ML20029C989
| ML20029C989 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/25/1994 |
| From: | Tjader T Office of Nuclear Reactor Regulation |
| To: | Woods B SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| TAC-M86191, TAC-M86192, NUDOCS 9405030177 | |
| Download: ML20029C989 (12) | |
Text
April 25, 1994
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Mr. Brian Woods Southern California Edison Company 23 Parker Street Irvine, CA 92718
Dear Mr. Woods:
Enclosed are NRC staff comments to Sections 3.] 6192, and Dockets and 3.5 of the San Onofre technical specifications (TS) (TAC #'s*86191 &N 50-361 & 50-362).
If necessary, after you review these comments we can arrange to meet to discuss them.
The NRC is determining if the deletion of the particulate / iodine channels from the proposed SONGS Technical Specifications (Proposed change 27/PCN 405) is acceptable.
Changes to Surveillance Requirement (SR) frequencies from 18 to 24 months (corresponding to refueling intervals), should be checked for compliance with Generic Letter 91-04 (Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month fuel Cycle).
Specifically, frequency changes in SRs 3.3.1.10, 3.3.3.5, 3.3.5.3, 3.3.5.4, 3.3.7.3, 3.3.7.4, 3.3.10.5, 3.3.11.4, 3.3.12.2, and 3.3.13.3 need to be justified.
Sincerely, bdsnil.eu-ca nu T. R. Tjader, Reactor Engineer Technical Specifications Branch Division of Operating Reactor Support Office Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
Enclosure:
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April 25,1994 Mr. Brian Woods Southern California Edison Company 23 Parker Street Irvine, CA 92718
Dear Mr. Woods:
Enclosed are NRC staff comments to Sections 3.3 and 3.5 of the San Onofre technical specifications (TS) (TAC #'s 86191 & 86192, and Dockets 50-361 & 50-362).
If necessary, after you review these comments we can arrange to meet to discuss them.
The NRC is determining if the deletion of the particulate / iodine channels from-the proposed SONGS Technical Specifications (Proposed change 27/PCN 405) is acceptable.
Changes to Surveillance Requirement (SR) frequencies from 18 to 24 months (corresponding to refueling intervals), should be checked for compliance with Generic Letter 91-04 (Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month fuel Cycle). Specifically, frequency changes in SRs 3.3.1.10, 3.3.3.5, 3.3.5.3, 3.3.5.4', 3.3.7.3, 3.3.7.4, 3.3.10.5, 3.3.11.4, 3.3.12.2, and 3.3.13.3 need to be justified.
Sincerely,
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T. R. Tjader, Reactor Engineer Technical Specifications Branch Division of Operating Reactor Support Office Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
Enclosure:
As stated
Enclosure COMMENTS ON SCE STS SUBMITTAL FOR'SAF ONOFRE 2 & 3 SPECIFICATION 3.3.1. RPS INSTRUMENTATION-0PERATING:
- 1) The LOSS OF LOAD and STEAM GENERATOR HIGH trips have been deleted.
They are included in the Licensee Controlled Specifications.
It is stated that the trips are for equipment protection only.
Reference to NRC/SER Chapter 7.2.1 is made.
The SER is not identified (Description of Proposed Change NPF-10/15-299, item 11),
Justify (i.e., identify SER) the acceptability of their removal from the Technical Specifications.
- 2) The frequency of SR 3.3.1.5 specified in the Unit 2 and 3 Technical Specifications was changed to 92-days from the NUREG-1432 specified 31-days with no annotation, description, or justification.
That frequency should revert to 31-days.
- 3) The frequency of SR 3.3.1.6 for calibrating the Excore nuclear instrumentation was changed from the 31-days of NUREG-1432 to 92-days based on a Pickard, Lowe, and Garrick, Inc., evaluation.
Provide that evaluation for NRC review to determine whether the basis for this change is acceptable.
- 4) On Table 3.3.1-1, note a, the NUREG-1432 ' bypass shall be automatically removed when THERMAL POWER is s[1E-4]% RTP' has been changed to
' bypass shall be automatically removed when THERMAL POWER is <[lE-4]% RTP' with no annotation, explanation, or justification. Justify this minor change.
- 5) On Table 3.3.1-1, note c, the NUREG-1432 ' trips may be bypassed when pressurizer pressure is <[400] psia.
