accumulation in the Instrument Volume prior to scram initiation.

The enange on page 7 3 modifies Note 10 of Table 3. 2- 3 to require that tne trip s/ stem be tripped if all tne instruments associated wi.th scram discharge instrument volume nign water level are not operable.

The changes on Pages 89a and 96 are required to comply with Surveillance Criterion i of tne Generic SER,

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f wnien states, as part of its Tacnnical Saeis, enat t i "Pariodic testing of the vant and drain valves will verify acceptable opening and closing times and assure

! proper valve stroke and operation." As part of its Acceptable Compliance section, this criterion furtner I

states that "Tnis testing should show valve closure in less than 30 seconds."

The surveillance criteria of the Generic SER are:

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" Vent and drain valves snail be periodically.

tested."

2) " Verifying and level detection instrumentation snall be periodically tested in place."-

3) "The operability of tne entire SDV system as an integrated whole shall be demonstrated periodically and during eacn operating cycle, by demonstrating scram instrument response and valve function at pressure and temperature at approximately 50 percent control rod density."

Surveillance Criteria 1 and 2 are addressed in the existing rechnical Specification surveillance requirements as amended by this proposed change.

A integrated system test will be performed during start-up from the current refueling outage (June -

August 198 3). Phis test will verify operability of the entire system by demonstrating scram instrument volume response and valve function. This test sill be performed at operating temperature and pressu're witn a control-rod density of approximately fifty percent.

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Section 4. 3.C (Scram Insertion Pimes) of the FitzPatrick Tecnnical Specifications already require extensive surveillance testing of the control rod

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driva cyctcm on a periodic basis.

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Tnecefore, no additional surveillance requirements are proposed to comply eitn Criterion 3.

III. Impact of the Cnanges The modifications of the FitzPatrick SDV System and the accompanying proposed Tecnnical Specifications changes will nave a positive impact on plant safety.

Because the ' modified. SDV system resolves NRC concerns associated witn inadequate nydraulic coupling, lack of redundancy and diversity of instrumentation, and common cause failure mechanisms, tne modified system improves the safety of the reactor. Pne proposed Technical Specification changes reflect the modified design of the SDV system and meet tne operational and surveillance requirements of the SRC's Generic SER.

The operating, design and surveillance criteria upon wnich the proposed changes are based were formulated by tne NRC as a means of ensuring acceptable, Long-term operation. As outlined in Attachment III, the FitzPatrick station is satisfying all of these criteria in an acceptable manner. Interim operating requirements, imposed by the Orders of References 4 and 5until the Long-term measures described above could be implemented, are being rescinded in view of demonstration of acceptable operation incorporating tne long-term modification.

The Authority considers tnat this proposed amendment can be classified as not likely to involve significant hazards considerations because it " involves relief granted upon demonstration of acceptable cperation from an operating restriction that was imposed because acceptable operation das not yet demonstrated."

(Example (iv), Federal Register, Vbl. 48 No. 67 dated April 6, 198 3, page 14d7 0) . Restrictions were applied on the

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operation of tno FitzPatrick plant by tne NRC in the Tno approval form of tdo orders (References 4 and 5) .

criteria nave been establisned by the NRC in their Generic Safety Evaluation Report "Bar Scram Disenarge System" dated December L, L980 as amended bf Generic Letter No. 81-18 dated daren 30, 1981. Attachment No.

III ("Conformance of Scram Disenarge Volume System to the Criteria of NRC Generic Saf etf Svaluation Report")

descrioes how tnis criteria nas been met.

- Tnu s , the proposed Tecnnical Specification cnanges involve no Significant Hazards Considerations, as -

defined in 10 CFR 50.92.

IV. Implementation of the Changes Implementation of tne cnanges, as proposed, will not impact tne fire protection program at FitzPatrick; nor will the changes impact the environment. Tne Autnoritf nas conducted an anal / sis designed to ensure that personnet doses f rom implementation of the SDV system modifications are kept As Low As is Reasonaoly Acnievable. Nevertheless, significant personnel doses are expected to result from installation of tne modifications. Because tne Pecnnical Specifications changes themselves specify, in most cases, remote surveillance of tne modified SDV system, long-term radiation exposure is expected to decrease as a result

! of tne cnanges.