Bypass shall be automatically removed when pressurizer pressure is 2[500] psia' has been changed in the SONGS Technical Specifications to read ' trips may be bypassed when pressurizer pressure is <[472) psia.
Bypass shall be automatically removed when pressurizer pressure is 2[472] psia'.
The initial change of 400 to 472 appears to be a typographical error, otherwise justify this change (compare with table 3.3.5-1).
- 6) On Table 3.3.1-1 footnote d was added to the markup of NUREG-1432.
The footnote reads ' trip can not be bypassed if ESF channels are required OPERABLE in Mode 3 because of shared bypass circuit breakers'.
This footnote was not called out in the list of changes to the NUREG.
The proposed SONGS Technical Specifications do not have this footnote.
Verify that the markup footnote d is not needed.
- 7) Table 3.3.1-2 specifies the process measurement and trip' bypasses associated with REQUIRED ACTIONS A.1 and A.2, and it amplifies the ' Functional Unit' of those REQUIRED ACTIONS. The table does not include logarithmic power level - high, pressurizer pressure - low, or reactor coolant flow - low.
Local power density - high and departure from nucleate boiling ratio (DNBR) -
low are indicated as part of the core protection calculator, but not otherwise included. Why are these trips not included?
- 8) On Bases page 83.3-1, reference 1 in the second paragraph is to General Design Criteria 21.
Reference 1 appears on page B 3.3-1 to 10 CFR 20
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along with reference 2 to 10 CFR 100.
10 CFR 50, Appendix A, GDC 21,-does not appear in the References section.
The references should be renumbered to include this reference. Note: - Reference 3 in the NUREG has been deleted by the licensee in the narrative in the following paragraph.
However, it still is listed in the References section of the BASES.
That reference should be l
removed.
9)
In the APPLICAGLE SAFETY ANALYSES section of the Bases, page B 3.3-12, the discussion ends '; and' because the subsequent line-item listing was deleted from NUREG-1432 by the licensee.
'And' should be relocated to the previous line.
10)
In the APPLICABLE SAFETY ANALYSES section of the Bases, page B 3.3-13, changes to paragraphs 3, 4, and 5 justification is that they are " changes that delete information act relevant to the SONGS design." The same justification is used for each of the three changes, yet in items 4 and 5,
'CCAS' is added. The licensee should justify these changes individually and specifically.
11)
In the APPLICABLE SAFETY ANALYSES section of the Bases,'page B 3.3-16, paragraph 12 on DNBR-Low, ' Single Reactor Coolant Pump (RCP) Shaf t Seizure' and ' Steam Generator Tube Rupture' have been removed from the listed events.
The annotated reason, No. 4, states additional detail is provided in the Bases for the SR.
There is not apparent justification provided for the removal of these two events.
The licensee should justify eliminating these two line item events.
12)
In the LCO sectica of the Bases on Reactor Coolant Flow, page B3.3-21, the section title is left out, resulting in the merging of this section with the Steam Generator Level - Low section.
Tre section title should be restored.
13)
In the ACTION section of the Bases, on page B 3.3-27 the section title, 'D.1 and D.2' is left out.
On page B 3.3-28, the section title,
'F.l' is left out. Note that G.1 (Continued) on Page 3.3-29 is NOT a Surveillance Requirement, but a continuation of the ACTIONS. The BASES for the SURVEILLANCE REQUIREMENTS begins later on the page.
- 14) The Bases for SR 3.3.1.4 on line 4, the word ' Agree,' marked out in the NUREG-1432 markup, should be removed from the SONGS document.
- 15) The Bases for SR 3.3.1.7, on bistable tests, two paragraphs in NUREG-1432, beginning with 'As found and as left setpoints are recorded,' were eliminated from the markup with no justification.
The licensee should justify this deletion.
- 16) The Bases for SR 3.3.1.9, two paragraphs in NUREG-1432, beginning with 'As found and as left calibration values are recorded,' were eliminated from the markup with no justification.
The licensee should justify this deletion.
17)
In SR 3.3.1.10, the NUREG statement, " Operating experience has shown that undetected CPC or CEAC failures do not occur in any given [18]
month interval," was changed by the licensee to a 24-month interval.
No t
o i
6 justification was provided for this change.
The licensee should support this change by evidencing the statement is true regardless of an 18-or 24-month interval.
- 18) The licensee notes in their Description of Change (NUREG-1432 and Proposed SONGS Technical Specifications), that "the logarithmic power level monitoring instrument has been replaced with the source range monitoring instrument." The nomenclature for this LC0 and BASES needs to be made consistent and clear.
See also LCOs and Bases for 3.3.2 and 3.3.13.
The nomenclature should be consistent throughout the Technical Specifications.
SPECIFICATION 3.3.2. RPS INSTRUMENTATION-SHUTOOWN:
- 1) The Bases for SR 3.3.2.2, on bistable tests, two of three paragraphs in NUREG-1432, beginning with 'As found and as left setpoints are recorded,'
were eliminated from the markup with no justification.
The licensee should justify this deletion.
- 2) The Bases for SR 3.3.2.4, two paragraphs in NUREG-1432, beginning with 'As found and as lef t calibration values are recorded,' were eliminated from the markup with no justification.
The licensee should justify this deletion.
SPECIFICATION 3.3.3. CEACs:
- 1) GENERIC questior.s regarding CONDITION C - (a) Should the Completion Time of '12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />' (after receipt of a CPC channel B or C cabinet high temperature alarm) to p9rform a CHANNEL FUNCTIONAL TEST on the affected CEAC(s) be '12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> until high temperature alarm is cleared'?
(Which CHANNEL FUNCTIONAL TEST [SR 3.3.3.3, SR 3.3.3.5, or both, see comment on Surveillance Requirement, below] is required?)
(b) ACTION CONDI' ION C.1 is based on high temperature alarms in the'CPC cabinets B or C.
The CFAC CEA isolation amplifiers are in CPC cabinets A and D (BASES SR 3.S.3.6).
In light of the operational need for these isolation amplifitrs, should ACTION CONDITION C.1 be based on high temperature alarms in CPC cabin 9ts A, B, C, or D?
- 2) Both SR 3.3.3.3 and SR 3.3.3.5 require the licensee to " perform a CHANNEL FUNCTIONAL TEST;" SR 3.3.3.3 every 92-days and SR 3.3.3.5 every 18-months (SONGS changes this to 24-months, and needs to be justified).
The BASES indicate these tests are different, in that SR 3.3.3.3 is a software-based test and the SR 3.3.3.5 test injects a signal as close to the sensors as possible for an end-to-end test, including alarms and trips.
The tests required by the two surveillance requirements should have different test title nomenclature to avoid confusion. Action C (noted above) then should refer to the specific Surveillance Requirement.
3)
In the ACTION B.1 section of the Bases, the reference to 'LC0 3.2.5, AXIAL SHAPE INDEX (ASI),' in NUREG-1432 is changed in the proposed SONGS-Technical Specifications to 'LC0 3.2.4, "DNBR,"'.
However, the continuation of the sentence, ' ensures... ASI... within a conservative region' remains unchanged.
The licensee should verify and justify the validity of this
4 change.
- 4) The Bases for SR 3.3.3.4, two paragraphs in NUREG-1432, beginning with 'As found and as left calibration values are recorded,' were eliminated from the markup with no justification.
The licensee should justify this deletion.
5)
In the Bases for SR 3.3.3.5, the extraneous '7778' should be deleted.
SPECIFICAT!0N 3.3.4. RPS LOGIC AND TRIP INITIATION:
- 1) The frequency for SR 3.3.4. has been changed from the NUREG 92-days to 31-days. The BASES,was not changed, and remains at 92-days.
Resolve this discrepancy, and justify if changing to 31-days.
2)
Reference 1 in the Bases should be changed from 10 CFR 50 to 10 CFR 20 (as done in sections on 3.3.1, 3.3.2, and 3.3.3).
- 3) Reference 4 in the Bases on the NRC Safety Evaluation Report should be deleted, and Reference 5 renumbered accordingly.
SPECIFICATION 3.3.5. ESFAS INSTRUMENTATION:
- 1) Table 3.3.5-2 should be addressed in the Bases.
- 2) Reference 3 has been deleted in the Background section of the Bases.
The remaining references need to be renumbered, and Reference 3 removed from the REFERENCE Section.
3)
In the Background Section of the Bases, under " Measurement Channels,"
in the next to last paragraph, the sentence ' plants that have demonstrated adequate channel to channel independence may operate...' should be made specific to San Onofre and not a generic catch-all.
- 4) There is an extraneous second "LC0" header on page B 3.3-93.
- 5) On Bases page B 3.3-101, the heading for Section SR 3.3.5.6 is missing above the last paragraph.