V. Conclusion The incorporation of tnese changes: a) will not increase the probability or tne consequences of an l

accident or malfunction of equipment important to safety as evaluated previousif in tne Safety Analysis Report; c) will not increase the possibility of an accident or malfunction of a type otner tnan enat

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4 ovaluated previoucif in tna Safotf Analfels Report; e

i c) will not reduce tne margin of s'afety as dsfined in tne basis for any Pecnnical Specification; d) does not constitute an unreviewed safety question, and e) involves no Significant Hazards Considerations, as defined in 10 CFR 50.92.

VI. References

1) PASNY letter, J. P. Bayne to H. R. Denton and

- R. .DeYoung, day 12, 198 3 (JPN-8 3-41) .

2) NRC IS Bulletin 80-14, June 13, 1980.

MRC IE Bulletin 8 0-17, Juif 3, 1980, ditn 3)

Supplements 1 (July 18, 1980), 2 (July 22, 198 ),

3 ( August 22, 1980) and 4 (December 18, 1980).

4) MRC Confirmatory Order, V. Stello to G. T. Serry, October 2, 1980.

5) NRC Order for Modification of License, T. A. Ippolito to G. f. Berry, Januarf 9, 1981.

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f.wh APTACHMENT III CONFORMANCE OF SCRAM DISCHARGE VOLUME SYSTEM TO THE CRITERIA OF NRC GENERIC SAFEPY EVAL 0ATION REPORT

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. New York Power Autnority James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 June 1983 t

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) ~ 's FitzPatrick Scram Discharge Volume System C M i % ce With NRC Ceneric Safety Evaluation The functional, safety, operating and design criteria listed below are extracted from the NRC Generic Safety Evaluation Report (and Generic Letter 81-18).

Functional Criterion No. 1 "The scram discharge volume shall have 1.

sufficient capacity to receive and contain water exhausted by a full reactor scram without adversely affecting control rod drive scram performance."

The capacity of the SDV (8" 9 headers, 10" 9 connecting line and 24" 9 instrument volume) has been provided so as to assure a free volume of 3.34 gallons per Hydraulic Control Unit (HCU) at the worst case maximum inflow leakage past the scram valves.

In regard to the operation under degraded conditions, this project has addressed the occurrence of low air pressure in the CRD control air headers. Operation under degraded control air conditions could result in a SDIV " fast fill" even,t. The hydraulic design incorpo-rated in this long term modification addresses this " worst case" situation and by the following quote from the NRC SER eliminates the need for the CRD Control Air System Modification (F1-81-01) presently installed:

"In the long term, the improved hydraulic coupling will assure detection by level instrumentation and thereby provide a timely automatic scram independent of the inleakage rate when the SDV headers fill." (p. 29 of NRC SER)

2. Safety Criterion No.1 "No single failure of a component or service function shall prevent a reactor scram, under the most degraded conditions that are operationally acceptable."

NRC RG 1.53 requires that no credible single failure result in the inability of a protective system to perform its intended safety related function. The Scram Discharge Instrument Volume (SDIV) electrical power and control and instrumentation is designed on a redundant basis. All wiring, conduit and cable / raceway runs are physically separated to prevent a single physical er electrical failure from isolating the SDIV on a reactor scram or on a high level signal in the SDIV. Redundant control air lines are routed from the SDIV air dump solenoid valves (SOV 31A & B) to the redundant vent and drain isolation valves The SDIV level measuring instrunients a're provided with redundancy and diversity as described under Safety Criterion No. 3.

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3. Safety Criterion No. 2 "No single active failure shall prevent uncontrolled loss of reactor coolant."

The criterion establishes the design basis for preventing loss of l reactor coolant due to a single failure in the SDIV System. It further f states that an acceptable way of meeting this criterion is to install two isolation valves in series for the vent and drain function.

' Two isolation valves are installed in series for the vent and drain functions to prevent a' single failure of a valve from preventing the -

isolation of the vent or drain. An uncontrolled loss of reactor coolant due to single isolation valve failure-to-close is thus prevented.

Two control air lines are routed from the scram solenoid valves to the redundant vent and drain isolation valves. A single failure in one control air line will not prevent the other control air line from closing the redundant isolation valves. The 115 volt a-c scram solenoid valves are backed up by 125 volt d-c solenoid valves 1

powered from the station battery. A single failure of one of the 115 volt a-c solenoid valves will not, therefore, prevent the isolation valves from closing.

4, Safety Criterion No. 3 "The scram discharge system instrumentation

' shall be designed to 1rovide redundancy, to operate reliably under all conditions, and s1all not be adversely affected by hydrodyr.amic forces or flow characteristics."

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! Each SDIV is provided with level measuring instrumentation which meets the requirement for redundancy and diversity. Each SDIV has two float type level switches and two differential pressure type level

instruments for actuating a scram on high SDIV level. Float switches and differential pressure actuated switches are arranged electrically in an "or" gate logic so that a failure of one type of measurement due to a comon mode failure will not result in the inability to initiate a reactor scram on high SDIV level. The level switches are arranged in a one-out of two taken twice logic arrangement. Therefore, the instrumentation on each SDIV meets the single failure criterion.

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. The Hydraulic Transient Analysis was made to determine the possible impact of hydrodynamic forces 'in the system. The effect of the hydrodynamic forces has been incorporated into the design of l the two (2) types of instrumentation used in this design. In addition, the impact, of flow characteristics has been determined and incorporated into the specification of the instrumentation which may be flow sensitive, i.e., the float-operated level switch.

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The level sensors provided for each Trip (System are of two (2) diverseclas types. The float operated level switch in operation and construction to that which is presently in use. The second type of level sensor is a sealed sensor system with a differential pressure transmitter which has operating principals totally different from that employed by the float-operated. level switch. This diverse instrumentation is completely class 1E qualified and provides assurance of protection from common cause failures due to float-crushing, etc.

Also, the possibility of a common cause failure is further protected.

against by: 1) the periodic functional testing of level instrumentation as required by Surveillance Criteria 2 of the NRC SER, 2) the operational principal diversity, and 3) the qualification of instruments to IEEE 323 and 344. .

The redundant instrumentation is powered from separate and redundant vital 115 VAC electrical busses such that a loss of electrical power in one bus will not cause an unnecessary scram. The electrical system is arranged so that Bus "A" powers the "A" system instruments and relays and Bus "B" powers the "B" system instruments and relays. A failure of either of these busses will cause a half scram.

5. Safety Criterion No. 4 " System-operatina conditions which are required for scram shall be continuously monitorea. a The SDIV is measured by redundant and diverse level instrumentation as described in section 4 above.

In addition, the control room operator is provideu with the following annunciators, computer printouts and status indicating lights.

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1) Annunciator Inputs

- One common annunciator window for "HIGH LEVEL SDIV SCRAM" on any one of 8 scram level instruments - 4 float switches and 4 differential pressure actuated switches.

- One. annunciator window to indicate "SDIV NOT DRAINED". This window is activated from either one of two slave trip units which are activated by their respective differential pressure transmitters on the attainment of the hic'i level alarm point. There.is one alarm function associated with each of the SDIVs.

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- One annunciator window to indi'cate "HIGH SDIV TRIP BYPASSED" k if bypass is selected in shutdown or refueling mode.

2) Computer Inputs

- One computer input for each of 8 level instruments - 4 float switches and 4 differential pressure actuated switches.

Indication is "Hi level SDV trip".

- Two computer inputs to indicate " Rod B1'ock Withdrawal". (One

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at each SDIV)

- Two computer inputs to indicate water level at " Alarm" condition. (One at each SDIV)

3) Status Indicating Lights

- One indicating light for "0 PEN" and one for " CLOSED" from each SDIV vent and drain valve. Open = Red, C]osed = Green.

A total of 16 lights is provided, 2 from each of 8 valves.

6. Safety Criterion No. 5 " Repair, replacement, adjustment, or surveillance of any system component shall not require the scram function to be bypassed."

When a level device is removed from service, the device will be bypassed. Float level switches and analog type (differential

- pressure) switches on each Instrument Volume in each channel are combined in a logic "0R" gate such that bypassing any one switch will not prevent actuation of the associated protective channel.

7. Operational Criteria No. 1 to 5

! (1) " Level instrumentation shall be' designed.to'be' maintained, I tested, or calibrated during plant operation without causing l a scram."

(2) "The system shall include sufficient supervisory instrumentation l

and alarms to permit surveillance of system operation."

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, (3) "The system shall be desicned'to minimize the exposure of l operating personnel to raciation."

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, (4) " Vent paths shall be provided to assure adequate drainage in

preparation for scram reset."

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l (5) " Vent and drain functions shall not be adversely affected by other system interfaces. The objective of'this requirement is to oreclude water backuo in the scram instrument volume which l

could cause spurious scram."