6)
In SR 3.3.5.6 Bases, the last paragraph, 'With 92 days of startup' should read 'once within. 92 days prior to each reactor startup.'
SPECIFICATION 3.3.6. ESFAS LOGIC AND MANUAL TRIP:
1)
In the APPLICABLE SAFETY ANALYSES section of the Bases, it states in paragraph 5 that 'CSAS is initiated by high containment pressure and a coincident.' should end with '... and with a coincident SIAS.'
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i 2)
In the LCO section of the Bases, paragraph 4 on the Recirculation i
Actuation Signal - Matrix logic, add MODE 4 applicability (per Table 3.3.6-1).
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3)
In the ACTIONS section of the Bases, CSAS is moved from ACTION E.1 and E.2 to ACTION F.1 and F.2.
In the Technical Specification ACTIONS, CONDITION E includes Containment Spray Actuation Signal and CONDITION F.1 and F.2 does not. The licensee should resolve this discrepancy.
If changes to the ACTION CONDITIONS result, those changes will need justification.
SPECIFICATION 3.3.7. DG-UNDERVOLTAGE START:
1)
In SR 3.3.7.3a, on time delay, 'At 9228 V' should be 'at 4228-Vac.'
- 2) The acronym 'LOVS' is used despite the licensee changing the LC0 title from ' loss of voltage start' to 'undervoltage start' and deleting the definition for 'LOVS'.
The licensee should reword the BASES consistently in accordance with what was done in LC0 3.3.7.
If used the acronym 'LOVS' should be defined in the text.
3)
In the Background section of the Bases, in first paragraph under Trip Setpoints and Allowable values, 'a detailed description of the methodology used to calculate the trip setpoints, including their explicit uncertainties is provided in Reference 3' was deleted.
Justify the deletion.
What is the Basis (or where is it found?) for the Trip Setpoints and Allowable Values?
4)
In SR 3.3.7.3 Bases, the licensee deleted the second and third paragraphs of NUREG-1432 with no description or justification.
SPECIFICATION 3.3.8. CPIS:
1)
In the Background section of the Bases, in first paragraph under Trip Setpoints and Allowable values, 'a detailed description of the methodology used to calculate the trip setpoints, including their explicit uncertainties is provided in Reference 2' was deleted.
Justify the deletion.
What is the Basis (or where is it found?) for the Trip Setpoints and Allowable values?
2)
In the third paragraph of the LC0 section of the Bases 'These uncertainties are defined in... (Ref. 2)' was deleted without annotation, description, or justification. This deletion should be resolved in concert with the immediately preceding comment.
3)
In the References section of the Bases, generic document titles should be replaced with actual document references.
Also, check the use of references, and delete and renumber as appropriate.
SPECIFICATION 3.3.9. CRIS:
1)
In SR 3.3.9.2, when the brackets were removed around " Allowable Value," the word "setpoint" should have been removed.
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2)
In the Background section of the Bases, in first paragraph under Trip Setpoints and Allowable values, 'a detailed description of the methodology used to calculate the trip setpoints, including their explicit uncertainties is provided in Reference 2' was deleted. Justify the deletion.
What is the Basis (or where is it found?) for the Trip Setpoints and Allowable Values? Adjust references as required.
- 3) In the APPLICABILITY section of the Bases, 'For those plants that credit gas decay tank rupture accidents, the CRIS must also be OPERABLE in MODES 5 and 6' was deleted with no annotation, description, or justification.
4)
In the References section of the Bases, reference 2 appears to be a generic reference, though different from section 3.3.8 and NUREG-1432.
It should be replaced with the specific reference for setpoint calculations for this instrumentation.
Note that ' Valves' should be ' Values.'
SPECIFICATION 3.3.10. FHIS:
1)
Bracketed SR 3.3.10.6, verifying FHIS channel response time was deleted.
The justification noted was a editorial correction.
SR 3.3.10.6 should be added to the proposed SONGS Technical Specifications.
SPECIFICATION 3.3.11. PAMI:
- 1) Required Action 8.1 and H.1 to' Initiate action in accordance with Specification 5.7.2' is no longer correct.
PAM report is not required by 5.7.2.
Either restore PAM report requirement to the Administrative Controls Section or be explicit in B.1 and H.l.
- 2) On Table 3.3.11-1, function 18 (AFW Flow), the REQUIRED CHANNELS from NUREG-1432
'2' have been changed to 'one per steam generator' with no annotation, explanation, or justification.
- 3) In the LCO section of the Bases, in paragraph I on EXCORE Neutron Flux, the bracketed 'At this unit, the [ wide-range] Neutron Flux PAM Channels consist of the following,'has been deleted.
No description of the SONGS EXCORE Neutron Flux instrumentation was provided.
The licensee should briefly describe the EXCORE Neutron Flux instrumentation here.
The licensee-description should document that this is a Type A variable (per the SER) and describe how it is used by the Emergency Operating Procedures.
4)
In NUREG-1432 in the LC0 section of the Bases, for Functions 1 and 6-11 the words 'For this unit, instrumentation consists of the following:' are bracketed. The 7 censee choose not to describe the instrumentation.
For a Type A variable, the description should include how i
the instrumentation is used in the Emergency Operating Procedures. This determination-should also apply to the licensee instrumentation added to the table (Functions 19 - 27).
5)
In the LC0 section of the Bases, in the last paragraph of 4 on RCS WR Pressure, references to this variable as a Type A variable have been deleted. The NRC SER indicates this instrumentation monitors a Type A l
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variable. This discrepancy should be resolved.
NOTE: The NRC SER identifies the following Functions of TABLE 3.3.11-1 as TYPE A variables; 1 - 7, 10, 12, 14 - 17,19, and 23 - 27. The licensee description should identify this instrumentation that monitors Type A variables and describe how it is used in the Emergency Operating Procedures.
(See previous comment.)
6)
In the LC0 section of the Bases, in paragraph 8 on Containment Isolation Valve Position, a line is missing.
The markup of NUREG-1432, insert A, included 'in a containment penetration flow path, i.
e., two total channels of PCIV' that was not transferred to the proposed SONGS Technical Specifications.
The licensee should restore that wording.
7)
In the LCO section of the Bases, in paragraph 12 on Steam Generator Water level, in the last sentence, ' extended startup range' should be ' wide-range.'
8)
In the LCO section of the Bases, in paragraph 13 on Condensate Storage Tank Level, it states that ' meter and annunciator are considered the primary indication used by the operator.' Annunciators are not post-accident monitoring instrumentation for this variable as defined in Regulatory Guide 1.97.
Stating the annunciator is a primary indication is erroneous.
The sentence should be reworded to delete mention of the annunciator as a primary indication.
9)
In the LC0 section of the Bases, in paragraph 18 on AFW Flow,
' Redundant monitoring capability is provided by two independent trains of instrumentation for each steam generator' was eliminated when incorporating the NUREG-1432 markup into the proposed SONGS Technical Specifications with no annotation, explanation, or justification.
10)
In the LCO section of the Bases in the proposed Tech Specs, on page B3.3-167, the following paragraph (as modified by the licensee (NUREG-1432 markup) was left out:
'In Table 3.3.11-1, the exception to the two channel requirement is Containment Isolation Valve Position, Auxiliary Feedwater Flow, Pressurizer Safety Valve Position Indication, HPSI Flow Cold Leg, and HPSI Flow Hot Leg.'
The licensee should restore this information. Also, on the same page, ' Plant Specific Evaluations in response to Item II.F.2 of NUREG-0737 (Ref. 3) should have identified the thermocouple pairings that satisfy these requirements' should be replaced with a positive statement in the SONGS-2/-3 Technical Specifications regarding the evaluation of pairings.
11)
In the Bases for SR 3.3.11.3, the CHANNEL FUNCTIONAL TEST should be described (as is done for other testing in SR 3.3.11.2, SR 3.3.11.4, and SR 3.3.11.5).
12)
In the Bases for SR 3.3.11.4, the proposed Technical Specifications gives an 18-month CHANNEL CAllBRATION interval, matching NUREG-1432 and its BASES. The proposed SONGS BASES was transposed to 24-months..
The licensee should correct the BASES to 18-months.
13)
In the Reference section of the Bases, is Reference 4, "NRC Safety Evaluation Report (SER)," needed? Where is reference to it?
'(
interchangeably.
Use of acronyms should be defined and consistent.
SPECIFICATION 3.3.12. REMOTE SHUTDOWN SYSTEM:
'l)
In Table 3.3.12-1 the following instruments are not included that are in Table 3.3-9 of the existing Tech Specs: Condenser Vacuum, Volume Control Tank Level, Letdown Heat Exchanger Pressure, and Letdown Heat Exchanger Temperature. Why are they excluded?