7.1. The level instrumentation is designed to be maintained, tested or calibrated during plant operation without scram as discussed in paragraph 6. Each instrument can be tested locally with proper function of respective relays, alams and computer messages assuring full operational readiness.

7.2. Level instrumentation is provided with control room annunciator alams and computer printouts to permit control room surveillance by the operator. Refer to Paragraph 5 for details of annun-ciators computer inputs and valve position indication lights.

7.3. The piping system is designed to minimize operating personnel exposure to radiation hazards. To assure minimal exposure of operating personnel to radiation hazards, the IV will be designed to accept temporary shielding and the vent line design will incorporate a protected, non-submerged discharge.

In addition, hydrolase connections are provided at critical areas of the drain and SDV headers to permit clean out. Further, the IV and the drain line are provided with concrete block shielding. enclosures.

7.4 . The vent path provides adequate drainage at reset. The piping design task will assure adequate venting, There will be a one (1) inch diameter common vent from both the SDV header and the instrument volume.

7.5. Vent and drains will not be impacted by other system interfaces.

The drains (2" dia) will be routed independently to equipment drain headers (4" dia) which, in turn, travel to the lower elevation equipment drain sumps to ensure highly reliable drainage. Since no increase in drain flow is expected and, in fact, is split now to two (2) 4" dia. drain headers, there ,

l is no impact on plant drainage systems.

Thd vents are provided with non-submergec discharge via a water knock-down chamber in the protected environment of nearby RHR heat exchanger rooms. This vent discharge arrangement is presently in operation at JAF and there are no operational problems regarding it.

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. 8. Design Criterion No.1 "The scram discharge headers shall be sized

! in accordance with G.E. OER-54 and shall be hydraulically coupled to the instrumented volumes in a manner to pennit operability of the scram level instrumentation prior to loss of system function.

Each system shall be analyzed based on a plant-specific maximum  ;

i inleakage to ensure that the system function is not lost prior to initiation of automatic scram. Maximum inleakage is the maximum l.

flow rate through the scram discharge line without control-rod

! motion summed over all control rods. The analysis should show no'

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need for vents or drains."

The scram discharge volume (headers, connection from header to instrument volume and available portions of the instrument volume) l are sized per G.E. OER 54 for 3.34 gal. per HCU. coincident with the worst case in-flow rate determined from an open-channel ,

l hydraulic analysis. The headers are 8 inch diameter along the legs of the "U" and are 10 inch diameter at the cross piece of the 1 '"U". A 10 inch diameter pipe connects each of the headers with i its respective instrument volume. The instrument volumes are 24

! inches in diameter.

i The worst case in-flow rate of 6.4 gpm per rod was determined from stall-flow tests conducted at JAFNPP. The open channel analysis i utilized this value for inleakage rate summed over all the control  !

rods connected to a header. Vent and drain flows are not necessary  ;

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to assure system function.  !

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! 9 Design Criterion No.2 " Level instrumentation shall be provided for automatic scram initiation while sufficient volume exists in the (

scram discharge volume."

f '1he hydraulic design and analysis task has eshh14ethed the scram discharge instrunent voluna required to meet the worst I case volune requirements. '1he Instrunent Arrangement Design and Analysis Procedure has established the instrunent settings t required to assure that autanatic scram initiation will occur '

with sufficient margin to assure that an adequate scram discharge  !

volune is present. Items imhvkr1 in the analysis of this criteria are:

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1. Accuracy of float and differential pressure sensors

2. Level sensor time delay .

3. Time delay from level sensor operation to trip of scram  !

solenoids  !

4. Time delay in scram solenoid operation  !

5. Time delay in actuation of scram ~ outlet valves on the HCU i

6. Maximum rod seal leakage rates into scram discharge header  !

i during plant operation, j l

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10. Design Criterion No.3 " Instrumentation taps shall be provided j on the vertical instrument volume and not on the connected pi pi ng .,"

The design provides two (2) separate taps directly to the instrument volume for each level instrument.

- 11. Design Criterion No.4 "The scram instrumentation shall be capable of detecting water accumulation in the instrumented j volume (s) assuming a single active failure in the instrumentation system or the plugging of an instrument line."

Single failure of level instrumentation is addressed in section 2.

All instrument taps are connected directly to the Scram Discharge Instrument Volume. This reduces or eliminates the possible

' accumulation of sediment which could plug the instrument sensing lines. Functional testing of the instrumentation of each SDIV in accordance with the technical specifications provides an j

additional level of assurance that plugging of the sensing lines will not occur.