2)
In the Bases Background and LC0 sections, 'with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition...' has been changed to 'with sufficient instrumentation'to place and maintain the unit in a safe shutdown condition...' with no explanation or justification.
The controls must be available for the remote shutdown capability to function.
'And controls' should be restored to the BASES at the three applicable locations.
3)
In the Reference section of the Bases, mention of Reference 2 (HUREG-1432, Reference 3) 'NRC Safety Evaluation Report (SER),' has been deleted from the BASES.
Is the listed Reference 2 still necessary?
- 4) NUREG SR 3.3.12.2 to ' verify each required control circuit and transfer switch is capable of performing the intended function' was deleted.
The licensee states it is not a SONGS surveillance.
The current Technical Specifications do not require it.
The NUREG BASES /LC0 states the 'LCO is intended to ensure that the instrument and control circuits will be OPERABLE if plant conditions require that the Remote Shutdown System be placed in operation.'
How can this confidence be ensured without testing the controls?
SPECIFICATION 3.3.13. SR MONITORING CHANNELS:
1)
In the fifth sentence of the third paragraph of the Bases Background section, the word ' range' is repeated.
The second ' range' should be deleted.
2)
In the Bases for SR 3.3.13.3, the paragraph in NUREG-1432, beginning with "As found and as left calibration values are recorded," was eliminated from the markup with no justification.
Enclosure o
COMMENTS ON SCE STS SUBMITTAL FOR SAN ON0FRE 2 & 3 SPECIFICATION 3.5.1. SAFETY INJECTION TANKS:
1)
In the Applicable Safety Analysis Bases discussion on precautions to assure that the SITS are available during an accident, an explanation as to how the SIT vent valves are disabled to avoid inadvertent opening by either removing fuses or by opening the vent valve motor disconnect switches has been inserted.
It is also explained that the surveillance to ensure that power is removed from the vent valve to preclude opening is in the Licensee Controlled Specifications (LCS). The existing LC0 and Bases do not include the vent valves.
Since an open vent valve during operation would be readily apparent, this treatment may be acceptable.
However, an exolanation should be provided about why these valves should not be in TS.
2)
In the SR 3.5.1.4 Bases, it is proposed to delete from the Bases the sentence for verifying the boron concentration of the SIT, after having 1% or greater volume addition, by sampling, and in its Flace inserting a discussion that allows a calculation for this determination.
This calculation'is not explained.
Further justification for understanding this procedure should be provided.
SPECIFICATION 3.5.2. ECCS-0PERATING:
- 1) SR 3.5.2.1 has been divided into two parts, SR 3.5.2.1 a and SR 3.5.2.1 b.
This numbering is different from all other SR numbers.
Is it not preferable to renumber the SRs, doing away with the parts a and b?
2)
In the seventh paragraph of the Bases Background, an insert is added explaining that for LOCAs too small to initially depressurize the RCS below the shutoff head of HPSI pumps, reliance is placed on the charging pumps to maintain inventory.
It is stated that that is why motor operated auxiliary and manual auxiliary spray valves must remain locked closed and valves in the charging flow path to the RCS must remain open. ' This change is justified as a D1, Plant Specific Design difference.
The reason for the auxiliary spray line valves being required to be closed and locked is not adequately explained in the Bases.
SPECIFICATIpj_L L J. ECCS-SHUTDOWN:
t 1)
In the LCO Bases, the last sentence of this discussion incorrectly states that "in Mode 4 with RCS cold leg temperatu.e less than or equal to those specified in the PTLR, a maximum of one HPSI pump is allowed to be operable".
LC0 3.4.12.1 for the LTOP System states in the LCO, "No more than two high pressure safety injection pumps shall be operable..." The accident analysis supports two operable.
This should be changed.
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' SPECIFICATION 3.5.5. TSP:
- 1) The SR'3.5.5.1 and SR 3.5.5.2 Frequencies were changed from 18 months to 24 months to coincide with the proposed 24 month refueling outage and is as based on operating experience with the crystals.
It is feasible to
'do this SR only with the plant shut down.
The justification for this interval change is given as D1, Plant Specific Design.
Supporting evidence of acceptability of sustaining the TSP crystal volume for this added time is not provided, only the statement based on " operating experience". Other justification should be provided to ensure the crystal volume required by the analysis is available after 24 months in the event of an accident.
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