The sensing line instrument isolation valve-taps are located on i

the SDIV at different orientation to prevent a single plugging l incident from disabling all instruments. The analog differential pressure transmitter is provided with sensing taps completely independent from the float level switches. Additionally, the differential pressure type instruments have a filled capillary sensing system which prevents sediment from reaching the instrument sensing mechanism.

! 12. Design Criterion No.5 " Structural and component design shall j consider loads and conditions including those due to fluid dynamics, thermal expansion, internal pressure, seismic consideration and adverse environment." ,

The piping, pipe supports, instrument volume / supports, instruments, i conduit and block wall enclosures have considered loads due to fluid dynamics, thermal expansion, internal pressure, seismic consideration and adverse environment, as required.

l 13. Design Criterion No.6 "The power-operated vent and drain valves shall close under loss of air and/or electric power. Valve l

position indication shall be provided in the control room."

l All air operated SDIV vent and drain valves are of the air to open/ fail close type. A lots of control air, control air tubing break or loss of both channels of vital 115 VAC which operate solenoids SV-31A & B will result in automatic spring-assisted

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closure of the air operated valves.

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Each air operated vent and drain isolation-valve is provided with l a green and red indicating light.on the main control panel to

! indicate closed and open position, respectively. At intermediate positions of.the valve, both lights will be illuminated.

14. Design Criterion No.7 "Any reductions in the system piping flow

! path shall be analyzed to assure system reliability and operability under all modes of operation." .

No reduction in flow area occurs in the SDV headers or SDV header to I.V. piping, j 15. Design Criterion No.8 " System piping geometry (i.e., pitch, line size, orientation) shall be such that the system drains continuously 1 j during normal plant operation."

i The piping for the SDV headers, the SDV header to I.V.

piping, the drain and the vent piping are all sloped at least 1/8 inch per foot thus providing for continuous free draining of the SDS.

16. Design Criterion No.9 " Instrumentation shall be provided to aid the operator in the detection of water accumulation in the instrument volume prior to scram initiation."

Annunciators and computer. printouts are provided for the operator to determine the occurrence of water accumulation in the SDIV prior 4

to scram initiation. Refer to section 5 for details.

This design criteria permits the present alann and rod block with-

drawal alarm to meet the requirements for surveillance provided that an acceptable hydraulic coupling exists. The hydraulic coupling of the scram discharge volume and the IV has' been addressed j in the hydraulic analysis task. '

17. Design Criterion No.10 " Vent and drain line valves shall be provided to contain the scram discharge water, with a single active failure and to minimize operational exposure."

Each drain and vent line is provided with two (2) isolation valves l in series and completely independent in operation. The redundancy i

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l provided in the valve control air system by the DC solenoids (S0V-140 & 141) provide acceptance to. single failure criteria.

The reliability of the well proven system will mitigate operational exposure. 4

18. Surveillance Criterion No. 1 -'" Vent and drain valves shall'be periodically tested."

A Surveillance and Test Procedure will cover the periodic testing i of the vent and drain valves via the 50V-29 switch which is located on the Main Control Panel. This test will record opening and closing times. Valve closure will be verified to be less than 30 seconds.

19. Surveillance Criterion No. 2 " Verifying and level detection instrumentation shall be periodically tested in place."

Surveillance and Test Procedure No. F-ISP-66 (Scram Discharge Volume High Water Level Instrument Functional Test / Calibration) will be updated to require draining of the instrument via the IV connection following operability testing of each instrument.

In addition, operating procedures will be updated to require.

comparison of the Scram Discharge System drain rate with previous measurements subsequent to scram reset.

20. Surveillance Criterion No. 3 "The operability ~ of' the entire system as an integrated whole shall ba demons trated . peri odical l y and . duri nc each operating cycle, by demonstrating. scram instrument response anc(

valve function at pressure and temperature at approximately 50%

' control-rod density."

s A integrated system test will be performed during start-up from the current refueling outage (June - August 1983). This test will verify operability of the entire system by demonstrating

scram instrument volume response and valve function. This test

' will be performed at operating temperature and pressure with a control-rod density of approximately fifty percent.

Section 4.3.C (Scram Insertion Times) of the FitzPatrick

' Technical Specifications already require extensive surveillance testing of the c,ontrol rod drive system on a periodic basis.

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